KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

purchase of Gold Bar dtd. 25/12/1985 is bogus and to treat sale proceed of Gold Bar as income from undisclosed sources. Further, CITA)-NFAC observed that sale bill is for sale of gold bar, whereas as per Wealth Tax Return the items shown are gold ornaments and the Appellant did not file copy of Valuation Report at any stage

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

credit side of the notebook by treating the same as cash receipts from unaccounted sources. It is further seen that, he made disallowance of Rs. 54,04,130/- u/s 37 of the Act on the alleged ground of bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board

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

credit side of the notebook by treating the same as cash receipts from unaccounted sources. It is further seen that, he made disallowance of Rs. 54,04,130/- u/s 37 of the Act on the alleged ground of bogus purchases, that is, cash received from the suppliers against purchase claimed in the books of account. ACIT Vs. Expert Particle Board

ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. GRENIC TILES PVT LTD, MORBI

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

unexplained cash credit u/s 68". Again, the reliance\nis placed on the decision of Hon'ble M.P. High Court in the case of Addl.\nCIT vs. Ghai Lime Stone Co. (1983) 144 ITR 140(MP), wherein it was held\nthat trade advances or cash received against which goods is supplied\nsubsequently is not a cash credit as contemplated by section

GRENIC TILES PRIVATE LIMITED,WANKANER-MORBI vs. ASST.COMMISSIONER OF INCOME-TAX CIRCLE 1(1) RKT, RAJKOT

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

unexplained cash credit u/s 68\". Again, the reliance\nis placed on the decision of Hon'ble M.P. High Court in the case of Addl.\nCIT vs. Ghai Lime Stone Co. (1983) 144 ITR 140(MP), wherein it was held\nthat trade advances or cash received against which goods is supplied\nsubsequently is not a cash credit as contemplated by section

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

bogus purchase is\ncompletely illogical. The averments made by Shri Naran Maheshwari in his\nstatement was clarified by him in his duly sworn affidavit. Here it is relevant to\nemphasise that salt procurement and manufacturing industries by and large are\ndriven by the unorganised and unskilled labourers / agents and village people,\nstaying remotely in desert or forest there for they

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)

bogus liability of Rs. 1,34,27,ISO/- on account of advances from debtors as cash credits u/s. 68 of the Act and charging the tax liability thereon u/s. 115BBE of the Act. The appellant craves leave to add, alter, amend, delete or withdraw one or more grounds of appeal.” 3. The brief facts of the case are that return

M/S. PARAG OIL MILL,PORBANDAR vs. THE ITO WARD-2 (4),, PORBANDAR

In the result, both the appeals of the assessee are allowed for statistical purpose for both the Assessment Years i

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

unexplained cash credit. The Counsel for the assessee submitted that the Ld. CIT(A) has made a substantial enhancement without giving adequate opportunity of hearing to the assessee and also ignoring the request for adjournment. He further submitted that Ld. CIT(A) while passing the order at Para 6.4 has observed that the assessee has not submitted the whole trail

M/S. PARAG OIL MILL,PORBANDAR vs. THE ITO WARD-2 (4),, PORBANDAR

In the result, both the appeals of the assessee are allowed for statistical purpose for both the Assessment Years i

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

unexplained cash credit. The Counsel for the assessee submitted that the Ld. CIT(A) has made a substantial enhancement without giving adequate opportunity of hearing to the assessee and also ignoring the request for adjournment. He further submitted that Ld. CIT(A) while passing the order at Para 6.4 has observed that the assessee has not submitted the whole trail

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)

cash credit. The addition needs deletion. 3. The Ld. CIT(A) has erred in law and facts confirming addition of an amount of Rs. 3,17,87,900/- treating the same as unexplained 7 bogus purchase

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

unexplained income of the appellant and to revise the assessment order. 5. Being aggrieved by the above order of the Ld. PCIT u/s. 263 dated 09.02.2024 of the Act, the appellant has filed this appeal before us. Global extrusions pvt. Ltd. 6. During the course of hearing the Ld. AR has submitted that a notice issued on account bogus purchase

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

unexplained cash credit u/s 68 of the Act. 5. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has confirmed the action of the Assessing Officer. So far reopening of assessment is concerned, the ld. CIT(A) observed that no any non-compliance with the procedural ITA Nos.779

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

unexplained cash credit u/s 68 of the Act. 5. Aggrieved by the order of the Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has confirmed the action of the Assessing Officer. So far reopening of assessment is concerned, the ld. CIT(A) observed that no any non-compliance with the procedural ITA Nos.779

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

credit-worthiness of the creditor /shareholder and ascertain whether the transaction is genuine, or these are bogus entries of name-lenders, has failed to conduct verifications/inquiries that should have been done and accepted the share capital as well as the unsecured loans as genuine.\n8. The Ld.PCIT noticed that trade payables of Rs. 11,61,51,118/-,have been reported

MISS PARI ANIL GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

cash credit u/s 68 of the Income tax Act 1961 (Para 3 of submission). The\nassessee has further stated that there no iota of deficiencies of any kind found with\nregard to the documentation (Para 4 of submission). At para 1.5 of the submission, the\nassessee has emphasized that every transaction has been accounted, documented and\nsupported. The payments

LATE SMT. PRITI A. GANDHI L/R. SHRI ANILBHAI A. GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

cash credit u/s 68 of the Income tax Act 1961 (Para 3 of submission). The\nassessee has further stated that there no iota of deficiencies of any kind found with\nregard to the documentation (Para 4 of submission). At para 1.5 of the submission, the\nassessee has emphasized that every transaction has been accounted, documented and\nsupported. The payments

SMT. MADHVIBEN NILESHKUMAR GANTRA,RAJKOT vs. THE ITO, WARD-1 (2) (5), RAJKOT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 47/Rjt/2020 िनधा"रण वष"/Asstt. Year: 2011-12 Smt. Madhaviben Nileshkumar Income-Tax Officer, Ganatra, Vs. Ward-1(2)(5), 1St Floor Tirupati Appt., Rajkot. Rajputpara, Rajkot-360001. Pan: Asdpg2945B

unexplained cash credit. 5. The facts in brief are that the assessee in the present case is an individual and claimed to be engaged in the business of Share Trading. For the year under consideration, no return under section 139 of the Act was filed by the assessee. Subsequently, the AO received information from DDIT Mumbai that the assessee

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

unexplained cash credit u/s. 68. The detailed response to show cause notice along with evidences justifying genuineness of the transactions was furnished, before the assessing officer. In this regard, the ld. Counsel relied on certain case-law, which we have gone through. The ld. Counsel stated that assessing officer, having gone through the documents of the assessee has passed

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)

credit. 5. The Ld. CIT(A) has erred on the facts and in law in not appreciating the fact that the assessee has not been able to demonstrate the creditworthiness of the lenders before the assessing officer with sufficient documentary evidences particularly when the income declared by these lenders do no commensurate with the loans so advanced