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:

demonetization period. However, total aggregate cash deposited by the assessee to the tune of Rs. 12,48,000/-, was disallowed

SAURASHTRA GRAMIN BANK MANAGER (F & A), RAJKOT,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX-I,, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 37/Rjt/2022 (Assessment Year: 2017-18) (Hybrid Hearing) Saurashtra Gramin Bank Vs. The Pr. Cit-1, Manager (F & A), Rajkot 1St Floor Wing 2, Lic Jeevan Prakash Building, Tagore Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahas2116H (अपीलाथ"/Appellant) (""यथ"/Respondent)

demonetization period to Reserve Bank of India on daily basis. The Assessee is authorized to deal with receipt and payment of cash. 6. Learned PCIT has grievously erred on calculating the disallowances

LALJIBHAI DUDABHAI BHUVA,RAJKOT vs. INCOME TAX OFFICER, WARD-2(2)(1), RAJKOT., RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./ Ita No.501/Rjt/2025 िनधा"रण वष"/Assessment Year : 2017-18

disallow 30% of Rs.3,56,500/- in the hands of the assessee which comes to Rs.1,06,950/-. 5 Laljibhai Dudabhai Buva vs. ITO 10. I also note that since the assessee has deposited amount during demonetization

GRENIC TILES PRIVATE LIMITED,WANKANER-MORBI vs. ASST.COMMISSIONER OF INCOME-TAX CIRCLE 1(1) RKT, RAJKOT

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

demonetization period is also not\ndisproportionate. In view of these facts the cash expenses till 08.11.2016\nwill be taken at Rs.46,49,944/-.Out of total debtors' collection of Rs.\n61,45,732/-, the ld CIT(A) disallowed

ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. GRENIC TILES PVT LTD, MORBI

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

demonetization period is also not\ndisproportionate. In view of these facts the cash expenses till 08.11.2016\nwill be taken at Rs.46,49,944/-.Out of total debtors' collection of Rs.\n61,45,732/-, the ld CIT(A) disallowed

M/S PREMJI VALJI & SONS,,RAJKOT-GUJARAT vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 125/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 M/S Premji Valji & Sons, The Principal Commissioner Of “Kuvarjibhai Tower”, Vs. Income Tax, Palace Road, Rajkot-1, Rajkot. Rajkot. Pan: Aacfp7696K

disallowance may not be made for default (I any). 18. Details of cash deposited during the year in following format A.Y. 2017-18 11 Bank Account Cash deposited during Cash deposited during Quantum of cash the year demonetization

SHRI DIPTEN AHINDRA BHOWMICK,GANDHIDHAM-KUTCH vs. THE ITO, WARD-1, GANDHIDHAM-KUTCH

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

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

disallowances of Rs. 7,54,700/- only. 8. The aggrieved assessee preferred an appeal to the learned CIT(A). 9. The assessee before the learned CIT(A) submitted that for the year under consideration i.e. A.Y. 2016-17, he furnished return after demonetization

SHRI PRASHANTSINH AJITSINH CHAUHAN,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

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

disallowance for such defaults”. The Principal CIT is of the view that the act of the assessing Officer in not converting the limited scrutiny assessment into full scrutiny assessment, looking into the fact that substantial amount was deposited by the assessee in the bank accounts held by him during the demonetization

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

disallowances had impact on the losses to be carried forward. No explanation has been offered for under- reporting of income to the extent of Rs.70,71,531/-, which was prima facie not allowable in view of the provisions of Section 36(1)(iii) r.w Explanation 8 to Section 43(1) of the Act. The dropping of penalty in respect

MANOJBHAI ARVINDBHAI PAREKH,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 385 /Rjt/2023 ("नधा"रण वष"/Assessment Year: (2017-18) Manojbhai Arvindbhai Parekh The Acit Of I. T. Circle – 2(1), Shreeji Giriraj Trading, 19-Giriraj Vs. Rajkot – 360001 Chamber, Old Gadhiwas Soni Bazar, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acypp1471C (अपीलाथ"/Assessee) (""यथ"/Respondent)

demonetization: (i).Hon'ble Visakhapatnam ITAT in the case of Hirapanna Jewellers (128 taxmann.com 291). Manojbhai Arvindbhai Parekh v. ACIT ITA No.385/Rjt/2023 AY. 2017-18 (ii).Hon'ble Jaipur ITAT in the case of Mahesh Kumar Gupta (151 taxmann.com 339). (iii).Hon'ble Jaipur ITAT in the case of Raj Kumar Nowal (146 taxmann.com 581). (iv)Hon'ble Chandigarh ITAT

NATHABHAI PARSANA (LR. GANESHBHAI PARSANA),RAJKOT vs. ACIT CIR -2(1), RAJKOT

Appeal is partly allowed in above terms

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

demonetization period by submitting the cash flow statement was also explained by the assessee. Besides, as per wealth tax return filed by the assessee, the assessee had cash balance, which has not been considered by the assessing officer and CIT(A).The Ld.CIT(A) has ignored these evidences. Therefore, learned Counsel argued that since the assessee has explained the cash

ABHAY HARGOVINDBHAI PATEL,JAMNAGAR vs. THE INCOME TAX OFFICER, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपीलसं./Ita No. 17/Rjt/2024 निर्धारणवर्ष / Assessment Year: (2017-18) (Hybrid Hearing) Abhay Hargovindbhai Patel Vs. The Income Tax Officer, Ward 305, Dwarkeshdham,B/H. Samudra 1(3), Jamnagar Sales, Rajnagar, Aerodram Road, 1St Floor, Taranjali Building, Pn Jamnagar 361006 Marg, Aubpp7196D Jamnagar 361008 (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri K. L. Solanki, Ld. Sr. (Dr) Date Of Hearing : 27/04/2025 Date Of Pronouncement : 16/07/2025 आदेश / 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 By Commissioner Of Income Tax (Appeals), Vide Order Dated 08/11/2023, Which In Turn Arises Out Of An Order Passed By The Assessing Officer, Dated 26/11/2019, U/S 144 Of The Income Tax Act, 1961. Page 1

demonetization period, father, and mother of the assessee gave the gift to the assessee. The assessee stated that he received some amount withdrawn by her mother from provident fund, which the assessee has received by way of gift from his mother. The copies of agricultural bills were submitted along with affidavit. We find that these documents are self servicing documents

CHATURBHAI K. DETROJA (HUF),MORBI vs. INCOME TAX OFFICER WARD-1, MORBI

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

Bench: Dr. Arjun Lal Saini

demonetization period in the bank account, out of the cash balance available on hand and out of the agricultural income of the Chaturbhai K. Detroja, assessee, and these documents were already considered by the learned CIT (A) and part relief had been given to the assessee. However, I also note that the assessee has not filed entire documents and evidences

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:

demonetization period. However, I find that assessee was not able to prove all its personal expense and drawings which was utilized by the assessee, out of cash withdrawals from bank and out of fixed deposit amount received by the assessee from the bank. I, therefore, take into account all these peculiar facts, and note that assessee has not been able

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)

demonetization period. This amount represents business receipts arising from cash sales in the ordinary course of business, primarily involving resale of fertilizers to farmers, a business that predominantly operates on a cash basis in rural India. * Reason for Non-filing of Return for A.Y. 2017-18: The assessee could not file the return of income for the Assessment Year

MAHEK TRADING,ANJAR vs. THE INCOME-TAX OFFICER, WARD 1 GANDHIDHAM, GANDHIDHAM

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 394/Rjt/2025 (Assessment Year: 2017-18) Mahek Trading Vs. Income-Tax Office, Wd-1, (Change In Firm Name Sector-8, Effective From F.Y. 2016-17) Gandhidham - 370201 12 Meter Road, Patni Bazar Anjar – 370110( Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqfm2604L (अपीलाथ"/Appellant) (""थ"/Respondent)

demonetization period remained unexplained and hence added to the returned income of the assessee, as per the provisions of section 68 of the I.T. Act. 8. Aggrieved by the order of the assessing officer, the assessee carried the matter in appeal before the Ld.CIT(A) who has confirmed the addition made by the assessing officer. The Ld.CIT(A) noted that

SHRI ANISH HASAN BAKHAI,KESHOD vs. THE AO, WARD-1, JUNAGADH, JUNAGADH

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

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

demonetization to the AO vide Instruction No. 3/2017[ F.NO. 225/100/2017/ITA-II] dated 21.2.2017 and annexure thereof issued under section 119 of Income Tax Act, which are discussing and providing a blanket exemption of Rs. 2,50,000/- per person. In the Press release dated 18.11.2016 also, it was stated that: “It was announced by the Government earlier that small deposits made

SHRI GIRISHKUMAR JAMNADAS BHALODIYA,DHORAJI vs. THE ITO WARD -2 (2) (6), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.914/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Shri Girishkumar Jamnadas Bhalodiya Ito, Ward-2(2)(6) बनाम Kishan, Shashtri Nagar Rajkot. Jamanava Road, Dhoraji. Vs.

demonetization, therefore, without any adverse material it could not be presumed that cash deposited by assessee was Shri Girishkumar Jamnadas Bhalodiya ITA No.914 /RJT/2024 (AY :2017-18) 7 out of some undisclosed source and thus, additions made to income of assessee were to be deleted. The findings of the Coordinate Bench are reproduced below: “10. We have heard the rival