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

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

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)

section 147 r.w.s. 144C(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. Grounds of appeal raised by the assesse are as follows: (1) Learned A.O. erred in law as well facts in making addition of Rs. 78,69,694/- as unexplained investment u/s 69 r.w.s 115BBE and passing order u/s 147 r.w.s. 144C

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. GANDHI REALITY (INDIA) PRIVATE LIMITED, RAJKOT

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

5. The assessing officer noticed that assessee-company, that is, Gandhi Realty (India) Pvt Ltd, [PAN:No. AAACD7535Q), earstwhile, J.B. Realties Pvt Ltd, has claimed depreciation of Rs. 20,18,52,087/- (being 25% of Rs. 80,74,08,346), on intangible asset, that is, on Goodwill. The erstwhile M/s. Gandhi Realty (India) Pvt Ltd, (PAN AACCG5189K) and M/s Crystal

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

43,75,230/- in respect of alleged investment for purchase of land for\nIndustrial Zone-17 project.\n•\nAddition of Rs 21,730/- in respect of alleged unaccounted expense for R K Industrial\nZone-17 project.\n•\nAddition of Rs 1,18,73,000/- in respect of alleged investment for purchase of land for\nR K Industrial Park Phase 5

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

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

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:-

D E R PER MS. MADHUMITA ROY, JUDICIAL MEMBER:- Both the appeals preferred by the different assessees are directed against the orders dated 18.02.2021 passed by the learned Pr. Commissioner of Income- tax, PCIT, Rajkot-1 (hereinafter referred to as the "PCIT"), whereby and whereunder the orders passed by the learned Assessing Officer, both dated 30.11.2017, have been quashed

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:-

D E R PER MS. MADHUMITA ROY, JUDICIAL MEMBER:- Both the appeals preferred by the different assessees are directed against the orders dated 18.02.2021 passed by the learned Pr. Commissioner of Income- tax, PCIT, Rajkot-1 (hereinafter referred to as the "PCIT"), whereby and whereunder the orders passed by the learned Assessing Officer, both dated 30.11.2017, have been quashed

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

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

43 to 55 of Annexure A-5 for allegation of on- money receipt, but alleged sales price of flat mentioned in such impounded documents does not match with the alleged sales price as per statement of Mr. Mihri Joshi. Following are some of the instances/samples of such deviation: Page 10 of 28 ITA Nos. 785 to 787 & 765/Rjt/2024 Six Twenty

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

43 to 55 of Annexure A5\n\nPages No.43 to 55 are sheets containing notings, data and details of Wing wise and flat\nwise cash received, date of booking, flat number, name of purchaser, contact number of\npurchaser, actual sales price, documented price, ON Money received per flat and written as\n\"Received Cash\", etc. I wish to clarify

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

43 to 55 of Annexure A5\n\nPages No.43 to 55 are sheets containing notings, data and details of Wing wise and flat\nwise cash received, date of booking, flat number, name of purchaser, contact number of\npurchaser, actual sales price, documented price, ON Money received per flat and written as\n\"Received Cash\", etc. I wish to clarify

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

43 to 55 of Annexure A5\n\nPages No.43 to 55 are sheets containing notings, data and details of Wing wise and flat\nwise cash received, date of booking, flat number, name of purchaser, contact number of\npurchaser, actual sales price, documented price, ON Money received per flat and written as\n\"Received Cash\", etc. I wish to clarify

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL-1, , RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

43) premises were covered, out of which 32 premises were covered under section 132 of the Income Tax Act 1961 and the other 11 premises were covered uls 133A of the Income Tax Act 1961. The premises covered were a mix of residential and business premises of the related entities, their family members, key associates and employees. The Gangdev group

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

43) premises were covered, out of which 32 premises were covered under section 132 of the Income Tax Act 1961 and the other 11 premises were covered uls 133A of the Income Tax Act 1961. The premises covered were a mix of residential and business premises of the related entities, their family members, key associates and employees. The Gangdev group

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

43) premises were covered, out of which 32 premises were covered under section 132 of the Income Tax Act 1961 and the other 11 premises were covered uls 133A of the Income Tax Act 1961. The premises covered were a mix of residential and business premises of the related entities, their family members, key associates and employees. The Gangdev group

DCIT, CENTRAL CIRLCLE 1, RAJKOT, RAJKOT vs. BUILDCON CREATIONS LLP, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

43) premises were covered, out of which 32 premises were covered under section 132 of the Income Tax Act 1961 and the other 11 premises were covered uls 133A of the Income Tax Act 1961. The premises covered were a mix of residential and business premises of the related entities, their family members, key associates and employees. The Gangdev group