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

NILESH ASHANAND THACKER,BHUJ vs. ITO WARD 4, GANDHIDHAM (BHUJ)

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

unexplained money u/s 69A of the I.T. Act, 1961. Nilesh A Thacker 3. That the Ld. CIT(A) has wrongly confirmed initiation of penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961. 4. That the Ld. CIT(A) has wrongly confirmed levy of interest u/s 234A, 234B and 234C of the I.T. Act, 1961. 5. That the findings

HARUNBHAI NOORMAMD JINDANI,JAMNAGAR vs. ITO, WARD 2(7), JAMNAGAR, JAMNAGAR

In the result, the appeal filed by the assessee is partly allowed, in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 407/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Harunbhai Noormamd Jindani The Income Tax Officer, Ward-2(7), Kishan Chowk, Behind Bodyg, Vs. Jamnagar-Rajkot Highway, Jamnagar - 361001 Jamnagar-361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Anxpj4114C (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 02/09/2025 Date Of Pronouncement : 17/11/2025 Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, 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 20.09.2023, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S. 144 Of The Act, On 11.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows:

condone the delay. 7. On merit, facts of the assessee`s case are as follows. In the assessee`s case, as per instructions issued by CBDT, in the form of SOP dated 21/02/2017, verification was carried out, in respect of the transactions of cash deposits made in bank account relating to demonetization period and it was found that the assessee

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

HOTHI SAMAT KESHWALA,PORBANDAR vs. INCOME TAX OFFICE, WARD 2(4), PORBANDAR, PORBANDAR

In the result, the appeal filed by the assessee is partly allowed in above terms

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 408/Rjt/2025 (िनधा"रणवष"/Assessment Year: (2017-18) Hothi Samat Keshwala Ito, Wd – 2(4), At Visavada, Via Bokhira Porbandar, Vs. Income Tax Office, Nh-8E, Porbanadar – 360575 Porbandar Road, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Buppk0380P (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Chetan Agarwal, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 02/09/2025 : 25/11/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, 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 05.08.2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Vide Order 21.10.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

condone the delay. 6. Succinct facts are that in assessee`s case, a notice u/s 142(1) of the Act, was issued by the Income Tax Officer Ward-2(3), Porbandar, on 13.02.2018, in which the assessee was requested to furnish return of income for A.Y. 2017-18 on or before 15.03.2018. The assessee had not furnished return of income

SHRI NARENDRA DHARAMDAS GIDWANI,ANJAR KUTCH vs. THE ADDL. CIT, NFAC, , NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 220/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Narendra Dharamdas Gidwani, The Commissioner Of Income Vs. Plot No. 29, Survey No. 193/1, Maitru Tax(Appeals), Residency Meghpar Borichi, Anjar, National Faceless Appeal Centre Kutch, (Nfac), Delhi, Income Tax Gujarat - 370110 Department, Ministry Of Finance, Government Of India "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akmpg6386M (Appellant) (Respondent) Appellant By : Shri Chiranjeev Tandon, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 26/03/2025 Date Of Pronouncement : 09/06/2025 आदेश / O R D E R Per D. M. Sinha, Jm:

condoned the delay. Narendra D. Gidwani 7. Brief facts of the case that the Appellant is on individual assessee employed with the private company. The Appellant is a salaried person and have been filing return of income regularly. The appellant filed return of income for assessment year 2015-16 on September 4, 2015. Thereafter, the assessing officer issued Notice under

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.185/Rjt/2023

condone the delay. 7. Succinctly, the factual panorama of the case is that assessee before us is a private limited company.The assessee- company had filed return of income for the assessment year (AY) 2017-18, on 13/10/2017, declaring total loss of Rs.2,36,06,293/-. The assessee`s case was selected for Scrutiny through CASS. The assessment was finalized

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

GHANSHYAMBHAI MOHANBHAI PATEL,AT PO UMARDA vs. INCOME TAX OFFICER WARD 4 SURENDRANAGAR, INCOME TAX OFFICE IRISH BUILDING

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

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 382/Rjt/2025 ("नधा"रण वष" / Assessment Year: (N.A.) (Hybrid Hearing) Ghanshyambhai Mohanbhai Patel Income Tax Officer, Ward-4, Surendranagar, Income Tax Near Swaminarayan Mandir, At Umarda, Vs. Office, Irish Building, Opp. Mela Ta.Muli, Dist. Surendranagar-363 510 Medan, Surendranagar-363 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brjpp 6166 K (Appellant) (Respondent)

unexplained money, without appreciating the appellant's explanation regarding the opening cash balance, business cash flows, and other financial records already submitted to the Assessing Officer. * Rejection of Books of Accounts under Section 145(3) 4 Ghanshyambhai M Patel The rejection of the appellant's books of accounts by the AO—and its confirmation by the CIT(A)—was unjustified

SHREE MARU KANSARA SONI GNATI,ANJAR vs. ITO EXEMPTION WARD-1 RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 789/Rjt/2025 धििाारण वर्ा/Assessment Year: (2017-18) Shree Maru Kansara Soni Gnati बनाम Income Tax Officer (Exemption), /Vs. C/O Rajesh K Soni, Shashtri Road, Ward- 1, Rajkot, Anjar, Kutch-360 001(Gujarat) It Office, New Aayakar Bhavan,Vatiaka, Rajkot-360 001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarts 1920 N (Appellant) (Respondent)

unexplained money u/s 69A of the I.T. Act, 1961. 5. That, the Ld. AO has wrongly applied the provision of section 115BBE of the I.T. Act, 1961. 6. That, the Ld. AO has wrongly initiated penalty proceedings u/s 274 r.w.s. 271AAC(1), 272A(1) (d) and 271F of the I.T. Act, 1961. 7. That, the Ld. AO has wrongly charged

BHAVESHKUMAR MAHENDRABHAI MANIYAR,JUNAGADH vs. THE ITO WARD-1, JUNAGADH., JUNAGADH

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

Bench: Shri Dr. A. L. Saini, Accountat Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.234/Rjt/2025 Assessment Year: (2019-20) (Physical Hearing) Bhavneshkumar Mahendrabhai Vs. Ito, Maniyar, Ward – 1, Prop.Of Shree Hari Enterprise, Junagadh Shop No.2, Rajkamal Apartment, Junagadh, Junagadh - 362001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afdpm3866Q (Appellant) (Respondent)

condone the delay of 249 days and admit the appeal for hearing. 5. Facts of the case in brief are that the assessee had e-filed on 24.09.2019, declaring total income of Rs.6,66,460/-. A search and seizure action u/s 132 of the Act named ‘operation blue diamond’ was conducted on 24.08.2021 in case of real estate builders

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)

condone the delay. 7. So far merits of the case are concerned, the relevant material facts of the assessee`s case, are as follows. The assessee had filed his return of income for assessment year (A.Y.) 2011-12, on 20.09.2011, declaring total income at Rs. NIL. The return of income, was processed u/s 143(1) of the Act. Later

HANIF OSMAN RAVDA,SITLACHAWK OPP. REHEMANI MASJID ,MEMANWAD MEMANWAD vs. INCOME TAX OFFICER, WARD 2(3) , PORBANDAR, GUJARAT

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

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.447/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Hanif Osman Ravda Vs. Ito Ward 2 (3), Sitla Chawk, Rehemani Masjid, Porbandar - 360575 Memanwad, Porbandar – 360575 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acepr8023N (Assessee) (Respondent)

delay is condoned in filing the appeal. 4. The facts of the case which can be stated quite shortly are as follows: The sole issue involved in the present appeal, relates to addition of Rs. 13,71,365/- made by the assessing officer as unexplained money

DIVYA DARSHAN ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(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. 150/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Divya Darshan Enterprise Vs. Deputy Commissioner Of Income Block No. 7/8, Meera Nagar, Opp. Circle – 1(1), Rajkot Shashikunj, Gandhipar, B/H. Sardarbaug, Aayakar Bhavan, Race Course Junagadh – 362001 Ring Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfd5111A (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 06/05/2025 Date Of Pronouncement : 30/06/2025

condonation of delay, supported by Affidavit. The crux of the application for delay is as under; “4. Subsequently, Hon'ble Pr. Commission of Income-tax, Rajkot-1, Rajkot has vide order u/s 263 of the Act dated 25.02. 2022 alleged that order passed us. 143(3) of the Act dated 22.11.2019 is erroneous and prejudicial to the interest of revenue

SMT. SUMARIBEN R. ODEDARA,PORBANDAR vs. THE INCOME TAX OFFICER, WARD-2(3), PORBANDAR

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

Bench: Ms. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

condone the delay of 02 days in filing this appeal by the assessee and the appeal is taken up for hearing. 2.1. The brief facts of the case is that the assessee is an individual, engaged in the business of trading of brass product and supplied goods to various parts of India. Further the assessee is an illiterate person

DILIPSINNH GAMBHIRSNH JADEJA,RAJKOT vs. INCOME TAX OFFICER WARD 2(1)(1), RAJKOT

In the result, the appeal of the appellant is dismissed

unexplained money on the alleged ground that the appellant failed to explain source of cash deposits alongwith necessary evidences. The addition made is totally unjustified on facts as also in law. deserves to be deleted and may kindly be deleted. 5.0 The learned AO erred in charging interest u/s. 234A, 234Band 234Cof the Act. 6.0 The learned AO erred