THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

purchase which could be added in income of assessee and thus, rightly so done by Commissioner (Appeals) and Tribunal - Held, yes [Paras 6 & 7] [In favour of assessee]." (iii) CIT vs. Bholanath Poly Fab (P) Ltd (2013) 355 ITR 290 (Guj-HC]: in this case it is held that: "Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus

THE DCIT, CIRCLE-1 (1), , RAJKOT vs. M/S. DHRUV CRAFT MILL PVT. LTD., VILLAGE: - LILAPAR, TAL. & DIST. MORBI,

In the result, both the appeals filed by the Revenue are hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

purchase which could be added in income of assessee and thus, rightly so done by Commissioner (Appeals) and Tribunal - Held, yes [Paras 6 & 7] [In favour of assessee]." (iii) CIT vs. Bholanath Poly Fab (P) Ltd (2013) 355 ITR 290 (Guj-HC]: in this case it is held that: "Section 69 of the Income-tax Act, 1961 Undisclosed investments [Bogus

THE INCOME TAX OFFICER, WARD-4,, MORBI vs. M/S. RANG CERA COAT, , MORBI

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar"नधा"रणवष"/Assessment Year: 2011-12 Income Tax Officer, Vs. M/S. Rang Cera Coat, Ward-4, 8-A, National Highway, Morbi Morbi Pan :Aalfr 1616 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri B.D. Gupta, Sr. Dr Assessee By : Shri Vimal Desai, Ar सुनवाई क" तार"ख/Date Of Hearing : 14.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 25.01.2023

Section 131 of the Act had evidentiary value. The learned CIT(A) was convinced with the explanation of the assessee that the entire purchases could not be disallowed as being bogus noting the fact that being a trader and the sales having not been doubted, there was no question of corresponding purchases in relation to the said sales having

SHREE N H ENTERPRISES,RAJKOT vs. PCIT-1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 227/Rjt/2025 िनधा"रण वष"/ Assessment Year: (2021-22) Shree N. H. Enterprises बनाम/ Pcit-1, D-101, Golden Portico Apartment, Dr. Income Tax Office, Vs. Madhapar Circle, Morbi Road, Rajkot- Rajkot-360007 360007 /. /. Pan/Gir No.: Adlfs7019K "थायीलेखासं जीआइआरसं (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) सुनवाई क" तारीख /Date Of Hearing : 07/10/2025 : 20/11/2025 घोषणा क" तारीख /Date Of Pronouncement

7 Shree N. H. Enterprises vs. PCIT of Bholanath Ploy Fab Pvt Ltd. (2013) 40 taxman.com 494 (Gujarat), wherein the Hon'ble court upheld the decision of the ITAT that the purchases were made from bogus parties, but the purchases themselves were not bogus as entire quantity of opening stock, purchases and the quantity manufactured during the year under consideration

M/S. PREMJI VALJI & SONS (JEWELLERS) P. LTD.,RAJKOT vs. THE DCIT, CIRCLE - 2 (1), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is partly allowed for the statistical purposes

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed, Accountant, Judic Member आयकरअपीलसं./Ita Nos.257 & 223/Rjt/2022 निर्धररवरध/Asstt. Years: 2010-11 & 2012-13 M/S Premji Valji & Sons D.C.I.T, (Jewellers) Pvt. Ltd. Vs. Circle-2(1), “Kuvarjibhai Tower” Rakot. Palace Road, Rajkot-360001. Pan: Aaccp2555N

section 147 of the Act in the given facts and circumstances. Hence, the ground of appeal of the assessee is hereby dismissed. 8. The second issue raised by the assessee is that the ld. CIT(A) erred in confirming the addition made by the Assessing Officer in part being 25% of bogus purchases instead of deleting the same in entirety

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

7. We hereby submit stock register having Party Name, Inward Quantity, Inward Value, Outward Quantity, Outward Value and closing quantity and value for honours kind verification, 8. It was submitted that all of purchases are genuine and paid through banking channel from the said purchases we have sold goods and declared the same as sales. If the purchases

M/S. PREMJI VALJI & SONS (JEWELLERS) P. LTD.,RAJKOT vs. THE DCIT, CIRCLE - 2 (1), RAJKOT, RAJKOT

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

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

section 147 of the Act in the given facts and circumstances. Hence, the ground of appeal of the assessee is hereby dismissed. I.T.A No. 258/Rjt/2022 A.Y. 2011-12 Page No 6 M/s. Premji Valji & Sons (Jewellers) Pvt. Ltd. vs. DCIT 5. The second issue raised by the assessee is that the ld. CIT(A) erred in confirming the addition made

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

7 and 8 of his Order by treating the purchase made from Ankit Metals, as Bogus Purchase and rendering the said purchase transactions to be unexplained. 3. The learned PCIT has erred in law vide para 9 and 10 of his Order by invoking Section

ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM vs. KAMLESH DEORAJ JAIN, GANDHIDHAM

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 594/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Assistant Commissioner Of Income Vs. Kamlesh Deoraj Jain, Tax, Bbz-N-108, Khanna Market, Plot No. 20/A, Sector No. 8, Gandhidham, Gandhidham Gandhidham Gujarat 370201 Gujarat 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (Appellant) (Respondent) Appellant By : Shri Sunil Maloo, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 21/ 01 /2026

section 68 of the Income-tax Act. 1961. AO observed that The primary onus on the appellant to prove that the purchases claimed by it are genuine and are wholly and exclusively for the purpose of business. ACIT vs. Kamlesh Deoraj Jain AO has concluded that the transactions undertaken with M/s Ankur Chemfood Ltd. were in the nature of circular

VIJAY ANANDBHAI CHAVDA,GONDAL vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT , RAJKOT

In the result, the order passed by the PCIT u/s 263 of the Act is hereby dismissed

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

7,75,000 Unexplained Gift 68 2. 18,83,64,331/- Unexplained sundry Section not creditors mentioned by the A.O. 3. 6,00,56,842/- 5% of purchase Section not mentioned by the A.O. 4. 1,34,27,150/- Bogus

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

bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021 (AY : 2019-20) with CO No.05/RJT/2022 17 23. Before the learned CIT (A), the assessee submitted that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A

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

bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board and Others ITA No.139 /RJT/2021 and 142/RJT/2021 (AY : 2019-20) with CO No.05/RJT/2022 17 23. Before the learned CIT (A), the assessee submitted that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A

SAMEER SHAH (HUF),1 "SWAPNEEL" ,OPP. GURUDATATREY TEMPLE PALACE ROAD vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.248/Rjt/2025 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Sameer Shah (Huf), Vs. The Ito Ward 1(3), 1 “Swapneel”, Opp. Jamnagar - 361001 Gurudatatrey Temple, Palace Road, Jamnagar - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawhs3749E (Appellant) (Respondent)

7. Based on the set of facts and evidence on record the order passed by the Ld. FAO as well as order passed by National Faceless Appeal Centre under Section 250 has erred in law as well as on facts in passing the appellate order and in contending that assessee was involved in the bogus LTCG and price ragging activity

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC CIT(A), DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

section 69, towards purchase of raw material and manufacturing expenditure in relation to the said unaccounted sales. The addition is duly supported by factual findings of the search action, as discussed in detail in the preceding paragraphs. Inparticular, the following evidence brings out that the corresponding purchase of raw material (and consequently the manufacturing expenditure related thereto) were also

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

section 69, towards purchase of raw material and manufacturing expenditure in relation to the said unaccounted sales. The addition is duly supported by factual findings of the search action, as discussed in detail in the preceding paragraphs. Inparticular, the following evidence brings out that the corresponding purchase of raw material (and consequently the manufacturing expenditure related thereto) were also

M/S. BABJI OIL MILL PVT. LTD.,,RANEKPAR, TAL. WAKANER, DIST. MORBI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, MORBI CIRCLE, , MORBI

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal, Judicial Member M/s. Babji Oil Mill Pvt. Ltd., 8- (Accountant Member)

bogus purchase. The addition needs deletion. 4. Taking into consideration the legal, statutory, factual, accounting and administrative aspects, no addition amounting to Rs. 22,70,0007- and Rs. 3,17,87,900/- ought to have been confirmed. The addition needs deletion. 5. Without prejudice, the assessment made is bad in law and deserves annulment. 6. Without prejudice, no adequate, sufficient

NISHANT PAREKH - LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 196/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2012-13) Nishant Parekh – Legak Heir Of Mina Income Tax Officer, Wd – 1(3), Parekh Vs. Aayakar Bhavan, 322, Madhav Square, Opp. Avantika Jamnagar – 361001 Complex, Limda Lane Road, Jamnagar – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (अपीलाथ"/Assessee) (""यथ"/Respondent)

purchase and sales of said shares was bogus, the Assessing Officer was not justified in absence of any material to support his finding that there has been collusion or connivance between the broker and the assessee for the introduction of his own unaccounted money, resulting into a bogus transaction. We note that there is no infirmity in the order passed

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587 2 2015-16 6,67,76,311 - 6,67,76,311 53,42,105 3 2018-19 7

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

Bogus Total Income @ Sales Purchases 8.0% 1 2013-14 5,01,82,334 - 5,01,82,334 40,14,587 2 2015-16 6,67,76,311 - 6,67,76,311 53,42,105 3 2018-19 7