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)

unexplained money, respectively without considering the fact that the assessee duly furnished documentary evidence from the third party including bank statements and confirmation from the loan party, substantiating the sources of the investments made for the purchase of immovable property (shop). The assessee has verifiable and lawful sources for the investments, which stand fully explained as received from M/s Parekh

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

investment under section 69, towards purchase of raw material and\nmanufacturing expenditure in relation to the said unaccounted sales. Secondly, this is\nnot one of those cases where purchase bills were found to be raised against bogus\nentities, whereas the actual supplies were sourced from the grey market. In the\npresent case, the assessee is a manufacturer, the manufactured finished

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

investment not disclosed in the books of account. (ii)Addition of Rs. 6,77,34,130/-, on account of unexplained receipt of cash u/s. 69A of the Act. (iii)Addition of Rs. 54,04,130/- on account of bogus purchase

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

investment not disclosed in the books of account. (ii)Addition of Rs. 6,77,34,130/-, on account of unexplained receipt of cash u/s. 69A of the Act. (iii)Addition of Rs. 54,04,130/- on account of bogus purchase

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

investments, copy of demat account\nstatement reflecting purchases, evidence of sale of shares through stock exchange,\ncopy of demat statement showing the sale of shares and STT paid, etc. All\ntransaction made through proper banking channel. Sale of shares are made through\nmember of Bombay Stock Exchange.\n(The details regarding payment for purchase of shares and acquisition of shares

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

investments, copy of demat account\nstatement reflecting purchases, evidence of sale of shares through stock exchange,\ncopy of demat statement showing the sale of shares and STT paid, etc. All\ntransaction made through proper banking channel. Sale of shares are made through\nmember of Bombay Stock Exchange.\n(The details regarding payment for purchase of shares and acquisition of shares

MOHANBHAI SAVJIBHAI VEGAD,VADODARA vs. INCOME TAX OFFICER, VERAVAL

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

investment of on-money in the purchase of\nresidential property but the authorities below without pointing out any defect or\ninfirmity in such affidavit of the assessee as relied on the affidavit of the third party\nfor making the impugned addition. In our considered view, it was the onus upon the\nRevenue to disprove the affidavit furnished by the assessee

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

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

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

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

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

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

HARESH MOHANLAL PATEL,RAJKOT vs. ITO, WARD-2(1)(4), RAJKOT, RAJKOT

In the result, the assessee's appeal is partly allowed, in about terms

purchase another property, therefore, the assessee withdrew\ncash from the bank but after withdrawal of the cash from the from bank\naccount, the Demonetization Scheme was announced by the Central\nGovernment, therefore, deposited the same in the bank account. We find that\nthe amount deposited during demonetization period to the tune of\nRs.11,51,000/-, was partly from the property

KHUSHBOO JAYKUMAR VITHLANI,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

Bench: Dr. Arjunlal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 75/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2021-22) (Hybrid Hearing) Jay Prabhudasvithlani Vs. The Principal Commissioner Of 201, Varajresidency, 8 – Patel Colony, Income Tax, Gujarat – 361008 Aayakar Bhavan, Nr. Subhash Bridge, Jamnagar Rajkot Highway Gujarat – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv0266A (Appellant) (Respondent)

unexplained within the meaning of sec. 69C r.w.s. of the Act. 3.5 The above peculiarities of the purchases lead to conclusion that the transaction of purchases are bogus and have remained unverified. The AO should have verified such transactions in details particularly when the core reason of selection of case for assessment is to verify the geniuses of purchases. However

JAY PRABHUDAS VITHALANI,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, both the appeals of the same assessee (ITA No

unexplained\nwithin the meaning of sec. 69C r.w.s. of the Act.\n3.5 The above peculiarities of the purchases lead to conclusion that the\ntransaction of purchases are bogus and have remained unverified. The AO\nshould have verified such transactions in details particularly when the\ncore reason of selection of case for assessment is to verify the geniuses of\npurchases. However

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

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