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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

49,800/-. (iv). Unexplained credit entries in unallocated Gold/Silver account of STCH - Rs.589,63,46,541/-. (v). Cash/Premium payment reflected in STCSH account - Rs.2,40,77,958/-. (vi). Unexplained Investment in Properties and Rent thereof as per KYC documents of Undisclosed Foreign Bank Account Rs.5,93,51,875/- (Rs.5,82,72,750/- + Rs.10,79,125/-). (vii). Deemed Rent of more

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

49,800/-. (iv). Unexplained credit entries in unallocated Gold/Silver account of STCH - Rs.589,63,46,541/-. (v). Cash/Premium payment reflected in STCSH account - Rs.2,40,77,958/-. (vi). Unexplained Investment in Properties and Rent thereof as per KYC documents of Undisclosed Foreign Bank Account Rs.5,93,51,875/- (Rs.5,82,72,750/- + Rs.10,79,125/-). (vii). Deemed Rent of more

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

49,800/-.\n(iv). Unexplained credit entries in unallocated Gold/Silver account of STCH -\nRs.589,63,46,541/-.\n(v). Cash/Premium payment reflected in STCSH account - Rs.2,40,77,958/-.\n(vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10

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

houses, bungalows, shops, flats, offices, tenements workshops, factory buildings, go-downs, warehouses, apartments, buildings, and civil works of all kinds. During the year under consideration, erstwhile Gandhi Realty (India) Private Limited having registered office at "Solitarie", Amin Marg Junction, 150 Ring Road, Nr. Pragati complex, Rajkot-360005 and PAN AACCG5189K (The Transferor Company 1" or "old GRIPL) and Crystal Organisers

PRAMUKH ARANYA DEVELOPERS,JUNAGADH vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee (in ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.372 /Rjt/2024 (निर्धारण वर्ष/Assessment Year: (2018-19) M/S. Pramukh Aranya Developers Office No. 5, First Floor, Cit Centre, Opp. New Collector Officer, B/H. Sardar Baug, Junagadh - 362001 The Pr. Cit-1, Vs. Aayakar Bhawan, Race Course Ring Road, Rajkot - 360001 स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaofp3393F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Appellant By राजस्व की प्रत्यर्थी ओर से/Respondent By : Shri Mehul Ranpura, Ld. Ar : Shri Sanjay Punglia, Ld.Cit (Dr) सुनवाई की तारीख / Date Of Hearing घोषणा की तारीख/Date Of Pronouncement Per Dr. A. L. Saini, Am: : 04/02/2025 : 28/04/2025 आदेश / Order By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 30.03.2024, 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 Year2018-19.Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: M/S. Pramukh Aranya Developers V. Pcit

House Property" u/s.22 r.w.s.23 of the Act, which has resulted into under assessment,as per learned PCIT, to the tune of Rs.84,86,212/-. 11.About the first issue, regarding unsecured loan, without charging interest given to family members and associated concerns, wherein the PCIT has worked out the interest to the tune of Rs.1,09,21,304/-. The Ld.Counsel submitted

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

property he had stated that he took the plot in 1964 from the housing society which was constructing the bungalow for which the assessee made contribution from time to time and took possession in 1974 when only one ground floor was constructed. He had been living there and during 1986 to 1988 he had constructed the first floor

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

property he had stated that he took the plot in 1964 from the housing society which was constructing the bungalow for which the assessee made contribution from time to time and took possession in 1974 when only one ground floor was constructed. He had been living there and during 1986 to 1988 he had constructed the first floor

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

property he had stated that he took the plot in 1964 from the housing society which was constructing the bungalow for which the assessee made contribution from time to time and took possession in 1974 when only one ground floor was constructed. He had been living there and during 1986 to 1988 he had constructed the first floor

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. It also invested in the share market and earned capital gain during the year under consideration. The assessee filed its return of income on 31.12.2011, declaring total income of Rs. 20,65,320/-. A copy of the return of income and computation of income for ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF the year under appeal, were

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. It also invested in the share market and earned capital gain during the year under consideration. The assessee filed its return of income on 31.12.2011, declaring total income of Rs. 20,65,320/-. A copy of the return of income and computation of income for ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF the year under appeal, were

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty

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

house property income of Rs. 30,000/- is treated as unexplained cash credit u/s 68 of the IT Act and added back in the income of the assessee. Since the assessee has already shown a sum of Rs 21,000/- (after claiming standard deduction of 30% from gross receipts), the difference of Rs 9,000 is being added here. Penalty