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

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

VIPUL ARJANBHAI PARMAR,MANGROL vs. INCOME TAX OFFICER, WARD -1, JUNAGADH

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.217/Rjt/2025 िनधा"रण वष"/Assessment Year : 2010-11 बनाम/ Vipul Arjanbhai Parmar Income Tax Officer Vs C/O. Sarda & Sarda (Ca), Sakar, Ward – 1, Junagadh 1St Floor, Dr. Radha-Krishnan Road, Opp. Rajkumar College, Rajkot, Gujarat - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ditpp9286B (अपीलाथ"/Assessee) (""थ"/Respondent)

condone the delay. 8. The grounds of appeal raised by the assessee, on merit, are as follows: “1. The assessment order u/s. 143(3) r.w.s. 147 of the Act is bad in law. 2. The learned Assessing Officer has erred in law as well as on facts for making the addition of Rs. 5,00,000/-on account of unexplained

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

condone the delay of 120 days in ITA No.612/RJT/2024,as also\n119 days' delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024,\nand admit these respective appeals for hearing.\n7. For the sake of convenience, the grounds as well as the facts narrated in ITA\nNo.612/RJT/2024, for assessment Year 2018-19, have been taken into\nconsideration for deciding

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

RUPA VIMAL PADALIYA,RAJKOT vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

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

unexplained investment in a flat. The assessee's appeal before the CIT(A) was dismissed ex-parte for delayed filing and non-compliance. The assessee then filed an appeal before the Income Tax Appellate Tribunal.", "held": "The Tribunal found that the CIT(A) dismissed the appeal without adjudicating on merits and that the assessee had a sufficient cause

RAJENDRASINH RANJITSINH JADEJA,KHAKHADABELA,PADDHARI vs. ITO WD 2(1)(4), RKT, RAJKOT

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, 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 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

condone the delay. 6. Brief facts qua the issue, on merit, are that assessee has filed return of income on 03.07.2013, declaring total income of Rs. 1,56,860/- for the year under consideration. As per the information available with the department and on enquiry, it was noticed by the assessing officer that the assessee has made cash deposit amounting

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

In the result, appeal filed by the assessee is dismissed

condone the delay.\n7. Succinctly, the factual panorama of the case is that assessee before us is a\nprivate limited company.The assessee- company had filed return of income for\nthe assessment year (AY) 2017-18, on 13/10/2017, declaring total loss of\nRs.2,36,06,293/-. The assessee`s case was selected for Scrutiny through CASS.\nThe assessment was finalized

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ITO, WARD-3 (1) (4), RAJULA, DIST. AMRELI, RAJULA, DIST. AMRELI

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

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

unexplained investment in Life Insurance Policy of Bajaj Alliance Life Insurance Co. The addition confirmed is totally unjustified and uncalled for and deserves to be deleted and may kindly be deleted. 4. We have heard rival parties and perused the materials available on record including the condonation petition, supporting affidavit filed by the assessee’s husband explaining thereby the delay

SMT. RANI HARERAM SAHANI,KOVAYA, RAJULA, DIST. AMRELI vs. THE ACIT, WARD-2 (4), BHAVNAGAR, BHAVNAGAR

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

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

unexplained investment in Life Insurance Policy of Bajaj Alliance Life Insurance Co. The addition confirmed is totally unjustified and uncalled for and deserves to be deleted and may kindly be deleted. 4. We have heard rival parties and perused the materials available on record including the condonation petition, supporting affidavit filed by the assessee’s husband explaining thereby the delay

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)

unexplained investment u/s. 69 of the Income Tax Act. 2. That on the facts and circumstance of the case, the learned assessing officer has grossly erred in making impugned addition under 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

INCOME TAX OFFICER, MORBI vs. MAHENDRAKUMAR BHAGVANDAS RANPURA, MORBI

delay is condoned in filing the cross objection.\n8. Succinctly, the factual panorama of the case is that assessee before us is an\nIndividual. The assessee has filed his return of income for assessment year (A.Y.)\n2017-18, on 31/01/2018, declaring therein total income of Rs. Nil/-. The return\nof income was processed u/s 143(1) of the Act. Later

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)

unexplained investment by the assessing officer within the meaning of section 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

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

condone the delay and admit the cross objection for hearing. 50. About the grounds raised by the assessee in respect of CO, the ld.Counsel for the assessee submitted the addition sustained by the ld.CIT(A) to the tune of Rs.85,500/-, on account of unexplained investment

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

condone the delay and admit the cross objection for hearing. 50. About the grounds raised by the assessee in respect of CO, the ld.Counsel for the assessee submitted the addition sustained by the ld.CIT(A) to the tune of Rs.85,500/-, on account of unexplained investment

SANJAYKUMAR DHIRUBHAI HIRPARA,KHAMBHA vs. AO, ITO, WARD-3(1)(2), RAJKOT

In the result, these Tax Appeals are also allowed

Bench: Smt. Annapura Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

delay is condoned. 3. It is seen from record, the case is listed for hearing 5th time today, even in the previous hearings None appeared on behalf of the assessee, in spite of service of notices to the assessee. Neither the assessee nor his Authorized Representative, C.A. Shri Janak Tarapara appeared for the hearing. The Ld. D.R. Mr. B.D. Gupta

VINOD LALJIBHAI VADSOLA,TIMBADI vs. ITO, WARD-1, MORBI

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 939/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2017-18) Vinod Laljibhai Vadsola Income Tax Officer, Ward-1, Vill. Timbadi, Tal: Morbi- Morbi-363 641 Vs. 363 641 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Alnpv 3995 K (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Appellant By : Shri Rajendra Singhal, A.R. राज"व क" ओर से/Respondent By : Shri Abhimanyu Singh Yadav, Sr. D.R. सुनवाई क" तार"ख/ Date Of Hearing : 05/05/2025 घोषणा क" तार"ख/Date Of Pronouncement : 07/05/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Order (Ay) 2017-18, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax(Appeals) / National Faceless Appeal Centre, Delhi (In Short “Cit(A)”, Dated 09.08.2024, Which In Turn Arises Out Assessment Order Passed By The Assessing Officer U/S 147 R.W.S. 144B Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act” Dated 25.05.2023. The Assessee Has Raised The Following Grounds Of Appeal:- 2. “The Grounds Of Appeal Mentioned Hereunder Are Without Prejudice To One Another. 1. The Ld.Cit(Appeals) Has Erred In Law & On The Facts In Holding Assessment Proceedings As Valid Through: A. The Notice U/S 148 Of The Act Has Been Issued By The Ito, Ward-1, Morbi In Violation Of The Provisions Of Sec. 151A Of Act & The Ita No. 939/Rjt/2024 A.Y.17-18 Vinod L. Vadsola

investment in LLP. 3. The Ld. CIT(A) has erred in law and on the facts in upholding addition of Rs.9,00,000/- u/s 69A of the Act for unexplained cash deposits. Yoour honour’s appellant craves leave to add, amend, alter or withdraw any or more grounds of appeal on/or before the hearing of appeal.” 3. The appeal

HARESHBHAI ARJUNDAS GURBANI,JAMNAGAR vs. THE INCOME TAX OFFICER, WD 2(10), JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.611/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Hareshbhai Arjundas Gurbani Aaykar Bhawan, Vs. 109/110 City Aarced, Nr Dsp Jamnagar Bunglow, Tin Batti, Jamnagar 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqspg3832M (Appellant) (Respondent) Appellant By : Shri Suresh Tejwani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav , Ld. Sr. (Dr) Date Of Hearing : 03/03 /2025 Date Of Pronouncement : 07/ 03/2025 आदेश / O R D E R Per Dinesh Mohan Sinha Jm;

delay in filing the appeal is hereby condoned and the appeal is to be heard on merit. Facts Of The Case as recorded by The Ld CIT(A) . That the assessee filed an appeal of the assessee. Order date 21.09.2021 before Ld CIT(A). That said appeal was disposed of with following observation. “In view of above discussion and perusal