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

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

property is not shown in\nthe Balance-sheet.\n7. The ld PCIT also noticed that the assessee has also not shown deemed\nrent income on one residential flat at Krishna Niwas-1, JVPD, Ville Parle,\nMumbai.\n8. The ld PCIT also noticed thatthe following transactions, have also\nremained unattended by the assessing officer, during the assessment\nproceedings:\n(a) Receipts

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

property is not shown in\nthe Balance-sheet.\n7. The ld PCIT also noticed that the assessee has also not shown deemed\nrent income on one residential flat at Krishna Niwas-1, JVPD, Ville Parle,\nMumbai.\n8. The ld PCIT also noticed thatthe following transactions, have also\nremained unattended by the assessing officer, during the assessment\nproceedings:\n(a) Receipts

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

house property', (iii) 'profits and gains from business or profession', (iv) 'capital gains' and (v) 'income from other sources' - cannot at all be adjusted against unexplained investment or expenditure. What is necessary as per Hon. Gujarat High Court is that source of acquisition of asset or expenditure should be clearly identifiable. In the case before Hon. Gujarat High Court

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property loss, in this respect you are requested to submit the loan details and the payment made by you during F.Y. 2019-20. In absence of any substantial evidence, the same will be considered your income and according will be added. Hence, you are requested to show cause why the total receipts/ payment

SHRI JUGALKISHORE NATWARLAL DHOLAKIA,JUNAGADH vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, both the appeals filed by the assessee(s) are dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./ Ita No. 14/Rjt/2021 Assessment Year : 2015-2016 Shri Jugalkishore Natwarlal Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abqpd 2710 D आयकर अपील सं./ Ita No. 15/Rjt/2021 Assessment Year : 2015-2016 Shri Girishkumar Vachhraj Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abupd 6245 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Samir Jani, Ar Revenue By : Shri Vijay Kumar Jaiswal, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 02/05/2023 आदेश/O R D E R Per Ms. Madhumita Roy:-

Section 142(1) of the Act along with questionnaire. In compliance whereof, the representative of the assessee appeared and filed written submissions on behalf of the assessee. Upon perusal of the entire set of documents placed before the learned Assessing Officer, it was found that the assessee the assessee derives income from business profession, house property salary and other sources

SHRI GIRISHKUMAR VACHHRAJ DHOLAKIA,,JUNAGADH vs. THE PR. COMMISSIONER OF INCOME TAX-1, RAJKOT-GUJARAT

In the result, both the appeals filed by the assessee(s) are dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./ Ita No. 14/Rjt/2021 Assessment Year : 2015-2016 Shri Jugalkishore Natwarlal Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abqpd 2710 D आयकर अपील सं./ Ita No. 15/Rjt/2021 Assessment Year : 2015-2016 Shri Girishkumar Vachhraj Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abupd 6245 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Samir Jani, Ar Revenue By : Shri Vijay Kumar Jaiswal, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 02/05/2023 आदेश/O R D E R Per Ms. Madhumita Roy:-

Section 142(1) of the Act along with questionnaire. In compliance whereof, the representative of the assessee appeared and filed written submissions on behalf of the assessee. Upon perusal of the entire set of documents placed before the learned Assessing Officer, it was found that the assessee the assessee derives income from business profession, house property salary and other sources

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

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

40,37,610/-.\n2. Grounds of Appeal in relation to computation of book profit u/s 115JB\nHon. CIT(A) erred in law as well as in facts in\n(i). confirming addition made by assessing officer of Rs. 73.99 crores to the book profits\nunder Clause (1) of Explanation 1 to Section 115JB (2) of the Income

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

properties as\nseized in the form of Digital Data and in the form of Hard Data were also\ncompared and corroborated with the documentary evidences and responses\nreceived from the Sub-registrar office and with the data available in public\ndomains on various government portals like garvi.gujarat.gov.in and 3)\ngujrera.gujarat.gov.in.Comparison of the financial 1) anyror.gujarat.gov.in 2)\ntransactions entered

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)

40,206/- stating that the debit balances of the loan proceeds should have been allowed to set off against the addition made for the credit balances of loan proceeds for all the year involved, and for remaining balances also the source to the extent of amount of corresponding unaccounted business receipts for the respective years has been treated as explained

GOJIYA BHIKHUBHAI,JAMNAGAR vs. PRINCIPAL COMMISSIONEROF INCOME TAX, JAMNAGAR

House, Plot No.25/1\nJoiser Park Estate\nB/H. Atul Petrol Pump\nJamnagar 361 001.\nThe Pr.CIT-1\nबनाम | Jamnagar.\nVs.\nGojijya Bhikhubhai and Others\nITA No.609, 610 and 612/RJT/2024 (AY:2018-19)\n2\nPAN : AIQPG 1300 В\n(अपीलार्थी/ Appellant)\n(प्रत्यर्थी/Respondent)\nनिर्धारितीकी ओरसे /Assessee by : Shri Mahesh Paun, ld.AR\nराजस्वकी ओरसे/Revenue by : Shri Sanjay Punglia, ld.CIT-DR\nसुनवाईकीतारीख

ASSTT. COMMR. OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT vs. SMITKUMAR P. KANERIA,, RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 22/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Smt. Bhavnaben बनाम/ Of Income-Tax Bhovanbhai Rangani Vs. Central Circle-1, Rajkot 701, Ratrani Tower, Nr. Bhaktidham Temple, Panchvati Main Road, Rajkot-05 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abupr5242C .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 23/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner Shri Bhupendra Trikamji बनाम/ Of Income-Tax Panchani Vs. Central Circle-1, Rajkot 11-A, “Akashdeep”, Sai Nagar Society, B/H. Ramdham Kalawad Road, Rajkot-360007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjpp7612B .. (अपीलाथ"/Appellant) (""यथ" / Respondent) & आयकर अपील सं./I.T.A. No. 24/Rjt/2021 ("नधा"रण वष" / Assessment Year : 2012-13) Assistant Commissioner बनाम/ Smt. Dimpleben

section 151 of the Act.” 12. The assessee replied as follows: “With reference to the above your honour has provided the reasons for reopening of assessment for AY 2012-13, Ongoing through the reason recorded, it is found that your notice is technically and factually erroneous and bad in law. Under instructions from our above named client we are submit