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

condone the delay of 120 days in ITA No.612/RJT/2024,as also 119 days’ delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024, and admit these respective appeals for hearing. 7. For the sake of convenience, the grounds as well as the facts narrated in ITA No.612/RJT/2024, for assessment Year 2018-19, have been taken into consideration for deciding

SHIV GREEN ENERGY PRIVATE LIMITED,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

condone the delay inassessee`s appeal in ITA No. 595/Rjt/2024 (Shiv Green Energy Pvt. Ltd.). 8. When, these two appeals called out for hearing, the Ld. Counsel of the assessee invited our attention to the order dated 25.04.2025 in the case of“Shree Samrath Switchgear &Transmission P. Ltd. & Shri Samrath Electronics P. Ltd.& Shri Gojiya Bhikhubhai”, vide

ASHOK GOPALDAS VITHLANI,JAMKHAMBHALIYA vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeals filed by the assessees(ITA No

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 595/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shiv Green Energy Pvt. Ltd. Vs. The Principal Commissioner Of Income Tax, 107, Divyam Park, Jamnagar 361001 Opp. H.O. Bhatt Bunglow, Nr. Sanjeevani Medical Store, Jamnagar - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aascs8645J (Appellant) (Respondent)

condone the delay inassessee`s appeal in ITA No. 595/Rjt/2024 (Shiv Green Energy Pvt. Ltd.). 8. When, these two appeals called out for hearing, the Ld. Counsel of the assessee invited our attention to the order dated 25.04.2025 in the case of“Shree Samrath Switchgear &Transmission P. Ltd. & Shri Samrath Electronics P. Ltd.& Shri Gojiya Bhikhubhai”, vide

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(1), JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA No

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(4), DWARKA, DWARKA

In the result, appeal filed by the assessee, in ITA No

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

DILIP KANTILAL KUBAVAT,PORBANDAR vs. ITO WD 2(3), PORBANDAR, PORBANDAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.522/Rjt/2025 "नधा"रण वष"/Assessment Year :2016-17 Dilip Kantilal Kubavat Ito बनाम/ Prop. Vijay Dairy Farm, Ward 2 (3), Vs Near Ramdhun S V P Road, Porbandar 360575 Porbandar - 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Azfpk8009B (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 09/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 14 /10/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M The Present Appeal Has Been Filed By The Assessee, Against The Order Passed By The Learned Commissioner Of Income Tax (Appeal) [Hereinafter Referred To As “Cit(A)”], Dated 21.03.2025, Arising In The Matter Of Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Here-In-After Referred To As “The Act”) Relevant To The Assessment Year 2016-17. 2. In This Appeal, The Assessee Has Raised Multiple Grounds Of Appeal. However, The Solitary Grievance Of The Assessee Is That The Ld Cit(A) Erred In Not To Consider The Basic Fact That The Assessee Has Gifted The Property To His Sister In Law (Younger Brother'S Wife) That Is, To A Relative For A Consideration Dilip Kantilal Kubavat

delay is condoned in filing the appeal. 6.Brief facts qua the issue are that the assessee has e-filed its return of income for the assessment year 2016-17, declaring total income of Rs.2,41,110/- and agriculture income of Rs.5,60,400/- on 18.03.2018. The return of income was processed u/s 143(1) of the 1.T. Act, accepting

SHRI CHINTAN KANJIBHAI KATARIYA,ANJAR-KUTCH vs. THE ITO WARD-1, , GANDHIDHAM-KUTCH

In the result, appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 40(a)(ia) of the Act. Further, the Assessing Officer also observed that the assessee had made substantial cash payments to labourers towards site expenses. However, on verification of bills, vouchers etc. the Assessing Officer observed that certain payments were made in cash below Rs. 20,000/- and some of the payments were supported only by self-made vouchers

MOTA DADVA MAHILA DOODH UTPADAK SAHKARI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(2)(1), RAJKOT

In the result, both appeals filed by the assessee, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.37 & 38/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 Mota Dadva Mahila Utpadak Sahakari The Ito, Ward-1(2)(1) बनाम At Mota Dadva, Gondal, Rajkot Rajkot Gujarat-360311 Vs. Pan : Aakfm7170M (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Samir Bhuptani, Ld.Ar राज"व क" ओर से/Revenue By : Ms. Monica Pandey, Sr-Dr

condoned in filing both these appeals. 5. On merit, At the outset, Learned Counsel for the assessee, begins by pointing out that assessee has not attended the proceedings before the assessing officer and before learned CIT(A), as the assessee is uneducated and reside in remote area, where internet facility is not available, therefore, notices of hearing were not served

MOTA DADVA MAHILA DOODH UTPADAK SAHKARI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(2)(1), RAJKOT

In the result, both appeals filed by the assessee, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.37 & 38/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 Mota Dadva Mahila Utpadak Sahakari The Ito, Ward-1(2)(1) बनाम At Mota Dadva, Gondal, Rajkot Rajkot Gujarat-360311 Vs. Pan : Aakfm7170M (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Samir Bhuptani, Ld.Ar राज"व क" ओर से/Revenue By : Ms. Monica Pandey, Sr-Dr

condoned in filing both these appeals. 5. On merit, At the outset, Learned Counsel for the assessee, begins by pointing out that assessee has not attended the proceedings before the assessing officer and before learned CIT(A), as the assessee is uneducated and reside in remote area, where internet facility is not available, therefore, notices of hearing were not served

SEASTEM LIMITED,JAMNAGAR vs. ACIT CIR - 1,, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 334/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Seastem Limited, Jamnagar Vs. Acit, Cir-1, Jamnagar 1 Avani Appartment, - Sarusection Road Income Tax Office, Jamnagar – 361001 Jamnagar - 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahcs9428G (Appellant) (Respondent) Appellant By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. Dr Date Of Hearing : 24/04/2025 Date Of Pronouncement : 09/07/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

38,710/- Addition: As discussed at Para 5 above 11,67,910/- Assessed income 40,06,620/- Say Rs. 40,06,620/- (Rs. Forty Lacs Six Thousand Six Hundred Twenty Only) 4. That the assessee filed an appeal against the order dated 29.12.2019 of the AO, in the office of the Ld. CIT(A), (NFAC) Rajkot

SHREE JAMNAGAR JILLA SAHAKARI KHARID VECHAN SANGH LIMITED,JAMNAGAR vs. DCIT-CIR-2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.223/Rjt/2025 "नधा"रण वष"/Assessment Year : 2018-19

condone the delay in filing appeal before ld. CIT(A). 6. On merit, I note that while passing assessment order, the AO made addition of Rs.12,31,766/- on account of 80P(2)(d) of the Act. The Ld. Counsel for the assessee invited my attention to the order dated 31.07.2024, passed by this Division Bench of this Tribunal

SHRI ASHOKBHAI BHAISINH JADEJA,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

condoning the delay in filing of the present appeal, in the interest of justice. 5. On merits, the brief facts of the case are that the assessee filed return of income for A.Y. 2017-18 on 30.10.2017 declaring total income of Rs. 4,85,230/-. The case was selected for limited scrutiny in order to examine “cash deposit during demonetization

NAVINBHAI BACHUBHAI MAKADIA L/H. SAMIRBHAI NAVINBHAI MAKADIA,RAJKOT vs. THE ITO WARD - 3 (1) (3) RAJKOT, RAJKOT

In the result, the appeals of the Assessee is dismissed in limine

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 207/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Navinbhai Bachubhai Makadia, Vs. The Ito Ward 3(1)(3) L/H. Samirbhai Navinbhai Makadia Rajkot - 360001 C/O Uma Motor Opp- S.T. Work Shop. Gondal Road, Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aetpm1907P (Appellant) (Respondent) Appellant By : Written Submission Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 08 / 10 /2025 Date Of Pronouncement : 09 / 12 /2025

section 250 of the Income Tax Act, 1961 by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals), dated 26/05/2023, which in turn arises out of an order passed by the Assessing Officer u/s 144 of the I.T. Act, on dated 16/12/2019. Navinbhai Bachubhai Makadia 2. The Grounds of appeal raised by the assessee are as follows

JAIN SANGHATANA FOUNDATION-JAMNAGAR,JAMNAGAR vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 359/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2025-26) Jain Sanghatana Foundation -Jamnagar, Cit (Exemption), Ahmedabad Vs. 15 Sidhbath Complex, K V Road, Aayakar Bhawan, Anandnagar- Jamnagar - 361001 Prahladnagar Road, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajaj8198C (Appellant) (Respondent) Appellant By : Shri Sagar Shah, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 07/07/2025 Date Of Pronouncement : 03/10/2025

condoned the delay in filing appeal by 421 days. 7. Brief facts of the case that the Appellant is an AOP which has been engaged in the Charitable Activities registered under the Bombay Public Charitable Trust Act, 1950 having Registration No. F/1354/Jamnagar. The Trust is also registered under section 12A(1)(ac) (iii) of the act, the copy

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

10,000) is not permitted. Buyers across India deposit the cash purchase- amount into the bank-account of self-styled Angadiya/shroff, who remitted cash to seller, after deducting commission. In certain instances, such Bank-accounts were also used for layering and delayering of funds in the process of money laundering. Upon detection, the Income Tax department has treated these sums

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

Section 292C, he is liable to explain the noting in the impounded diary. 42.The assessee submitted before the learned CIT(A) that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A of the Act dated 03.01.2019, was a non-connected party, as he is neither subjected to survey action nor he is owner of the premises surveyed from which

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

Section 292C, he is liable to explain the noting in the impounded diary. 42.The assessee submitted before the learned CIT(A) that the statement of Shri Bhupendra Balubhai Patel recorded u/s 133A of the Act dated 03.01.2019, was a non-connected party, as he is neither subjected to survey action nor he is owner of the premises surveyed from which

SULTANPUR JUTH SEVA SAHKARI MANDLI LTD,RAJKOT vs. ASSESSMENT UNIT, NFAC (PRESENT JURIS. ACIT-DCIT CIR 1(1),, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

condone the delay and admit these appeals for hearing. 5. First, we shall take two appeals in quantum proceedings, in ITA No. 492 & 493/Rjt/2024, for Assessment Year 2018-19 & 2020-21. When these two appeals were called out for hearing, Learned Counsel for the assessee, invited our attention to the order dated 31.07.2024, Passed by the Division Bench of this