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

92 & 93/RJV2018, dated 09.10.2018, the following\nadditions were confirmed, on which penalty u/s 271(1)(c) of the Act, was\nproposed to levy by the assessing officer:\n(1) Income earned out of credit entries in undisclosed foreign account :\nRs.1,04,61,096/-\n(2) Deemed rent of more than one properties, reflected in the Balance\nSheet Rs.1

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

92 & 93/RJV2018, dated 09.10.2018, the following\nadditions were confirmed, on which penalty u/s 271(1)(c) of the Act, was\nproposed to levy by the assessing officer:\n(1) Income earned out of credit entries in undisclosed foreign account :\nRs.1,04,61,096/-\n(2) Deemed rent of more than one properties, reflected in the Balance\nSheet Rs.1

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

92 & 93/RJV2018, dated 09.10.2018, the following\nadditions were confirmed, on which penalty u/s 271(1)(c) of the Act, was\nproposed to levy by the assessing officer:\n(1) Income earned out of credit entries in undisclosed foreign account :\nRs.1,04,61,096/-\n(2) Deemed rent of more than one properties, reflected in the Balance\nSheet Rs.1

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

92 & 93/RJV2018, dated 09.10.2018, the following\nadditions were confirmed, on which penalty u/s 271(1)(c) of the Act, was\nproposed to levy by the assessing officer:\n(1) Income earned out of credit entries in undisclosed foreign account :\nRs.1,04,61,096/-\n(2) Deemed rent of more than one properties, reflected in the Balance\nSheet Rs.1

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

92 & 93/RJV2018, dated 09.10.2018, the following\nadditions were confirmed, on which penalty u/s 271(1)(c) of the Act, was\nproposed to levy by the assessing officer:\n(1) Income earned out of credit entries in undisclosed foreign account :\nRs.1,04,61,096/-\n(2) Deemed rent of more than one properties, reflected in the Balance\nSheet Rs.1

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 during the year under consideration. Hence, only assessee claimed interest on self-occupied property and not shown any deemed rent income. 7. Regarding room rent expenses of Rs. 23,74,186/-, site expenses of Rs. 28,93,270/-, and salary overtime expenses, the assessee submitted as follows before the learned PCIT: (a)Regarding Room Rent Expenses: the assessee

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

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

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

House Property\" u/s.22 r.w.s.23 of the Act, which\nhas resulted into under assessment,as per learned PCIT, to the tune of\nRs.84,86,212/-.\n11.About the first issue, regarding unsecured loan, without charging interest\ngiven to family members and associated concerns, wherein the PCIT has\nworked out the interest to the tune of Rs.1,09,21,304/-. The Ld.Counsel\nsubmitted

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

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

house agent, renting of godown and\nwarehouse etc. The pioneer and founder of the salt manufacturing business, was\nLate Shri Sadhabhai Ramjibhai Kangad, who has installed the first washery plant\nShri Shamjibhai Shadabhai Kangad & Ors.\nIT(SS)A Nso.11 to 23/RJT/2022 and Ors. (AYs: 2011-12 to 2018-19 & Ors..)\n11\nway back in 1968 in the name of Neelkanth

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)

property in the assessment order so framed by him. Therefore, the satisfaction note recorded by the assessing officer is itself invalid and bad in law and consequently, assessment orders framed by the assessing officer are liable to be quashed. Therefore, we note that required conditions, mentioned above, are not satisfied, hence the “satisfaction note” would be defective, and the assessment

SHRI HEMAL MANHARBHAI VAISHNAV,VERAVAL-362266 vs. THE ITO WARD-4,, VERAVAL

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2012-13. I.T.A No. 201/Rjt/2022 A.Y. 2012-13 Page No 2 Hemal Manharbhai Vaishnav vs. ITO 2. The brief facts of the case is that the assessee is an individual and receiving salary income and interest income

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

properties as seized in the form of Digital Data like and in the form of Hard Data were also compared and corroborated with the documentary evidences and responses received from the Sub-registrar office and with the data available in public domains on various government portals like 1) anyror.gujarat.gov.in 2) garvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial transactions entered

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

properties as seized in the form of Digital Data like and in the form of Hard Data were also compared and corroborated with the documentary evidences and responses received from the Sub-registrar office and with the data available in public domains on various government portals like 1) anyror.gujarat.gov.in 2) garvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial transactions entered

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

properties as seized in the form of Digital Data like and in the form of Hard Data were also compared and corroborated with the documentary evidences and responses received from the Sub-registrar office and with the data available in public domains on various government portals like 1) anyror.gujarat.gov.in 2) garvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial transactions entered

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

properties as\nseized in the form of Digital Data like 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 1) anyror.gujarat.gov.in 2)\ngarvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial\ntransactions entered

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

properties as\nseized in the form of Digital Data like 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 1) anyror.gujarat.gov.in 2)\ngarvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial\ntransactions entered