CLAYMINE MICRONS LLP,WANKANER vs. PRINCIPAL CIT 1, RAJKOT

In the result, the appeal of the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

133(6) (Acknowledgements for the dated 19.04.2021 & 20.04.2021 is submitted in annexure A). List of all the 19 partners mentioned above along with PAN, details of Capital and amount of capital received are being submitted in tabular format in Annexure B. 5. Vide your notice dated 19.04.2021, as per para "d" your good self has stated that

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S RAMBOO PROLEN PVT. LTD.,, RAJKOT-GUJARAT

In the result, ground number 8 of the Department’s appeal is dismissed

section 133(6) of the Act to both the suppliers, which were returned unserved with the remarks “left”. Accordingly, the AO made disallowance

M/S SAFARI FINE CLOTHING PVT. LTD.,,GANDHIDHAM. vs. ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM., GANDHIDHAM

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedिनधा"रण िनधा"रण वष" वष" M/S. Safari Fine Clothing Pvt. Acit, Ltd., Vs. Gandhidham Circle Shed No.280/281, A Type, Gandhidham. Sector No.3, Ka Sez, Gandhinagar- Kutch वष" Ito, M/S. Safari Fine Clothing Pvt. Ward-2, Vs. Ltd., Gandhidham "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aajcs 0565 Q अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" (""यथ" / Respondent) Assessee By : Shri Chetan L. Agarwal, Ar. Revenue By : S Shri Praveen Verma, Sr. D.R. सुनवाई क" तारीख / Date Of Hearing : 01/08/2018 घोषणा क" तारीख / Date Of Pronouncement : 03/10/2018

133(6) to give details of the purchasers like name, address, contact person, contact number, E- mail address etc and the person who were in touch with the said commission receiving parties. The Assessing Officer had also specifically asked these parties as to how they came in contact with the purchasing parties and whether they had traveled to countries outside

PARSHWA PRINTPACK PVT. LTD.,,SURENDRANAGAR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, SURENDRANAGAR

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

133(6) of the Act to the above mentioned parties but no response was received. Thereafter, a summon under section 131(1) of the Act was issued to all the parties. In response to the summon, the parties mentioned at serial Nos. 1 to 5 in the above table came forward and their statements were recorded. The AO found

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

133(6) of the Act to the above mentioned parties but no response was received. Thereafter, a summon under section 131(1) of the Act was issued to all the parties. In response to the summon, the parties mentioned at serial Nos. 1 to 5 in the above table came forward and their statements were recorded. The AO found

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

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

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

133(6) of the Act to the above mentioned parties but no response was received. Thereafter, a summon under section 131(1) of the Act was issued to all the parties. In response to the summon, the parties mentioned at serial Nos. 1 to 5 in the above table came forward and their statements were recorded. The AO found

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. M/S REAL PROCON PVT. LTD.,, RAJKOT-GUJARAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.498/Rjt/2015 िनधा"रण वष"/Asstt. Year: 2012-2013 D.C.I.T., M/S Real Procon Pvt. Ltd., Circle-1(1), Vs. Saneshwar Complex, Rajkot. Opp. Balalji Hall, 150 Ft. Ring Road, Rajkot.

section 133(6) of the Act. Likewise, out of the total investor companies, the directors of 2 companies were called for, who appeared before the AO wherein it was accepted by them to have made the investments in the assessee company. 3.5 However, the AO was not satisfied with the submission of the assessee for the reason that the project

M/S. VASUDEV MINERALS,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1),, RAJKOT

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

section 133(6) has been served on Mr. D. H. Jadeja who has confirmed/confessed that the transportation work was carried for the assessee during the impugned assessment year. Mr. D H Jadeja had lost the original bill, and on assessee’s demand when Mr. D H Jadeja given duplicate bill, he inadvertently filled incorrect date which fell outside the assessment

KETAN GORI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(10), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.42/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Ketan Gori The Pr.Cit बनाम Plot No.3009 Jamnagar. Gidc Phase-Iii Vs. Dared. Pan : Ahppg 5892 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

6. In response to the notice of the ld. Pr. CIT, the assessee submitted its written submissions along with documentary evidences, which are reproduced by the ld. Pr. CIT in the revision order. The assessee submitted before the learned PCIT that revision proceeding are mere change of opinion and without bringing anything new on the record. During the assessment proceedings

ASHOK HIRPARA, DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. SANJAY GULABRAI KUNDALIA, JAMNAGAR

In the result, appeal filed by the revenue is dismissed and cross objection filed by the assessee is also dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.66/Rjt/2025 & C.O. No. 10/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Deputy Commissioner Of Income Sanjay Gulabrai Kundalia बनाम Tax, Jamnagar Khambhaliya Circle-1, Vs. Highway, Sikkarpatiya, Jamnagar Sikka, Jamnagar Pan: Acypk3888Q Sanjay Gulabrai Kundalia Jamnagar Khambhaliya Vs. Deputy Commissioner Of Income Tax, Highway, Sikkarpatiya, Circle-1, Jamnagar Sikka, Jamnagar Pan: Acypk3888Q (अपीलाथ"/Appellant/Respondent) : (""यथ"/Respondent/Cross Objector) "नधा"रती क" ओर से/Assessee By : Shri K.D. Sheth, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 30/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 18/09/2025 Order Per: Dr. Arjun Lal Saini: Captioned Appeal Filed By The Revenue & Cross Objection Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Are Directed Against The Common Orders Passed By The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [In Short ‘Ld. Cit(A)/Nfac’], Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 10.12.2024, Which In Turn Arises Out Of An Dcit Vs.Sanjay Gulabrai Kundalia

section 133(6) of the Act, the respective parties filed the confirmations before the assessing officer. The assessee also filed the bank statement before the assessing officer. The assessee also submitted before the assessing officer, that most of the transactions are through account payee cheques and also stated the in appropriate cases TDS DCIT VS.Sanjay Gulabrai Kundalia ITA No.66 /RJT/2025

DY. COMMR. OF INCOME TAX, MORBI CIRCLE,, MORBI vs. M/S QUTONE CERAMIC P. LTD., MORBI

In the result, appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2013-14

Section 133(6), the assessee explained that the finding of the Assessing Officer is not correct and relied upon the confirmations. Ground no.1 of Revenue’s appeal is dismissed. 10. As regards to ground no.2 the assessee has explained the source of the source related to cash transactions and payment made towards share capital and premium and the details

RADHE RENEWABLE ENERGY DEVELOPMENT PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

133(6) of the Act. On its choosing not to exercise such powers, it was erroneous on the part of the Assessing Officer to make addition of a sum of Rs.23,00,000/-, despite such cogent evidences having been put-forth by the assessee. Both the authorities have concurrently held the issue in favour of the assessee and moreover

THE DEPUTY COMMR. INCOME TAX, CIRCLE-1(2),, RAJKOT vs. M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

133(6) of the Act. On its choosing not to exercise such powers, it was erroneous on the part of the Assessing Officer to make addition of a sum of Rs.23,00,000/-, despite such cogent evidences having been put-forth by the assessee. Both the authorities have concurrently held the issue in favour of the assessee and moreover

M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSTT. COMMR. INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

133(6) of the Act. On its choosing not to exercise such powers, it was erroneous on the part of the Assessing Officer to make addition of a sum of Rs.23,00,000/-, despite such cogent evidences having been put-forth by the assessee. Both the authorities have concurrently held the issue in favour of the assessee and moreover

THE DY. COMMR. OF INCOME TAX, CIRCLE-1(1),, RAJKOT-GUJARAT vs. M/S. RADHE RENEWABLE ENERGY DEVELOPEMENT PVT. LTD.,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

133(6) of the Act. On its choosing not to exercise such powers, it was erroneous on the part of the Assessing Officer to make addition of a sum of Rs.23,00,000/-, despite such cogent evidences having been put-forth by the assessee. Both the authorities have concurrently held the issue in favour of the assessee and moreover

THE ITO, WARD 1(3), RAJKOT-GUJARAT vs. M/S PAVAN CONSTRUCTION CO, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

133(6)/131 of the Act. But the AO has not done so while passing the assessment order. 13.4 It is also worth mentioning that the assessee has shown Kapchi in its closing stock for a value of Rs.1,09,784/- but the AO without adjusting the same has made the addition of the entire purchases of Kapchi for Rs.44

M/S SHYAM ENTERPRISE,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-1(3),, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No.324/Rjt/2014 "नधा"रण वष"/Asstt. Year: 2009-2010 Income Tax Officer, M/S Shyam Enterprise, Ward 1(3), Vs. Shop No.3, Prasang Complex, Rajkot. 150 Ft. Ring Road, Rajkot.

section 133(6) of the Act. The assessee has also not produced any documentary evidence in support of such rent expenses. The assessee finally agreed before the AO for the disallowance

DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. VASANTBHAI MULJIBHAI KANANI, JAMNAGAR

In the result, appeal filed by the revenue is dismissed, whereas appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Dy. Cit, Cir-1 Vasantbhai Muljibhai Kanani बनाम Jamnagar. Plot No.7, Ambica Enterprise Vs. Sardar Patel Ind. Estte-4 Indira Road Opp: Jakat Naka, Jamnagar-361004 (Guj) Pan : Aitpk 8038 P आयकर अपील सं /.Ita No.08/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Vasantbhai Muljibhai Kanani Dy. Cit, Cir-1 बनाम Plot No.7, Ambica Enterprise Jamnagar. Sardar Patel Ind. Estte-4 Vs. Indira Road Opp: Jakat Naka, Jamnagar- 361004 (Guj) Pan : Aitpk 8038 P (अपीलाथ"/Assessee) : (""यथ"/Respondent)

disallowed Rs. 3,47,91,594/-, by the assessing officer, and added to the total taxable income of the assessee for the year under consideration. DCIT Vs. Vasantbhai Muljibhai Kanani ITA No.124 /RJT/2025 and 08/RJT/2025 5 6. Aggrieved by the order of the assessing officer, the assessee carried the matter in appeal before the ld. CIT(A), who has deleted

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)

133(6) of the Income Tax Act, 1961, to conduct further necessary inquiry, which the assessing officer has failed to do so. Manojbhai Arvindbhai Parekh v. ACIT ITA No.385/Rjt/2023 AY. 2017-18 11. The Ld. Counsel for the assessee, further stated that before the assessing officer, assessee has furnished, copy of the bills, and vouchers and audited financial statements, including