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

THE ACIT, CEN. CIR.-2, RAJKOT, RAJKOT vs. EXPERT PARTICLE BOARD, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

House No.1, Vavdi Road Morbi. PAN : AIWPA 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee by : Shri Mehul Ranpura, ld.AR राज"व क" ओर से/Revenue by : Shri Sanjay Punglia, ld.CIT-DR सुनवाई क" तार"ख /Date of Hearing : 05/06/2025 घोषणा क" तार"ख /Date of Pronouncement : 29/08/2025 ORDER Per, Dr. Arjun Lal Saini, Accountant Member

THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT vs. SHRI BHAGVANJI PRABHUBHAI AMRUTIYA, MORBI

In the result, cross objection filed by the assessee, ( in CO No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.139/Rjt/2021 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Expert Particle Board बनाम Cent.Cir.2, Rajkot. Survey No.111, 8-A National Vs. Highway B/H. Bharatinagar Iti, Ravapar Nadi Morbi 363 642. Pan : Aahfe 0299 G आयकर अपील सं /.Ita No.142/Rjt/2021 With Cross Objection No.05/Rjt/2022 िनधा"रणवष"/ Assessment Year: 2019-2020 Asstt.Commissioner Of Income-Tax Bhagvaji Prabhubhai बनाम Cent.Cir.2, Rajkot. Amrutiya, Meera Park-2 Vs. House No.1, Vavdi Road Morbi. Pan : Aiwpa 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 05/06/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/08/2025 Order Per, Dr. Arjun Lal Saini: The Captioned Two Appeals Filed By The Revenue Pertaining To Assessment Year 2019-20 & The Cross Objection Filed By The Assessee, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income-Tax

House No.1, Vavdi Road Morbi. PAN : AIWPA 0121 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee by : Shri Mehul Ranpura, ld.AR राज"व क" ओर से/Revenue by : Shri Sanjay Punglia, ld.CIT-DR सुनवाई क" तार"ख /Date of Hearing : 05/06/2025 घोषणा क" तार"ख /Date of Pronouncement : 29/08/2025 ORDER Per, Dr. Arjun Lal Saini, Accountant Member

BHIKHALAL PRAHLADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

property. The case of assessee was reopened u/s.147 of the Act and a notice under section 148 of the Income tax Act, 1961, was issued on 29.03.2018 and was duly served upon the assessee, through ITBA email facility. Thereafter, a notice u/s 143(2) dated 30.07.2018, was issued and served upon the assessee through ITBA email facility. Further, a notice

BHIKHALAL PRAHALADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

property. The case of assessee was reopened u/s.147 of the Act and a notice under section 148 of the Income tax Act, 1961, was issued on 29.03.2018 and was duly served upon the assessee, through ITBA email facility. Thereafter, a notice u/s 143(2) dated 30.07.2018, was issued and served upon the assessee through ITBA email facility. Further, a notice

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

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

131(1A) of the Act has explained lucidly that these sheet contain detail such as flat no, name of the buyers/ booking persons and details of cash / cheque received and to be received against sale /booking of respective unit. He further explained that sheets inventoried as page 20-39 are more updated and having more amount. Beside the above, during

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

house property and business losses of Rs. 52,358/-. Thus, total income of Rs. 8,17,320/- has been offered. A Search, Seizure and Survey action was carried out by the office of DDIT (Inv.), Unit-1, Rajkot in the case of leading real estate builders of Rajkot and their key associates on 24.08.2021. Four different groups were covered

DEEPAK MOHANLAL PURUSWANI,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.630 & 631/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2021-2022 & 2022-23) Hybrid Hearing बनाम Shree Deepak Mohanlal Puruswani The Dcit, Cc-1 Rajkot Nr. Maa Krupa, 4- Saurashtra Kala Vs. Aaykar Bhawan “Amruta Estate”, Kendra Society, Opp. Nirmala Convent, Mg Road, Rajkot 360001, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं/.Ita No.665/Rjt/2024 िनधा"रण वष"/ Assessment Year: (2022-23) बनाम The Dcit, Cc-1 Rajkot Shree Deepak Mohanlal Puruswani Aaykar Bhawan“Amruta Estate”, 2Nd Vs. Nr. Maa Krupa, 4- Saurashtra Kala Floor Mg Road Kendra Society, Opp. Nirmala Rajkot 360001, Gujrat Convent, Kalawad Road, Rajkot-360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Ajvpp5139P .. (अपीलाथ"/Appellant) (""यथ"/Respondent)

house property and business losses of Rs. 52,358/-. Thus, total income of Rs. 8,17,320/- has been offered. A Search, Seizure and Survey action was carried out by the office of DDIT (Inv.), Unit-1, Rajkot in the case of leading real estate builders of Rajkot and their key associates on 24.08.2021. Four different groups were covered

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. SMT. KRUSHNABA P. JADEJA,, RAJKOT-GUJARAT

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

131 of the Act, and they have replied to the Assessing Officer, with documentary evidences, therefore, no adverse conclusion can be drawn in respect of other 14 persons, as the Assessing Officer never summoned to these 14 persons and never asked any details and documents and information from them. The Assessing Officer has not summoned, during the proceedings under section

SMT. KRUSHNABA PRAVINSINH JADEJA,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CIR.-1(1),, RAJKOT-GUJARAT

131 of the Act, and\nthey have replied to the Assessing Officer, with documentary evidences,\ntherefore, no adverse conclusion can be drawn in respect of other 14\npersons, as the Assessing Officer never summoned to these 14 persons and\nnever asked any details and documents and information from them. The\nAssessing Officer has not summoned, during the proceedings under section

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

131(1A) of the Act has explained lucidly that these sheet\ncontain detail such as flat no, name of the buyers/ booking persons and details of\ncash / cheque received and to be received against sale /booking of respective unit.\nHe further explained that sheets inventoried as page 20-39 are more updated and\nhaving more amount. Beside the above, during

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

131(1A) of the Act has explained lucidly that these sheet\ncontain detail such as flat no, name of the buyers/ booking persons and details of\ncash / cheque received and to be received against sale /booking of respective unit.\nHe further explained that sheets inventoried as page 20-39 are more updated and\nhaving more amount. Beside the above, during

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

131(1A) of the Act has explained lucidly that these sheet\ncontain detail such as flat no, name of the buyers/ booking persons and details of\ncash / cheque received and to be received against sale /booking of respective unit.\nHe further explained that sheets inventoried as page 20-39 are more updated and\nhaving more amount. Beside the above, during

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

131 of The Act at the residential premise of Girish Vanjani on 27.08.2021) that Shri Girish Vanjani does the work of accounting as per his instructions. Thus, Shri Girish Vanjani is a key employee and accountant of the R K Group is an admitted and confirmed fact. During the course of search and seizure action at the residential premise

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

131 of The Act at the residential premise of Girish Vanjani on 27.08.2021) that Shri Girish Vanjani does the work of accounting as per his instructions. Thus, Shri Girish Vanjani is a key employee and accountant of the R K Group is an admitted and confirmed fact. During the course of search and seizure action at the residential premise

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

131 of The Act at the residential premise of Girish Vanjani on 27.08.2021) that Shri Girish Vanjani does the work of accounting as per his instructions. Thus, Shri Girish Vanjani is a key employee and accountant of the R K Group is an admitted and confirmed fact. During the course of search and seizure action at the residential premise

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

131 of The Act\nat the residential premise of Girish Vanjani on 27.08.2021) that Shri\nGirish Vanjani does the work of accounting as per his instructions. Thus, Shri\nGirish Vanjani is a key employee and accountant of the R K Group is an admitted\nand confirmed fact. During the course of search and seizure action at the\nresidential premise

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

131 of The Act\nat the residential premise of Girish Vanjani on 27.08.2021) that Shri\nGirish Vanjani does the work of accounting as per his instructions. Thus, Shri\nGirish Vanjani is a key employee and accountant of the R K Group is an admitted\nand confirmed fact. During the course of search and seizure action at the\nresidential premise

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

131 of The Act\nat the residential premise of Girish Vanjani on 27.08.2021) that Shri\nGirish Vanjani does the work of accounting as per his instructions. Thus, Shri\nGirish Vanjani is a key employee and accountant of the R K Group is an admitted\nand confirmed fact. During the course of search and seizure action at the\nresidential premise