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

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

property in India or control and management vested in India, are not satisfied in the present case. The commission expenses paid on export sales to a non-resident admittedly for services rendered outside India is not coming under the purview of Sec. 40(a)(ia) of the Act. It is relevant to mention that the ‘commission’ simpliciter is not fees

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

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

property in India or control and management vested in India, are not satisfied in the present case. The commission expenses paid on export sales to a non-resident admittedly for services rendered outside India is not coming under the purview of Sec. 40(a)(ia) of the Act. It is relevant to mention that the ‘commission’ simpliciter is not fees

M/S. D.M.L. EXIM PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

property in India or control and management vested in India, are not satisfied in the present case. The commission expenses paid on export sales to a non-resident admittedly for services rendered outside India is not coming under the purview of Sec. 40(a)(ia) of the Act. It is relevant to mention that the ‘commission’ simpliciter is not fees

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

house property and business losses of Rs.\n52,358/-. Thus, total income of Rs.8,17,320/- has been offered. A Search, Seizure\nand Survey action was carried out by the office of DDIT (Inv.), Unit-1, Rajkot in\nthe case of leading real estate builders of Rajkot and their key associates on\n24.08.2021. Four different groups were covered

SHRI GHANSHYAMBHAI GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

10,2005 Rs.1,00,000/- 3 By Cheque 17,12,2005 Rs.1,00,000/- Rs39,00,000/- The assessee during the assessment proceedings failed to justify the source of deposits in his bank account, therefore the AO treated the same as unexplained cash credit under section 68 of the Act. Hence the AO added the sum of Rs. 39 lakhs

SHRI KISHOR GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

10,2005 Rs.1,00,000/- 3 By Cheque 17,12,2005 Rs.1,00,000/- Rs39,00,000/- The assessee during the assessment proceedings failed to justify the source of deposits in his bank account, therefore the AO treated the same as unexplained cash credit under section 68 of the Act. Hence the AO added the sum of Rs. 39 lakhs

SHRI SANJAYBHAI GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 ,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

10,2005 Rs.1,00,000/- 3 By Cheque 17,12,2005 Rs.1,00,000/- Rs39,00,000/- The assessee during the assessment proceedings failed to justify the source of deposits in his bank account, therefore the AO treated the same as unexplained cash credit under section 68 of the Act. Hence the AO added the sum of Rs. 39 lakhs

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 83/Rjt/2025 (निर्धारण वर्ष/Assessment Year: (2017-18) Seabird Marine Services Pvt. Vs. Ltd. Office No. 309 & 310, Centroid Luxuria, Nr. Crystal Mall, Khodiyar Colony, Aerodrome Road, Jamnagar 361006 Assistant Commissioner Of Income-Tax, Circle-1, Jamnagar, Aayakar Bhawan, Nr. Subhash Bridge, Jamnagar -Rajkot Highway, Jamnagar स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaccs 9869 C (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Appellant By : Shri S. N. Soparkar, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit-Dr Date Of Hearing : 30/04/2025 Date Of Pronouncement : 30/05/2025 Per Dr. A. L. Saini, Am: आदेश / Order Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2017-18, Is Directed Against The Order Passed By The National Faceless Appeal Centre (Nfac), Dehi/ Commissioner Of Income Tax (Appeal) [In Short 'Ld. Cit(A)'], Dated 02.01.2025, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”), Vide Order Dated 31.12.2019. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “All The Below Mentioned Grounds Of Appeal Are Independent & Without Prejudices To Each Other.

house Property instead of business income and considering the same as not eligible for computing deduction u/s 801A though the Rent Income has direct nexus with the 80IA eligible business activity of the assessee, being income derived from the business and further issue is covered in favour of assessee by the decision of Rajkot bench in assessee's case

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

34,00,000\n| 7 | 24,78,000\n| 9 | 97,44,123\n| 10 | 15,00,00,000\n| 12 | 6,06,000\n| 14 | 4,12,000\n| Total | 27,23,60,123\n\n18. Though, we strongly denied the above-stated unaccounted payments / expenses for\nthe project, for sake of academical purpose, it is submitted that estimated

SIX TWENTY REALTY PVT LTD,RAJOT vs. DCIT, CC-1, RAJKOT, RAJKOT

34,00,000\n| 7\n| 24,78,000\n| 9\n| 97,44,123\n| 10\n| 15,00,00,000\n| 12\n| 6,06,000\n| 14\n| 4,12,000\n| Total\n| 27,23,60,123\n\n18. Though, we strongly denied the above-stated unaccounted payments / expenses for\nthe project, for sake of academical

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

34,000\nD4\n101\n2 BHK\n24,00,000\n27,00,000\n3,00,000\n\n14. In view of the above inconsistencies (sample basis) between noting / entries made\nby or through Mr. Ashutosh Ganatra (who was responsible for negotiating price with\ncustomer inclusive of all other add-on services provided by him) in various impounded\ndocuments/data as well

M/S. PATEL COPPER PVT. LTD.,,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2 (1) (4), , RAJKOT

The appeal of the assessee is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar(Through Web-Based Video Conferencing Platform) "नधा"रणवष"/Assessment Year: 2013-14 Vs. M/S. Patel Copper Pvt. Ltd., Income-Tax Officer, A-76, Aashopalav Bunglows, Ward 2(1)(4), Nr. Satya Sai Hospital, Rajkot Rajkot-360005 Pan : Aagcp 6173 J अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assesseeby : Shri Rajendra Singhal, Ar Revenue By : Shri Ashish Kumar Pandey, Sr Dr

10 times more than its purchase price for the purpose of deriving Fair Market Value of the shares, was purchased during the current year itself. He also noted the fact that the land was purchased for Rs.8,74,460/- and its jantri value was Rs.7,35,000/- @ Rs.642/- per square meter, while the valuer had valued it at Rs.87

SHRI HARESH JADAVJI GHADIA,RAJKOT vs. THE INCOME TAX OFFICER, WARD-5(1),, RAJKOT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2006-07

34,137-). The addition needs deletion. 2. The Ld. CIT(A) has erred in law and facts in confirming addition of Rs.3,47,300/- based on factual position which he described wrongly. The addition needs deletion. 3. The Ld. CIT\(A) has erred in law and facts in confirming addition of Rs.3,47,300/- erroneously applying provisions of section

DUSHYANT BHARATBHAI MEHTA,RAJKOT vs. ITO WD-(2)(1)(2) , RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.422/Rjt/2024 (निर्धारणवर्ष / Assessment Year: (2015-16) Dushyant Bharatbhai Mehta (Physical Hearing) C/O Bhabha Fashions 34/35 Bhabha Bazzar, Ghee Kanta Road, Vs. The Ito, Ward -2(1)(2), Aaykar Bhawan, Rajkot Rajkot 360001 (Gujarat) स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahgpm4763P (Assessee) (Respondent) Assessee By Respondent By : Shri Vijay Mehta, Ld. Ar : Shri Abhimanyu Singh, Yadav, Ld. Sr. Dr Date Of Hearing : 01/05/2025 Date Of Pronouncement : 30/06/2025 आदेश / Order Per, Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged Correctness Of The Order Dated 27-05-2024 Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The

house property 2 ITA No. 422/Ahd/2024 A.Y. 2015-16 Dushyant Bharatbhai Metha Vs. ITO for a sum of Rs. 73,27,000/-. Out of this, 50% was shown purchase of his brother Shri Paras Mehta, without executing any transfer deed or getting the sale officially registered. This transfer was only Rs. 37,01,000/-. The assessee thereafter showed huge cost

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

10 respectable witnesses in his defence before the Assessing Officer to establish the contents of the so called affidavit as true nor their affidavits were filed. Those two persons were the actual witnesses of the search proceedings and were from the same locality. Thus, the copy of the so called affidavit not supported by any evidence had no evidentiary value

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

10 respectable witnesses in his defence before the Assessing Officer to establish the contents of the so called affidavit as true nor their affidavits were filed. Those two persons were the actual witnesses of the search proceedings and were from the same locality. Thus, the copy of the so called affidavit not supported by any evidence had no evidentiary value

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

10 respectable witnesses in his defence before the Assessing Officer to establish the contents of the so called affidavit as true nor their affidavits were filed. Those two persons were the actual witnesses of the search proceedings and were from the same locality. Thus, the copy of the so called affidavit not supported by any evidence had no evidentiary value

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

10 respectable witnesses in his defence before the Assessing Officer to establish the contents of the so called affidavit as true nor their affidavits were filed. Those two persons were the actual witnesses of the search proceedings and were from the same locality. Thus, the copy of the so called affidavit not supported by any evidence had no evidentiary value

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

10 respectable witnesses in his defence before the Assessing Officer to establish the contents of the so called affidavit as true nor their affidavits were filed. Those two persons were the actual witnesses of the search proceedings and were from the same locality. Thus, the copy of the so called affidavit not supported by any evidence had no evidentiary value