LATE SMT. PRITI A. GANDHI L/R. SHRI ANILBHAI A. GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

D-mat account. Further, it has been mentioned that all details\nregarding the purchase/sale of shares i.e. evidence of purchase of shares, evidence\nof payment for purchase of shares made by way of account payee cheque, copy of\nbank statement, copy of balance sheet disclosing investments, copy of demat account\nstatement reflecting purchases, evidence of sale of shares through stock

MISS PARI ANIL GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

D-mat account. Further, it has been mentioned that all details\nregarding the purchase/sale of shares i.e. evidence of purchase of shares, evidence\nof payment for purchase of shares made by way of account payee cheque, copy of\nbank statement, copy of balance sheet disclosing investments, copy of demat account\nstatement reflecting purchases, evidence of sale of shares through stock

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

In the result, ground No.4 raised by the assessee is allowed

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

THE INCOME TAX OFFICER-WARD-2, , GANDHIDHAM - KUTCH vs. M/S. RIDDHI SIDDHI JEWELLERS, GANDHIDHAM - KUTCH

In the result, appeal of the Revenue isdismissed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Royassessment Year :2014-15 Ito, Ward-2 Vs. M/S.Riddhi Siddhi Jewellers Gandhidham. Shop No.1, Plot No.68 Bba (Sough) Gandhidham-Kutch. 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri B.D. Gupta, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 11/04/2023 घोषणा क" तार"ख /Date Of Pronouncement: 05/07/2023

D E R PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER Present appeal has been filed by the Revenue against order passed by the ld. Commissioner of Income Tax (Appeals)-3, Rajkot [hereinafter referred to as “Ld.CIT(A)”] under section 250(6) of the Income Tax Act, 1961 ("the Act" for short) dated 16.3.2018 pertaining to the Asst.Year 2014-15. 2. The grounds

JITENDRASINH ZALA,JAMNAGAR vs. THE PR.COMMISSIONER OF INCOME TAX, JAMNAGAR

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

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

D E R Per, Dr. A. L. Saini, AM: By way of this appeal, the assessee has challenged the correctness of the order dated 22.10.2024 passed by the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) under section 263 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'), for the assessment year 2020-21. Grievances

MITESHKUMAR DAYALJIBHAI PABARI,BHATIYA vs. ASSISTANT COMMISSIONER/ DEPUTY COMMISSIONER , RAJKOT

In the result, the appeal filed by the assessee is allowed, for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 420 /Rjt/2025 (िनधा"रण वष"/Assessment Year: (2020-21) Miteshkumar Dayaljibhai Pabari Assistant Commissioner/Deputy Commissioner, International C/O Dayaljibhai Pabari, Shreeji Catlery Vs. Taxation Rajkot, Stores, Main Bajar, Bhatiya, Devbhoomi Dwarka, Room No. 312, Income Tax Office, Amruta Estate Building, Near Girnar Dwarka-361315(Gujarat) Cinema, M.G. Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bctpp7290M (अपीलाथ"/Appellant) (""यथ"/Respondent)

d) of the Act, was issued after getting approval u/s 151 of the Act of competent income-tax authority. Thereafter, notice u/s 148 of the I.T Act, 1961 dated 29.03.2024, was served requiring the assessee to furnish return of Income. In response to the notice u/s 148 of the Act, the assessee has filed return of income on 29.07.2024 thereby

PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

housing projects in order to avail excess deduction of Section 80IB(10) of the Act.In itself, such a claim is a misrepresentation of facts which would have succeeded but for selection of case in scrutiny and detection thereof in assessment. The Ld. CIT(A) was of the view that misrepresentation has led to underreporting of income, therefore, ld.CIT(A), confirmed

SHRI SAJISAVAI MOXDHAM SEVA TRUST ,SAVARKUNDLA, DIST. AMRELI vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 848 & 849/Rjt/2024 Shri Sajisavai Moxdham Seva Vs. The Cit (Exemption), Trust-Amreli, Savarkundla, Ahmedabad Amreli "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abbts9964K (अपीलाथ"/Appellant) (""यथ"/Respondent)

d) of section 12AB(4) of the Income Tax I.T.A Nos. 848 & 849/Rjt/2024 6 Shri Sajisavai Moxdham Seva Trust Act. The objects of the applicant are not as per scheme of provisions provided under Income Tax Act, therefore, the activities cannot be said to be gunnie and in accordance with provisions of law. We note that the trustee is registered

SHRI SAJISAVAI MOXDHAM SEVA TRUST ,SAVARKUNDLA, DIST. AMRELI vs. THE CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 848 & 849/Rjt/2024 Shri Sajisavai Moxdham Seva Vs. The Cit (Exemption), Trust-Amreli, Savarkundla, Ahmedabad Amreli "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abbts9964K (अपीलाथ"/Appellant) (""यथ"/Respondent)

d) of section 12AB(4) of the Income Tax I.T.A Nos. 848 & 849/Rjt/2024 6 Shri Sajisavai Moxdham Seva Trust Act. The objects of the applicant are not as per scheme of provisions provided under Income Tax Act, therefore, the activities cannot be said to be gunnie and in accordance with provisions of law. We note that the trustee is registered

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

D E R Per, Dr. A. L. Saini, AM Captioned two appeals filed by the assessee, pertaining to Assessment years, (A.Ys.) 2011-12 & 2016-17, are directed against the order passed by the Learned Commissioner of Income Tax ( Appeals) [Ld. CIT(A)], National Faceless Appeal Centre (in short “NFAC”), Delhi, vide orders dated 16.09.2024 & 30.08.2024, which in turn arise

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

D E R Per, Dr. A. L. Saini, AM Captioned two appeals filed by the assessee, pertaining to Assessment years, (A.Ys.) 2011-12 & 2016-17, are directed against the order passed by the Learned Commissioner of Income Tax ( Appeals) [Ld. CIT(A)], National Faceless Appeal Centre (in short “NFAC”), Delhi, vide orders dated 16.09.2024 & 30.08.2024, which in turn arise

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

17,400\nUnaccounted payment for purchase of land\n(-)1,18,73,000\nUnaccounted expenses\n(-)8,46,360\n1,34,98,040\nTotal\nNet Surplus\n71,25,350\nNet Surplus (%)\n51%\nPage 23 of 35\nITA Nos.630 & 631 and 665/Rjt/2024\nDeepak Mohanlal Puruswani\nAs can be seen from this table, the net surplus in the hands of the assessee

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

D E R PER MADHUMITA ROY, JUDICIAL MEMBER: In this bunch of appeals two appeals were filed by the Revenue against the orders dated 30.10.2015 & 14.05.2015 passed by passed by the Ld. CIT(A)-1, Rajkot for A.Ys. 2012-13 & 2011-12 respectively and the ITA Nos.27/RJT/2016& 360,315/Rjt/2015 A.Y.2011-12,2012-13 assessee has come up against the order dated

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

D E R PER MADHUMITA ROY, JUDICIAL MEMBER: In this bunch of appeals two appeals were filed by the Revenue against the orders dated 30.10.2015 & 14.05.2015 passed by passed by the Ld. CIT(A)-1, Rajkot for A.Ys. 2012-13 & 2011-12 respectively and the ITA Nos.27/RJT/2016& 360,315/Rjt/2015 A.Y.2011-12,2012-13 assessee has come up against the order dated

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

D E R PER MADHUMITA ROY, JUDICIAL MEMBER: In this bunch of appeals two appeals were filed by the Revenue against the orders dated 30.10.2015 & 14.05.2015 passed by passed by the Ld. CIT(A)-1, Rajkot for A.Ys. 2012-13 & 2011-12 respectively and the ITA Nos.27/RJT/2016& 360,315/Rjt/2015 A.Y.2011-12,2012-13 assessee has come up against the order dated

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)

17:-Admission defined: ‘An admission is a statement, oral or documentary or contained in electronic form which suggests any inference as to any fact, any issue or relevant fact, and which is made by any of the person, and not the circumstances herein after mentioned. One such persons mentioned in Section 18(1) is “ by party interested in subject matter

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)

17:-Admission defined: ‘An admission is a statement, oral or documentary or contained in electronic form which suggests any inference as to any fact, any issue or relevant fact, and which is made by any of the person, and not the circumstances herein after mentioned. One such persons mentioned in Section 18(1) is “ by party interested in subject matter

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

section 68 of the Act."” 23. However, the Assessing Officer, rejected the above contention of the assessee and observed that assessee has failed to prove identity, ITA Nos.572&577/RJT/2015/AY.2012-13 Krushnaba Pravinsinh Jadeja genuineness and creditworthiness of the transactions, therefore, made addition of Rs. 83,00,000/- u/s. 68 of the Act. 24. On appeal, by the assessee