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

section 263 of the Act, to revise the assessment order should be quashed. 4 Shree N. H. Enterprises vs. PCIT 10. On the other hand, the Ld. DR for the revenue submitted that the assessing officer, disallowed 25% of bogus purchases, however, as per Ld. PCIT 100% purchases, which were bogus, should have been disallowed by the assessing officer, therefore

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)

section 143 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 & 2015-16. Since I.T.A Nos. 206 & 207/Rjt/2022 A.Ys. 2014-15 & 2015-16 Page No 2 DCIT Vs. M/s. Dhruv Craft Mill Pvt. Ltd. identical issue of bogus purchase is involved in both cases, the same are disposed

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)

section 143 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2014-15 & 2015-16. Since I.T.A Nos. 206 & 207/Rjt/2022 A.Ys. 2014-15 & 2015-16 Page No 2 DCIT Vs. M/s. Dhruv Craft Mill Pvt. Ltd. identical issue of bogus purchase is involved in both cases, the same are disposed

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

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 read with section 115BBE of the Act. (iv) The AO failed to conduct any verification or inquiry to ascertain the genuineness of these transactions, despite it being the primary reason for scrutiny selection

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)

bogus purchases from M/s Nazar Impex Pvt. Ltd. Undisputedly, the report from the investigation wing is a tangible material which was not available to the Assessing Officer during the I.T.A No. 258/Rjt/2022 A.Y. 2011-12 Page No 5 M/s. Premji Valji & Sons (Jewellers) Pvt. Ltd. vs. DCIT proceedings carried out on the earlier occasions. The Hon’ble Gujarat High Court

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

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

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 आदेश / O R D E R PER, Dr. DINESH MOHAN SINHA JM; Captioned two appeals filed

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been

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

8% of bogus purchase of Rs. 1,93,37,000/-. (ii) The estimation of suppressed sales done by the CIT(Appeals) by extrapolating certain percentage on accounted sales is unwarranted and also adoption of gross profit rate on suppressed sales is bad in law as if at all the profit was to be estimated, only net profit could have been