KANATALAW SEVA SAHAKARI MANDALI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Commissioner of Income-tax (Appeals), dated 15.03.2024 & 13.06.2024, which in turn arise out of intimation orders passed by CPC, Bengaluru / Assessing Officer u/s 143(1) of the Act, on 25.06.2019 & 01.05.2020; respectively. 2. Grounds of appeal raised by the assessee in ITA No.200/Rjt/2025

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)

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

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, 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.\nvi. The \"Angadiya\" is a very common term in Gujarat. Another common term related to monetary transactions is \"shroff

PARAS RAMESHCHANDRA DOSHI,RAJKOT vs. THE PCIT - 1, RAJKOT , RAJKOT

delayering of funds in\nthe process of money laundering. Upon detection, the Income Tax department has\ntreated these sums as unexplained cash deposits and taxed the entire amount as deemed\nincome. The ‘Angadiya/shroff' have disclosed the modus-operandi in clear terms.\nvi. The \"Angadiya” is a very common term in Gujarat. Another common term related to\nmonetary transactions is “shroff

THE DEPUTY COMMR. OF INCOME TAX, CEN. CIR.1,, RAJKOT vs. JAYESH HARAKHJI PATEL,, RAJKOT

In the result, all appeals filed by the different assessee's and Revenue\nare allowed for statistical purposes

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

SOLO STEEL TECH,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is dismissed

delayering of funds in\nthe process of money laundering. Upon detection, the Income Tax department has\ntreated these sums as unexplained cash deposits and taxed the entire amount as deemed\nincome. The ‘Angadiya/shroff' have disclosed the modus-operandi in clear terms.\nvi. The "Angadiya” is a very common term in Gujarat. Another common term related to\nmonetary transactions is “shroff

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

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

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

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

condoning it or taking part in it.\nFurther down he said:\n\" It is merely taxing the individual with reference to certain facts. It is not a partner or a sharer in\nthe illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The\nCommissioners of Inland Revenue

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 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