SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 62/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2018-19) Kamlesh Deoraj Jain Income Tax Officer, Ward-1, Plot No 35-36, Devashish Gandhidham, Income Tax Vs. Sector-5 Gandhidham 370201 Office, Plot No.32, Sector No.3, Near Iffco Colony, Gandhidham-370 201 "ायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (अपीलाथ"/Appellant) (""थ"/Respondent)

bogus purchases outside the books of accounts and therefore, the addition confirmed by the Tribunal in respect of the undisclosed income

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)

undisclosed income or source of such income. It was submitted that majority of salt sale by Neelkanth Group is out of India and to listed/multi- national companies in India. All such sales are made through banking channel and duly accounted for in the audited financial statements of group concerns and the same is verifiable from the financial statements and books

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

undisclosed income or source of such income. It was submitted\nthat majority of salt sale by Neelkanth Group is out of India and to listed/multi-\nnational companies in India. All such sales are made through banking channel\nand duly accounted for in the audited financial statements of group concerns and\nthe same is verifiable from the financial statements and books

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

undisclosed business income. Further, it is worthwhile to mention that assessee himself has stated having earned unaccounted income and investment / advances, therefore, considering the facts discussed above and provision of section 292C of the Act, assessee is liable to explain and owned all the liabilities arises against the transactions reflected on the impounded papers which were found from his office

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

undisclosed business income. Further, it is worthwhile to mention that assessee himself has stated having earned unaccounted income and investment / advances, therefore, considering the facts discussed above and provision of section 292C of the Act, assessee is liable to explain and owned all the liabilities arises against the transactions reflected on the impounded papers which were found from his office

PRIYANSI CORPORATION,DIST RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

bogus purchases, unaccounted cash loans,\nunaccounted payments, unaccounted receipts etc. The assessing officer noted\nthat seized documents containing name of the assessee are speaking documents\nand the seized page nos. A4-45, A8-180 are the invoices raised by Shamji\nKangad& Co. (entity owned by the member of Neelkangh Group) in the name\nof the assessee on various dates during

JITENDRABHAI DEVAJIBHAI BODAR,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal is dismissed as not admitted”

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

purchase and sale of shares of penny stock company and thereby adding the same as income from undisclosed sources. The addition made is totally unjustified on facts as also in law and deserves to be deleted and may kindly be deleted. 4. The learned AO grievously erred on facts as also in law in adding gross commission income

OSWAL AGRICOMM PRIVATE LIMITED,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

MAHAVIR IMPEX,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

NARENDRAKUMAR BHANWERLAL NIMBAVAT HUF,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

SHRI RAMJI HAMIR VIRDA,GANDHIDHAM vs. THE DCIT, CENTRAL CIRCLE-1, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

RISHABH STEEL SUPPLIER,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

bogus purchases, unaccounted cash loans, unaccounted payments, unaccounted receipts etc.The assessing officer noted that seized documents containing name of the assessee are speaking documents and the seized page nos. A4-45, A8-180 are the invoices raised by Shamji Kangad& Co. (entity owned by the member of Neelkangh Group) in the name of the assessee on various dates during

CHAMPALAL COMPANY,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for\nstatistical purposes

bogus purchases, unaccounted cash loans,\nunaccounted payments, unaccounted receipts etc. The assessing officer noted\nthat seized documents containing name of the assessee are speaking documents\nand the seized page nos. A4-45, A8-180 are the invoices raised by Shamji\nKangad& Co. (entity owned by the member of Neelkangh Group) in the name\nof the assessee on various dates during

OSWAL PETROCHEM,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for\nstatistical purposes

bogus purchases, unaccounted cash loans,\nunaccounted payments, unaccounted receipts etc. The assessing officer noted\nthat seized documents containing name of the assessee are speaking documents\nand the seized page nos. A4-45, A8-180 are the invoices raised by Shamji\nKangad& Co. (entity owned by the member of Neelkangh Group) in the name\nof the assessee on various dates during

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

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

undisclosed income of the firm, in addition to regular income for the financial year 2018-19. Thus, the amount of Rs.81,32,250/- disclosed ITA No. 312, 322 to 329/Rjt/2024 ITA No. 331 & 335 & 371/Rjt/2024 during the survey action was not recorded in the books of accounts when the partner has admitted it. The learned PCIT also noticed that

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

undisclosed income of the firm, in addition to regular income for the financial year 2018-19. Thus, the amount of Rs.81,32,250/- disclosed Page 6 during the survey action was not recorded in the books of accounts when the partner has admitted it. The learned PCIT also noticed that the disclosure has been made by the partner, after examining

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

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

undisclosed income of the firm, in addition to regular income for the financial year 2018-19. Thus, the amount of Rs.81,32,250/- disclosed ITA No. 312, 322 to 329/Rjt/2024 ITA No. 331 & 335 & 371/Rjt/2024 during the survey action was not recorded in the books of accounts when the partner has admitted it. The learned PCIT also noticed that

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

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

undisclosed income of the firm, in addition to regular income for the financial year 2018-19. Thus, the amount of Rs.81,32,250/- disclosed ITA No. 312, 322 to 329/Rjt/2024 ITA No. 331 & 335 & 371/Rjt/2024 during the survey action was not recorded in the books of accounts when the partner has admitted it. The learned PCIT also noticed that