MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowed than the ratio laid down\nby the various High Courts, regarding not taxing all the receipts would remain in\npapers only. Thus, with a view to strike a proper balance between the factual vis-\nà-vis the legal aspects it is decided to further enhance the average net profit rate\nto 50%. Accordingly, the net unaccounted profit for this

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT., RAJKOT

disallowed than the ratio laid down\nby the various High Courts, regarding not taxing all the receipts would remain in\npapers only. Thus, with a view to strike a proper balance between the factual vis-\na-vis the legal aspects it is decided to further enhance the average net profit rate\nto 50%. Accordingly, the net unaccounted profit for this

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

disallowed than the ratio laid down\nby the various High Courts, regarding not taxing all the receipts would remain in\npapers only. Thus, with a view to strike a proper balance between the factual vis-\nà-vis the legal aspects it is decided to further enhance the average net profit rate\nto 50%. Accordingly, the net unaccounted profit for this

THE DCIT CENTRAL CIRCLE-1 , RAJKOT vs. SHRI SHAMJIBHAI SADHABHAI KANGAD, GANDHIDHAM-KUTCH

In the result, appeal filed by the Revenue, in IT(SS) No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआ.(खो और ज).सं./It(Ss)A Nos.11 To 20/Rjt/2022 "नधा"रण वष"/ Assessment Years:2011-12 To 2020-21 बनाम/ Shri Shamjibhai Sadhabhai Deputy Commissioner Of Kangad Income Tax, Central Circle-1, Vs. Bbz-S-60, Zanda Chowk, “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Adepk 3471 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.21 To 23/Rjt/2022 "नधा"रण वष"/ Assessment Years:2014-15, 2016-17 &2017-18 बनाम/ Deputy Commissioner Of Income Shri Shamjibhai Sadhabhai Tax, Central Circle-1, “Amruta Kangad Vs. Estate”, 2Nd Floor, M.G. Road, Bbz-S-60, Zanda Chowk, Rajkot-360001 Gandhidham-370 201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aabca 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.15/Rjt/2023 "नधा"रण वष"/ Assessment Year:2019-20 बनाम/ Deputy Commissioner Of Shri Hetab Shamjibhai Kangad Income Tax, Central Circle-1, Bbz-South-60, Zanda Chowk, Vs. “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aqtpk 7484 M (अपीलाथ"/Assessee) (""यथ"/Respondent)

1) of the Act, it was alleged by the assessing officer that during the course of search proceeding, at the residential premises of Shri Naran B Maheshwari, some digital data in his pen-drive was seized and on the basis of such data (Tally Data), it was alleged that Neelkanth Group have carried out unaccounted transactions. In this connection

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, RAJKOT

disallowed than the ratio laid down\nby the various High Courts, regarding not taxing all the receipts would remain in\npapers only. Thus, with a view to strike a proper balance between the factual vis-\na-vis the legal aspects it is decided to further enhance the average net profit rate\nto 50%. Accordingly, the net unaccounted profit for this

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”). 2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

1)\nof the Act, it was alleged by the assessing officer that during the course of search\nproceeding, at the residential premises of Shri Naran B Maheshwari, some digital\ndata in his pen-drive was seized and on the basis of such data (Tally Data), it was\nalleged that Neelkanth Group have carried out unaccounted transactions. In this\nconnection

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

153A of the Act, dated 31.07.2019 and\nInitiated penalty proceedings u/s 271(1)(c) of the Act. Further, in the first\nappeal, the CIT(A) had confirmed the said additions. Thereafter, the Hon'ble\nITAT had also confirmed the said additions made by the assessing officer.\nAccordingly, the assessing officer had levied penalty u/s 271(1

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

disallowance can be made in relation to that assessment year in exercise of powers under section 1534 of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur v. Assistant Commissioner of Income

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

disallowance can be made in relation to that assessment year in exercise of powers under section 1534 of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur v. Assistant Commissioner of Income