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

70,81,357/- Components, Jamnagar 6 8 RasiklalParshottambhaiKateshiya, 9,92,728/- Proprietor of M/s Vadachi 80,31,784/- Products, Jamnagar 7 9 Jenul Abedin Ebrahim Darjada, Authorised person of M/s Sanjari 72,40,405/- 8,94,914/- Press Products, Jamnagar 8 10 VishalkumarHasumkhbhai 7,72,846/- Rabadiya, Proprietor of M/s M.K. 62,52,799/- Enterprise, Jamnagar ITA Nos.111-113/Rjt/2024A.Ys

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

70,81,357/- Components, Jamnagar 6 8 RasiklalParshottambhaiKateshiya, 9,92,728/- Proprietor of M/s Vadachi 80,31,784/- Products, Jamnagar 7 9 Jenul Abedin Ebrahim Darjada, Authorised person of M/s Sanjari 72,40,405/- 8,94,914/- Press Products, Jamnagar 8 10 VishalkumarHasumkhbhai 7,72,846/- Rabadiya, Proprietor of M/s M.K. 62,52,799/- Enterprise, Jamnagar ITA Nos.111-113/Rjt/2024A.Ys

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita Nos.111 To 113/Rjt/2024 निर्धारण वर्ष / Assessment Years: 2013-14 To 2015-16 Krupalu Metals Pvt. Ltd Income Tax Officer, बनाम / National Faceless Assessment Plot No..4345, Gidc, Phase- Vs. Centre, Delhi/Dcit, Circle-3, Iii, Udhyog Nagar, Jamnagar Jamnagar-361008 स्थायी लेखा सं/. जीआइआर सं/.Pan/Gir No.: Aadck6122 B (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से/Assessee By : Shri Sarvesh Gohil, Ld. Ar राजस्व की ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr-Dr सुनवाई की तारीख /Date Of Hearing : 27/02/2025 घोषणा की तारीख/Date Of Pronouncement : 22/05/2025 Per Bench: आदेश / Order Captioned Three Appeals, Filed By The Assessee, Pertaining To

70,81,357/- Components, Jamnagar 6 8 RasiklalParshottambhaiKateshiya, 9,92,728/- Proprietor of M/s Vadachi 80,31,784/- Products, Jamnagar 7 9 Jenul Abedin Ebrahim Darjada, Authorised person of M/s Sanjari 72,40,405/- 8,94,914/- Press Products, Jamnagar 8 10 VishalkumarHasumkhbhai 7,72,846/- Rabadiya, Proprietor of M/s M.Κ. 62,52,799/- Enterprise, Jamnagar

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)

bogus transaction. We note that there is no infirmity in the order passed by the CIT(A). That being so, we decline to interfere with the order of Id. CIT(A) in deleting the aforesaid additions. His order on this addition is, therefore, upheld and the grounds of appeal of the Revenue are dismissed. 7. As the issue is squarely

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

SMT. GRACY KUTHUMKAL THOMAS,,VERAVAL vs. THE JOINT COMMISSIONER OF INCOME TAX, JUNAGADH RANGE-1,, JUNAGADH

In the result, appeals of the Revenue and assessee, both are dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

bogus or incorrect. Assessing Officer has only raised a suspicion that the purchase are from unregistered dealers therefore they may be incorrect. Assessing Officer has not brought out any evidence by examining the suppliers of goods to reach any conclusion to reject the books of accounts. 4.2 Appellant has not accounted for the body parts of fish, which are removed

THE DEPUTY COMISSIONER OF INCOME TAX, CIRCLE-1,, JUNAGADH vs. SMT. GRACY KUTHUKMAL THOMAS,, VERAVAL

In the result, appeals of the Revenue and assessee, both are dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

bogus or incorrect. Assessing Officer has only raised a suspicion that the purchase are from unregistered dealers therefore they may be incorrect. Assessing Officer has not brought out any evidence by examining the suppliers of goods to reach any conclusion to reject the books of accounts. 4.2 Appellant has not accounted for the body parts of fish, which are removed

THE DY. COMMR. OF INCOME TAX, CIR.-2,, JAMNAGAR vs. ADITYA COKE PRIVATE LIMITED,, BHACHAU - KUTCH

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 554/Rjt/2015 िनधा"रण वष"/Asstt. Years: 2012-2013 D.C.I.T., Aditya Coke Private Limited, Circle-2, Vs. Survey No.14, Jamnagar Village Chopadva, Tal. Bhachai, Dist. Kutch, (Gujarat)

section 41(1) of the Act was justified in law. 10.5 Coming to the facts of the present case, we note that the assessee itself has admitted during the assessment proceedings that it is not approaching to the creditors namely M/s Khodiyar Enerprise, Krishna Enterprise, Karan Enterprise and A.Y. 2012-13 8 SK Corporation as it is reluctant to make

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

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

ITO WARD 3(1)(4), RAJKOT-STATION- AMRELI, AMRELI, GUJARAT vs. AVADH AGRI EXPORTS, AMRELI, GUJARAT

In the result, appeal filed by the revenue is dismissed

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

70,116/-. 10.Aggrieved by the order of the Ld. CIT(A), the Revenue is in appeal before us. 11. We have heard both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings

BHIKHALAL PRAHALADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

section 147 of the Act. The reasons of reopening are reproduced by the AO on Page No. 1 to 8 of the reassessment order, which we have gone through. On perusal of the reasons recorded for reopening, it may be observed that the reopening u/s 147 of the Act has been initiated in the case of the assessee

BHIKHALAL PRAHLADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

section 147 of the Act. The reasons of reopening are reproduced by the AO on Page No. 1 to 8 of the reassessment order, which we have gone through. On perusal of the reasons recorded for reopening, it may be observed that the reopening u/s 147 of the Act has been initiated in the case of the assessee

DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. VASANTBHAI MULJIBHAI KANANI, JAMNAGAR

In the result, appeal filed by the revenue is dismissed, whereas appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Dy. Cit, Cir-1 Vasantbhai Muljibhai Kanani बनाम Jamnagar. Plot No.7, Ambica Enterprise Vs. Sardar Patel Ind. Estte-4 Indira Road Opp: Jakat Naka, Jamnagar-361004 (Guj) Pan : Aitpk 8038 P आयकर अपील सं /.Ita No.08/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Vasantbhai Muljibhai Kanani Dy. Cit, Cir-1 बनाम Plot No.7, Ambica Enterprise Jamnagar. Sardar Patel Ind. Estte-4 Vs. Indira Road Opp: Jakat Naka, Jamnagar- 361004 (Guj) Pan : Aitpk 8038 P (अपीलाथ"/Assessee) : (""यथ"/Respondent)

70,90,800/- amount of lenders, than how the partial-genuineness of Rs.15,82,200/- can be un-explained? Genuineness of the lenders cannot be considered in part, this shows CIT(A) has negligently passed the assessee order and the same is required to be set aside for the addition confirmed of Rs.15,82,200/- when the order is silent

RADHE RENEWABLE ENERGY DEVELOPMENT PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

bogus transactions is not sustainable. Accordingly, we direct the AO to delete the same. It is not out of the place to mention that learned 19 A.Y.2011-12 and others CIT-A has deleted the addition made by the AO after elaborate discussion which has been reproduced somewhere in the preceding paragraph. The learned DR at the time of hearing