PRAVINBHAI MOHANBHAI VADI,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.102/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Pravinbhai Mohanbhai Vadi The Pr. Commissioner Of बनाम Flat No.1, Prabhudeep Apartment Income Tax, Jamanagar. Air Force-2 Road Vs. Jamnagar. Pan : Agzpv6946P (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

bogus and were likely used to accommodate unaccounted money. Thus, purchases from these entities should have been disallowed and treated as unexplained expenditure under section 69C

M/S. R M TRADELINK,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

bogus purchases and made addition of " 76,86,510/- disallowing 30% of the purchase of " 2,53,99,953/- since no TCS was collected on the same. However, as per the Principal CIT, the entire purchase amounting to " 2,53,99,953/- should have been treated as un-expenditure in the nature of unverifiable purchases and the total amount

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

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL - 1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RJAKOT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

CLASSIC NETWORK PRIVATE LIMITED,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. CLASSIC NETWORK PVT. LTD., RAJKOT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

M/S. CLASSIC NETWORK LIMITED,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK LIMITED,, RAJKOT-GUJARAT

In the result, appeal filed by the assessee in ITA No

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

69C 2 143999517 Unexplained / unaccounted income 3 900000 Profits chargeable to tax as per Section 41(1) Total 17,39,72,425 Relevant Provision of the Income-tax Act 31. Aggrieved by the order of the assessing officer, the assessee, carried the matter in appeal, before the Ld.CIT(A), who has partly deleted the addition, observing as follows: “5.13 Having

JAY PRABHUDAS VITHALANI,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 75/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudas Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat-361001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent) आयकर अपीलसं./Ita No.74/Rjt/2025 (निर्धारणवर्ष / Assessment Year: (2021-22) Khushaboo Jaykumar Vithlani 201, Varajresidency, 8 – Patel Colony, Gujarat-361008 Vs. The Principal Commissioner Of Income Tax, Aayakar Bhavan, Lal Wadi Main Road, Kaushal Nagar, Gujarat - 361110 स्थायी लेखासं . / जी आइआरसं . / Pan/Gir.: Aefpv6723A (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri Sagar Shah, Ld. Ar : Shri Sanjay Kumar, Ld. Cit(Dr) : 19/06/2025 : 05/08/2025 आदेश / Order Per Dinesh Mohan Sinha, Jm: Captioned Two Appeals Filed By The Different Assessee, Pertaining To Assessment Year (Ay) – 2021-22, Are Directed Against The Separate Order Passed By The Principal Commissioner Of Income Tax [(In Short "Ld. Pr.Cit”] U/S. 263 Of The Act, Both Orders Dated 24.01.2025. 2. Since, These Two Appeals Filed By The Different Assessee For Same

69C r.w.s. of the Act. 3.5 The above peculiarities of the purchases lead to conclusion that the transaction of purchases are bogus and have remained unverified. The AO should have verified such transactions in details particularly when the core reason of selection of case for assessment is to verify the geniuses of purchases. However, it is seen that AO allowed

KHUSHBOO JAYKUMAR VITHLANI,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

69C r.w.s. of the Act. 3.5 The above peculiarities of the purchases lead to conclusion that the transaction of purchases are bogus and have remained unverified. The AO should have verified such transactions in details particularly when the core reason of selection of case for assessment is to verify the geniuses of purchases. However, it is seen that AO allowed