ARJAN LILA GORANIYA,PORBANDAR vs. ITO WARD 2(4), PORBANDAR

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

Bench: Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainiआयकरअपीलसं आयकरअपीलसं./Ita No.378/Rjt/2025 "नधा"रणवष" "नधा"रणवष" / Assessment Year: (2013-14) Arjan Lila Goraniya Vs. Ito Ward 2 (4), Inajiya Vadi Vistar, Porbandar - 360575 Porbandar Bhojeshwar S.O, Porbandar Bhojeshwar S.O, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./ ./Pan/Gir No.: Bbwpg1554P (Appellant) (Respondent)

69 of the I.T. Act, 1961. ARJAN LILA GORANIYA, 2. That, the Ld. CIT(A) has wrongly confirmed the initiation of penalty proceedings u/s That, the Ld. CIT(A) has wrongly confirmed the initiation of penalty proceedings u/s That, the Ld. CIT(A) has wrongly confirmed the initiation of penalty proceedings

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

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

KANTABEN VAJUBHAI PAGHADAL,RAJKOT, GUJARAT vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.552/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Kantaben Vajubhai Paghadal Vs. It-Office, New Aayakar At- Charan Samadhiyala, Bhawan, Jetpur – 360370(Gujarat) Rajkot - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxmpp2962D (Appellant) (Respondent)

condone the delay. 3. On merit, Learned Counsel for the assessee, submitted that the issue involved in the appeal of the assessee is that assessee had received interest on enhanced compensation of Rs. 18,51,082/- on account of compulsory acquisition of agricultural land, which is exempted under section 10(37) of the Income tax Act 1961. However, assessing officer

AMITKUMAR RAMKISHORBHAI SHARMA,MORBI vs. INCOME TAX OFFICER, WARD - 1, MORBI

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

condoning the delay in filing the appeal. 3. The Id. AO has erred in law as well as on facts in making the addition of Rs. 15,00,000/- under section 69

SHRI GIRISHKUMAR RAMNIKLAL DOSHI,,SURENDRANAGAR vs. THE INCOME TAX OFFICER, WARD-2,, SURENDRANAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.297/Rjt/2017 ("नधा"रण वष" / Assessment Year: (2011-12) (Hybrid Hearing) Shri Girishkumar Ramniklal Vs. Income Tax Officer Doshi Ward-2, Surendranagar B-601, Retreat, Near Shyamal Cross Road, Satellite, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ablpd2297E (Assessee) (Respondent)

Section 69 of the Act without appreciating the fact that no actual investments were made for the subject year under consideration by the appellant. 3. The appellant craves to add. amend, alter, substitute, modify any or all the above grounds of appeal, if necessary, on the basis of submissions to be made at the time of personal hearing

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

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

CHIMANLAL BHUTALAL SAGAR,MUMBAI vs. DEPUTY COMMISIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 126/Rjt/2025 ("नधा"रणवष" / Assessment Year: (208-19) (Hybrid Hearing) Chimanlal Bhutalal Sagar Vs. Deputy Commissioner Of Income C/.O Ca Himansu Gandhi, 10Th Floor, D Tax (International Taxation)-1, Wing, Trade World Building, Kamala Room N.312, Ito, Amruta Mills Compaund, Lower Parle – 400013 Building, Nr. Girnar Cinema, M. G. Road, Gujarat – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Fdmps3665D (Appellant) (Respondent) Appellant By : Shri Himansu Gandhi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/05/2025 Date Of Pronouncement : 30/06/2025

condoning the delay in filling appeal before him, even though the appellant is suffered from reasonable and sufficient cause. 3. On the facts and circumstances of the case and law, the Ld CIT(A) failed to consider that provisions of Section 144C was not complied by the Ld AO and thus the Order passed by the Ld AO was itself

MITESHKUMAR DAYALJIBHAI PABARI,BHATIYA vs. ASSISTANT COMMISSIONER/ DEPUTY COMMISSIONER , RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 420 /Rjt/2025 (िनधा"रण वष"/Assessment Year: (2020-21) Miteshkumar Dayaljibhai Pabari Assistant Commissioner/Deputy Commissioner, International C/O Dayaljibhai Pabari, Shreeji Catlery Vs. Taxation Rajkot, Stores, Main Bajar, Bhatiya, Devbhoomi Dwarka, Room No. 312, Income Tax Office, Amruta Estate Building, Near Girnar Dwarka-361315(Gujarat) Cinema, M.G. Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bctpp7290M (अपीलाथ"/Appellant) (""यथ"/Respondent)

69 r.w.s 115BBE of the I.T Act, 1961. 7. In the draft assessment order, the assessing officer also stated that this is a draft order passed as per the provisions of Section 147 r.ws. 144C(1) of the I.T. Act, 1961. The assessee is hereby allowed thirty days' (30 days) time from the date of receipt of this order (draft

AMRATALAL KARSANDAS SAMANI,JAMKHAMBHALIYA vs. OFFICE OF THE PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am.& & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.463/Rjt/2024 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Amrutlalkarsandassamani Vs. Principal Commissioner Rest House Road, Of Income Tax, Jodhpur Gate, Jamnagar-361008 Jam Khambhaliya, Dist: Devbhoomi Dwarka-361305. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhps5447P (Appellant) (Respondent) Appellant By : Shri Mahesh Paun, Ld. Ar Respondent By : Shri Sanjay Pungalia, Ld. Cit(Dr) Date Of Hearing : 27 /02 /2025 : 25 /04 /2025 Date Of Pronouncement आदेश / O R D E R

condone the delay and admit the appeal for hearing. 6.Succinctly, the factual panorama of the case is that assessee before us is an Individual.In this the assessee has filed return of income on 29/10/2017 declaring total income of Rs. 19,59,300/- (which includes the amount of Rs 10,06,000/-disclosed during the survey proceedings as unaccounted excess stock

BHARAT NATHABHAI BARAD,VERAVAL, GIR SOMNATH vs. ITO WARD-4, VERAVAL

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.411/Rjt/2023 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Bharat Nathabhai Barad Vs. The Income Tax Officer, Prop. Of M/S. Vinesh Enterprise, Ward-4, Village: Savani, Tal.: Veraval, Veraval. Veraval - Kodinar Highway, Dist.: Gir Somnath-362 268. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Avjpb6301K (Appellant) (Respondent)

Section 253 of the Act but the prescribed time limit of 60 days to avail such remedy was already expired at that point of time. On further deliberation, I have been given to understand that he appeal can be filed before Your Honours with the prayer for condonation of delay in view of bonafide sufficient reasonable cause involved

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 made by the assessee in his bank account. Further, the assessee has been

SHRI VIVEK PRAVINCHANDRA PALA,JAMNAGAR vs. THE ITO, WARD-2 (2), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: The Hearing Of Appeal.

delay being condoned. 4. The brief facts of the case are that the assessee had filed its return of income for assessment year 2014-15 declaring total income of ₹ 2,18,500/-. During the course of assessment for the impugned assessment year, the AO noticed that the assessee has shown an amount of ₹ 10,01,133/- as opening capital balance

SHRI MANSHUKH K. KUMBHANI,AMRELI vs. THE PR.CIT-3, RAJKOT

In the result, the appeal of the assessee is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

delay in filing of the present appeal is hereby being condoned. 4. The brief facts of the case are that the assessment was completed under section 143(3) of the Act by making an addition of " 1,14,69

BHARTIBEN VASHRAMBHAI SINDHAV,,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(3), , RAJKOT

In the result, appeal of the assessee is dismissed

Bench: The Hearing Of Appeal.”

condoning the delay and hearing the appeal on merits. 3. On merits, the facts of the case are that during the year under consideration, the assessee has shown income from job work and agricultural income. During the year, the assessee had purchased a piece of agricultural land at Kuvada for an amount of " 1,16,86,000/- along with Shri