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

21,459/- are\nmade as under:\n(i). Income earned out of credit entries in undisclosed foreign Bank account -\nRs.32,40,46,529/-.\n(ii). Unexplained credit entries of various concerns/third parties in Standard\nBank, London's account - Rs.3,77,42,710/-.\n(iii). Unmatched entries in STCSH account - Rs.3,78,49,800/-.\n(iv). Unexplained credit entries in unallocated

M/S. UNITED ENGINEERS, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, RAJKOT, RAJKOT

In the result, the above appeals of the assessee are partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

5), reported in [2012] 20 taxmann.com 380 (Pune) wherein it was held as under: “On perusal of the provisions laid down under section 153C, it is apparent that after issuance of notice under section 153C, the Assessing Officer having jurisdiction over such other person (against which incriminating material has been found during the course of search conducted on a person

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA, No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 510, 511 & 512/Rjt/2025 (िनधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Vallabhbhai Bhagvanjibhai Vs. Ito Ward 2(10) Jamnagar Kathiriya Aayakar Bhavan, Jamnagar, Khitadia, Jamnagar, Jamnagar - 361006 Jamnagar – 361006 Pan No. - Αυτρκ7716N (Appellant) (Respondent)

21 of 24 ITA Nos. 510 Rjt 2025 & 9 Ors. Vallabhbhai Bhagvanjibhai Kathiriya for A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the assessee submitted that no penalty should be imposed on estimated addition. Learned Counsel pointed out that assessing officer made the estimation on turnover/ deposits in bank account, and on appeal

KLIN INDUSTRIES,SANDHA KHAMIDANA, JUNAGADH vs. THE ACIT, CIRCLE, JUNAGADH, JUNAGADH

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini

21,198/-, under section 271(1)(c) of the Act, despite the final tax liability for A. Y. 2014-15, having been determined and levied exclusively under the deemed provisions of Section 115JC (AMT) of the Act. 4. That the Ld. authorities failed to appreciate that the case is covered by the reasonable cause u/s 273B; hence no penalty

VALLABHBHAI BHAGVANJIBHAI KATHIRIYA,JAMNAGAR vs. ITO WARD 2(10) JAMNAGAR, JAMNAGAR

21 of 24\nITA Nos. 510 Rjt 2025 & 9 Ors.\nVallabhbhai Bhagvanjibhai Kathiriya\nfor A.Y. 2014-15 - penalty u/s. 271(1)(c) of the Act. Learned Counsel for the\nassessee submitted that no penalty should be imposed on estimated addition.\nLearned Counsel pointed out that assessing officer made the estimation on\nturnover/ deposits in bank account, and on appeal

DINESHCHANDRA N. SHAH,,JAMNAGAR. vs. INCOME TAX OFFICER, WARD-2(5),, JAMNAGAR.

In the result, the appeal of the assessee is allowed

21-02-2018, in proceedings under section 271(1)(c) of the Income Tax Act, 1961; in short “the Act”. I.T.A No. 128/Rjt/2018 A.Y. 2013-14 Page No 2 Shri Dineshchandra N. Shah Vs. ITO 2. The only issue raised by the assessee is that the learned CIT (A) erred in confirming the penalty amounting to Rs. 18,390/- under

M/S. GUPTA GLOBAL EXIM PVT. LTD.,,GANDHIDHAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

The appeal of the assessee is allowed, and appeal of the Assessing

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

u/s. 271(1)(c) of the I.T. Act of Rs.40,90,779/-.” 15. The only issue raised by the assessee is that the learned CIT (A) erred in imposing the penalty of Rs. 40,90,779.00 under the provisions of section 271(1)(c) of the Act. 16. The assessee in the year under consideration has declared the loss

M/S. DECENT METAL PRODUCTS,JAMNAGAR vs. THE ITO, WARD-3 (1), JAMNAGAR

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

u/s. 271(1)(c) of the Act and therefore, the same is confirmed.” 5. Being aggrieved by the order of the learned CIT (A), the assessee is in appeal before us. ITA No. 139/Rjt/19 [Decent Metal Products vs. ITO] A.Y. 2010-11 - 3 - 6. The learned AR before us filed a paper book running from pages

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

5 made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search

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

5 made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search

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

5 made separately for each AY on the basis of the findings of the search and any other material existing or brought on the record of the AO. vii. Completed assessments can be interfered with by the AO while making the assessment under Section 153 A only on the basis of some incriminating material unearthed during the course of search