BHARATKUMAR KALYANJIBHAI BHINDI,JUNAGADH vs. PCIT, RAJKOT-1, RAJKOT , RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

THE ACIT, CEN. CIR.-2, RAJKOT, RAJKOT vs. EXPERT PARTICLE BOARD, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

69A of the Act which is the total of the credit side of the notebook by treating the same as cash receipts from unaccounted sources. It is further seen that, he made disallowance of Rs. 54,04,130/- u/s 37 of the Act on the alleged ground of bogus purchases, that is, cash received from the suppliers against purchase claimed

THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT vs. SHRI BHAGVANJI PRABHUBHAI AMRUTIYA, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

69A of the Act which is the total of the credit side of the notebook by treating the same as cash receipts from unaccounted sources. It is further seen that, he made disallowance of Rs. 54,04,130/- u/s 37 of the Act on the alleged ground of bogus purchases, that is, cash received from the suppliers against purchase claimed

THE DCIT CENTRAL CIRCLE-1 , RAJKOT vs. SHRI SHAMJIBHAI SADHABHAI KANGAD, GANDHIDHAM-KUTCH

In the result, appeal filed by the Revenue, in IT(SS) No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआ.(खो और ज).सं./It(Ss)A Nos.11 To 20/Rjt/2022 "नधा"रण वष"/ Assessment Years:2011-12 To 2020-21 बनाम/ Shri Shamjibhai Sadhabhai Deputy Commissioner Of Kangad Income Tax, Central Circle-1, Vs. Bbz-S-60, Zanda Chowk, “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Adepk 3471 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.21 To 23/Rjt/2022 "नधा"रण वष"/ Assessment Years:2014-15, 2016-17 &2017-18 बनाम/ Deputy Commissioner Of Income Shri Shamjibhai Sadhabhai Tax, Central Circle-1, “Amruta Kangad Vs. Estate”, 2Nd Floor, M.G. Road, Bbz-S-60, Zanda Chowk, Rajkot-360001 Gandhidham-370 201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aabca 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.15/Rjt/2023 "नधा"रण वष"/ Assessment Year:2019-20 बनाम/ Deputy Commissioner Of Shri Hetab Shamjibhai Kangad Income Tax, Central Circle-1, Bbz-South-60, Zanda Chowk, Vs. “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aqtpk 7484 M (अपीलाथ"/Assessee) (""यथ"/Respondent)

bogus purchase is completely illogical. The averments made by Shri Naran Maheshwari in his statement was clarified by him in his duly sworn affidavit. Here it is relevant to emphasise that salt procurement and manufacturing industries by and large are driven by the unorganised and unskilled labourers / agents and village people, staying remotely in desert or forest there for they

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

section 132A, then, the provisions of sub-section (1) shall\napply as if such books of account, other documents or assets which had been taken into custody from\nthe person referred to in clause (a) or clause (b) or clause (c), as the case may be, of sub-section (1) of\nsection 132A, had been found in the possession

TALSHIBHAI KANJIBHAI NAROLA,DAMNAGAR vs. THE ITO WD 3(1)(4), RKT, AMRELI-RAJKOT

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

section 147 r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”), vide order dated 22.03.2023. Talsibhai K. Narola 2. Grounds of appeal raised by the assessee are as follows: 1. The learned Commissioner (Appeals), National Faceless Appeal Centre (NFAC), Delhi erred in dismissing the appeal of the Appellant ex-parte, by failing to appreciate that the Appellant

M/S. DHRUV CRAFT MILL PVT. LTD.,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

DHRUV PRINT PACK INDUSTRIES,MORBI vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year, should be treated, as deemed income in view of the provisions of section

HETALKUMAR PRAVINCHANDRA RAJYAGURU,RAJKOT vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

purchase\nand sales made by him, during the year under consideration. Such\nexplanation of the assessee, which is not backed by any corroborative\nevidence, was not accepted by ld PCIT. The ld PCIT also noticed that\nmerely saying that the noting in the note book were unaccounted\npurchase and sales made by him during the year under consideration is\nnot

NARANJI RAJARAM DAVE,PORBANDAR vs. INCOME-TAX OFFICER, WARD-2(3), PORBANDAR , PORBANDAR, GUJARAT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 822/Rjt/2024 ("नधा"रणवष"/Assessment Year: (2017-18) Naranji Rajaram Dave, Income Tax Officer, Wd -2(3), Vs. Porbandar-360575 17, 17 Naranji Rajaram Dave, Suttar Vada, Porbandar, Suttar Vada, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acjpd8823B (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 69A of the Income Tax Act, 1961, cannot be invoked in case where the transactions relating to the cash deposited into the bank account were recorded in the books of accounts and got them Audited by a Chartered Accountant and arrived the correct taxable income. The ld.Counsel has further contended that the assessing officer has accepted the books

VISHAL KANAIYALAL DESAI,BHUJ vs. ACIT CIRCLE GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is allowed for statistical purposes

bogus LTCG\nfrom penny stock scrip. Ld. CIT(A) erred in law as well as on facts in not adjudicating\nthe same.\n8. Ld. AO erred in law as well as on facts in invoking provision of section 69A r.w.s.\n115BBE in respect of the disclosure made by the appellant Rs. 25,05,400/- on account\nof fees from patients

HARESH MOHANLAL PATEL,RAJKOT vs. ITO, WARD-2(1)(4), RAJKOT, RAJKOT

In the result, the assessee's appeal is partly allowed, in about terms

section 69A of the Act.\n4.\nAggrieved by the order of the Assessing Officer, the assessee carried the\nmatter in appeal before the Ld.CIT(A), who has confirmed the action of the\nAssessing Officer. The ld. CIT(A) noted that during the assessment\nproceedings, assessee has failed to prove the genuineness of the cash deposit\nwith documentary evidences, therefore

CHUNILAL GOVIND VANIK,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section

SHAMJI NATHU VAISHYA,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section

KISHOR VELJIBHAI FOFANDI,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section

DEEPMALA MARINE EXPORTS,VERAVAL vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section

SOHAM PAPERS PRIVATE LIMITED,MORBI vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

purchase and sales made by him during the year under consideration is not sufficient to claim these unaccounted receipts as business receipts. Therefore, ld. PCIT observedthat excess stock found during the survey and admitted by the assessee, as its income earned during that year,should be treated, as deemed income in view of the provisions of section

CORUS VITRIFIED PVT. LTD.,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

bogus companies, since the same would amount to double taxation. Further, on perusal of the order passed by ld. PCIT, it is seen that the ld. PCIT has not established as to how the repayment of loans falls u/s. 69C of the Act when the assessee has not claimed the same as expenditure and also when the source of such