THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The 'Angadiya/shroff' have disclosed the modus-operandi in clear terms. vi. The "Angadiya" is a very common term in Gujarat. Another common term related to monetary transactions is "shroff

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The 'Angadiya/shroff' have disclosed the modus-operandi in clear terms. vi. The "Angadiya" is a very common term in Gujarat. Another common term related to monetary transactions is "shroff

SHRI VISHAL MEHTA,RAJKOT vs. THE ITO WARD-2 (1) (2), RAJKOT, RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The ‘Angadiya/shroff’ have disclosed the modus-operandi in clear terms. ITA Nos.74-77/Rjt/2024 (AYs-12-13 to 15-16) Vishal Mehta 17 vi. The “Angadiya” is a very common term

SHRI VISHAL MEHTA ,RAJKOT vs. THE ITO WARD-2(1) (2) RAJKOT, RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The ‘Angadiya/shroff’ have disclosed the modus-operandi in clear terms. ITA Nos.74-77/Rjt/2024 (AYs-12-13 to 15-16) Vishal Mehta 17 vi. The “Angadiya” is a very common term

SHRI VISHAL MEHTA,RAJKOT vs. THE ITO WARD-2(1) (2) , RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The ‘Angadiya/shroff’ have disclosed the modus-operandi in clear terms. ITA Nos.74-77/Rjt/2024 (AYs-12-13 to 15-16) Vishal Mehta 17 vi. The “Angadiya” is a very common term

SHRI VISHAL MEHTA ,RAJKOT vs. THE ITO WARD-2 (1) (2), RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums as unexplained cash deposits and taxed the entire amount as deemed income. The ‘Angadiya/shroff’ have disclosed the modus-operandi in clear terms. ITA Nos.74-77/Rjt/2024 (AYs-12-13 to 15-16) Vishal Mehta 17 vi. The “Angadiya” is a very common term

SHRI RAMA MEPA ODEDARA,PORBANDAR vs. THE INCOME TAX OFFICER, WARD-2(4),, PORBANDAR

In the result, Ground No. 2 of the assessee’s appeal is partly allowed

Bench: Us, The Counsel For The Assessee Submitted An Application For Condonation Of Delay & Argued That The Reason For Delay In Filing Appeal Before Itat Was That The Assessee Was Suffering From Spinal Injury & Was Advised Complete Bed Rest By The Doctors. In Support Of The Above Contention, The Assessee Also Filed Medical Certificate With Respect To The Injury Suffered

condoning the delay of 126 days in filing of the present appeal. On jurisdiction 4. On jurisdiction, the assessee has challenged the initiation of proceedings under section 147 of the Act. However, we observe that in the instant set of facts, there was a substantial cash deposit

HARUNBHAI NOORMAMD JINDANI,JAMNAGAR vs. ITO, WARD 2(7), JAMNAGAR, JAMNAGAR

In the result, the appeal filed by the assessee is partly allowed, in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 407/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Harunbhai Noormamd Jindani The Income Tax Officer, Ward-2(7), Kishan Chowk, Behind Bodyg, Vs. Jamnagar-Rajkot Highway, Jamnagar - 361001 Jamnagar-361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Anxpj4114C (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 02/09/2025 Date Of Pronouncement : 17/11/2025 Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 20.09.2023, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S. 144 Of The Act, On 11.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows:

cash deposited in bank account as unexplained. The Commissioner of Income Tax (Appeals) has erred on facts and in laws in partly confirming the addition of Rs.7,48,000/-.” 3. This appeal filed by the assessee is barred by limitation by 572 days. The assessee has moved a petition for condonation of delay

SHRI RAVI PARSOTAMBHAI ASANANI,VILLAGE JETPUR, DIST. RAJKOT vs. THE ITO WARD 1 (2) (1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainiआयकरअपीलसं आयकरअपीलसं./Ita No. 434/Rjt/2025 ("नधा"रणवष" "नधा"रणवष"/Assessment Year: (2013-14) Ravi Parsotambhai Asnani Income Tax Officer, Nfac, Delhi Income Tax Officer, Nfac, Delhi Prop., Jay Ambe Textile, M.G.Road, Prop., Jay Ambe Textile, M.G.Road, Vs. Aayakar Bhavan, Race Course Ring Aayakar Bhavan, Race Course Ring Jetpur – 360370 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Pan/Gir No.: Amnpa7007Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

condonation of delay, are as follows; “In connection with the above appeal the applicant most In connection with the above appeal the applicant most humbly and respectfully begs to humbly and respectfully begs to state and submit as under: under: 1] The case of the applicant was reopened. The applicant filed the return in response 1] The case

FUSION GRANITO PRIVATE LIMITED,MORBI vs. THE PR. COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed for statistical purposes, in above terms

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.190/Rjt/2023 (िनधा"रण वष" / Assessment Year: (2018-19) (Physical Hearing) Fusion Granito Pvt. Ltd. बनाम/ Principal Commissioner Of Income Revenue Survey No.555/P1/91, Tax-1, Vs. Nr. Khokhra Hanuman Temple, 2Nd Jetpar Road, Morbi-363641 Rajkot, Floor, “Aayakar Bhawan”, Race Course Ring Road, Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcf 0696 B (अपीलाथ"/Appellant) (""थ" /Respondent) अपीलाथ" ओर से/ Appellant By Shri Bandish Soparkar, Ar ""थ" की ओर से/Respondent By Shri Praveen Verma, Cit Dr सुनवाई की तारीख/Date Of Hearing 24/06/2025 घोषणा की तारीख /Date Of Pronouncement 10/09/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax - 1, Rajkot [In Short ‘Ld. Pcit’], Dated 27.03.2023, Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The ‘Act’] For The Assessment Year (Ay) 2018-19. 2. Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: “1. The Revision Order U/S 263 Of The Act Dated 28.03.2023 Is Bad In Law. 2. The Hon’Ble Pr. Cit-1, Rajkot Has Erred In Law As Well As On Facts In Completing The Revision Proceedings U/S 263 Of The Act Hurriedly In Short Span Of Time Fusion Granito Pvt. Ltd.

cash, which he has deposited in his bank account before the issuance of cheque towards purchase of shares. The “source of the source” has not been examined by PCIT, as well as by AO as the assessee did not submit the documents and evidences to prove the source of the source. Therefore, the order passed by the Assessing Officer

HOTHI SAMAT KESHWALA,PORBANDAR vs. INCOME TAX OFFICE, WARD 2(4), PORBANDAR, PORBANDAR

In the result, the appeal filed by the assessee is partly allowed in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 408/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Hothi Samat Keshwala Ito, Wd – 2(4), At Visavada, Via Bokhira Porbandar, Vs. Income Tax Office, Nh-8E, Porbanadar – 360575 Porbandar Road, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Buppk0380P (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 02/09/2025 : 25/11/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 05.08.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Vide Order 21.10.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

cash deposited in bank account.” 1 Hothi Samat Keshwala 3. Brief facts qua the issue are that, the appeal filed by the assessee is barred by limitation by 252 days. The assessee has moved a petition for condonation of delay

SHREE SAMARTH SWITCHGEAR AND TRANSMISSION PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

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

condonation of the delay, in ITA No.612/RJT/2024, as a sample,for adjudicating the respective delay in filing these three appeals. The contents of the petition for donation of delay submitted before the Bench,in ITA No.612/RJT/2024, as a sample, are as follows: “Departmental official survey have made at the business premises on 16-02-2018 Departmental official survey proceeding

SHREE SAMARTH ELECTRICALS PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

condonation of the delay, in ITA No.612/RJT/2024, as a sample,for adjudicating the respective delay in filing these three appeals. The contents of the petition for donation of delay submitted before the Bench,in ITA No.612/RJT/2024, as a sample, are as follows: “Departmental official survey have made at the business premises on 16-02-2018 Departmental official survey proceeding

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.185/Rjt/2023

condone the delay. 7. Succinctly, the factual panorama of the case is that assessee before us is a private limited company.The assessee- company had filed return of income for the assessment year (AY) 2017-18, on 13/10/2017, declaring total loss of Rs.2,36,06,293/-. The assessee`s case was selected for Scrutiny through CASS. The assessment was finalized

SHRI ARJANBHAI DAYALJIBHAI PARMAR,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 37/Rjt/2023 िनधा"रण वष" िनधा"रण वष"/Asstt. Years: 2017-2018 िनधा"रण िनधा"रण वष" वष"

condone the delay and proceed to adjudicate the issue on merit. A.Y. 2017-18 3 6. The facts in brief are that the assessee in the present case is an individual and filed its return of income declaring income at Rs. 2,89,870/- only. Thereafter, the case of the assessee was selected under limited scrutiny on account of large

NILESH ASHANAND THACKER,BHUJ vs. ITO WARD 4, GANDHIDHAM (BHUJ)

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

condone the delay and admit the appeal of the assessee for hearing on merit. 8. Succinctly, the factual panorama of the case is that assessee before us is an Individual and had filed his return of income for assessment year (A.Y.) 2012-13, on 25.03.2013, declaring total income of Rs. 1,78,070/-. During the year, the assessee has earned

JAYPRAKASH BHOVANBHAI JAGANI HUF,RAJKOT vs. ITO, WARD-1(1)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini(Hybrid Hearing) Assessment Year: (2017-18) Shri Jayprakash Bhovanbhai Jagani Vs. The Ito, Ward-1(1)(1) (Huf) Rajkot. Block No.1001, Rajdhani Apartment Opp: Purhkardham, University Road Rajkot 360 005. Pan : Aaghj 5696 F (Appellant) (Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr

cash deposit in the bank accounts held with the Co-operative Bank of Rajkot during demonetization period. The addition confirmed is unjustified and uncalled for, which deserves to be deleted, may kindly be deleted. 3. Your Honour’s appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing

SHRI DHARAMRAJSINH BRIJRAJSINH JADEJA,DHROL vs. THE INCOME TAX OFFICER, WARD-3(2), JAMNAGAR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

condone the delay of 47 days in filing this appeal by the assessee. 2.1. The Grounds raised by the assessee is to delete the addition of Rs.3,52,500/- by treating cash deposit