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

GOJIYA BHIKHUBHAI,JAMNAGAR vs. PRINCIPAL COMMISSIONEROF INCOME TAX, JAMNAGAR

delay in filing the appeals, for which condonation was sought and granted.", "held": "The Tribunal held that the PCIT's orders were not sustainable as the Assessing Officer had applied his mind and taken a plausible view, and the conditions for invoking revisional jurisdiction under Section 263 were not met. The Tribunal quashed the PCIT's orders.", "result": "Allowed", "sections

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

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

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

69B of the Act, as amount of 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 u/s 37 of the Act. 35. Aggrieved by the order of the assessing officer

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

69B of the Act, as amount of 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 u/s 37 of the Act. 35. Aggrieved by the order of the assessing officer

KALPESH CHATURBHAI RAIYANI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(1)(1), RAJKOT

Appeal is allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 143-145/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15-2016-17) Kalpesh Chaturbhai Raiyani The Income Tax Officer, Ward- 8-New Meghani Nagar Corner, Sahakar Vs. 1(1)(1), Main Road, Aaykar Bhawan, Race Course Ring Rajkot - 360002 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aszpr8968H (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/08/2025 : 04/11/2025 Date Of Pronouncement Order Per, Dinesh Mohan Sinha, J.M.: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15 – 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961, By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 05.06.2024/06.06.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The Act, On 28.03.2022/ 29.03.2024. Ita No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds Of Appeal Raised By The Assessee Are As Follows (Ita No. 143- Rjt-25):

section 144B of the Act, on 28.03.2022/ 29.03.2024. ITA No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds of appeal raised by the assessee are as follows (ITA No. 143- Rjt-25): 1. Ld. AO erred in law as well as on facts in not supplying the material based on which the assessment has been re-opened and 1 consequently

KALPESH CHATURBHAI RAIYANI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(1)(1), RAJKOT

Appeal is allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 143-145/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15-2016-17) Kalpesh Chaturbhai Raiyani The Income Tax Officer, Ward- 8-New Meghani Nagar Corner, Sahakar Vs. 1(1)(1), Main Road, Aaykar Bhawan, Race Course Ring Rajkot - 360002 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aszpr8968H (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/08/2025 : 04/11/2025 Date Of Pronouncement Order Per, Dinesh Mohan Sinha, J.M.: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15 – 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961, By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 05.06.2024/06.06.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The Act, On 28.03.2022/ 29.03.2024. Ita No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds Of Appeal Raised By The Assessee Are As Follows (Ita No. 143- Rjt-25):

section 144B of the Act, on 28.03.2022/ 29.03.2024. ITA No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds of appeal raised by the assessee are as follows (ITA No. 143- Rjt-25): 1. Ld. AO erred in law as well as on facts in not supplying the material based on which the assessment has been re-opened and 1 consequently

KALPESH CHATURBHAI RAIYANI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(1)(1), RAJKOT

Appeal is allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 143-145/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15-2016-17) Kalpesh Chaturbhai Raiyani The Income Tax Officer, Ward- 8-New Meghani Nagar Corner, Sahakar Vs. 1(1)(1), Main Road, Aaykar Bhawan, Race Course Ring Rajkot - 360002 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aszpr8968H (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Samir Bhuptani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/08/2025 : 04/11/2025 Date Of Pronouncement Order Per, Dinesh Mohan Sinha, J.M.: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2014-15 – 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961, By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 05.06.2024/06.06.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The Act, On 28.03.2022/ 29.03.2024. Ita No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds Of Appeal Raised By The Assessee Are As Follows (Ita No. 143- Rjt-25):

section 144B of the Act, on 28.03.2022/ 29.03.2024. ITA No. 143-145/Rjt/2025 Kalpesh Chaturbhai Raiyani 2. Grounds of appeal raised by the assessee are as follows (ITA No. 143- Rjt-25): 1. Ld. AO erred in law as well as on facts in not supplying the material based on which the assessment has been re-opened and 1 consequently

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, 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 the illegality.\"\nThat crime is not a business is also recognised in F. A. Lindsay, A. E. Woodward and W. Hiscox v. The Commissioners of Inland Revenue