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

36(1)(iii) of the Act - Rs.1,04,88,591/-.\n(x). Disallowance of hedging loss Rs.79,37,455/-.\n6.\nIn respect of above additions, penalty u/s 271(1)(c) of the Act, was also\ninitiated for concealment of income by furnishing inaccurate particulars of\n3\nH\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj

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

36(1)(iii) of the Act - Rs.1,04,88,591/-.\n(x). Disallowance of hedging loss Rs.79,37,455/-.\n6.\nIn respect of above additions, penalty u/s 271(1)(c) of the Act, was also\ninitiated for concealment of income by furnishing inaccurate particulars of\n3\nhis income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated 10.07.2017, was\nissued

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

36(1)(iii) of the Act - Rs.1,04,88,591/-.\n(x). Disallowance of hedging loss Rs.79,37,455/-.\n6.\nIn respect of above additions, penalty u/s 271(1)(c) of the Act, was also\ninitiated for concealment of income by furnishing inaccurate particulars of\n3\n==End of OCR for page 3==\nITA No.76 to 81/RJT/2022

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

36(1)(iii) of the Act - Rs.1,04,88,591/-.\n(x). Disallowance of hedging loss Rs.79,37,455/-.\n\n6.\nIn respect of above additions, penalty u/s 271(1)(c) of the Act, was also\ninitiated for concealment of income by furnishing inaccurate particulars of\n\n3\n\nhis income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated

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

36(1)(iii) of the Act - Rs.1,04,88,591/-.\n(x). Disallowance of hedging loss Rs.79,37,455/-.\n6.\nIn respect of above additions, penalty u/s 271(1)(c) of the Act, was also\ninitiated for concealment of income by furnishing inaccurate particulars of\n3\nITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15)\nPankaj

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

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)

iii) Penalty order-ITA No.530/Rjt/2025 - Α.Υ. 2015-16 - Penalty u/s.271F of the Act Therefore, above penalties are deleted and above appeals of the assessee, are allowed. 20. Now, we shall take assessee`s remaining appeals for assessment year 2013- 14 and for assessment year 2014–15, and for assessment year 2016-17, the details of these appeals, assessment year

THE ACIT-CENTRAL CIRCLE-2, RAJKOT vs. SHRI VICKY BALKRISHNA MEHTA, RAJKOT

The appeal of the Revenue is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2004-05 Assistant Commissioner Of Vs. Shri Vicky Balkrishna Mehta, Income-Tax, 7Th Floor, Mansrovar Central Circle-2, Apartment, Royal Park, Rajkot Kalawad Road, Rajkot Pan : Agqpm 6495 B अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 28.11.2022 घोषणा क" तार"ख /Date Of Pronouncement: 22.02.2023 आदेश/O R D E R Per Annapurna Gupta: This Appeal Is Preferred By The Revenue Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-13, Ahmedabad (Hereinafter Referred To As “Cit(A)”) Dated 22.01.2020 Passed U/S 250(6) Of The Income-Tax Act, 1961, (Hereinafter Referred To As “The Act”) For Assessment Year (Ay) 2004-05. 2. The Grounds Of Appeal Raised By The Revenue Read As Under:

iii) of the proviso to Section 34(1) of the Indian Income Tax Act, 1922, as it then stood, a notice of assessment or reassessment could not be issued against a person deemed to be an agent of a non-resident under Section 43, after the expiry of one year from the end of the year of assessment. The Section

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

u/s 271(1 )(C) of the Act is initiated for concealment of income.” 30. The ld.CIT(A) has confirmed the addition of Rs.9,000/- on the ground that the assessee has not shown from which property this rental income was received. The stand of the assessee is that since this is the assessment order framed under section 153A, therefore

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

u/s 271(1 )(C) of the Act is initiated for concealment of income.” 30. The ld.CIT(A) has confirmed the addition of Rs.9,000/- on the ground that the assessee has not shown from which property this rental income was received. The stand of the assessee is that since this is the assessment order framed under section 153A, therefore

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

u/s 271(1 )(C) of the Act is initiated for concealment of income.” 30. The ld.CIT(A) has confirmed the addition of Rs.9,000/- on the ground that the assessee has not shown from which property this rental income was received. The stand of the assessee is that since this is the assessment order framed under section 153A, therefore

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

u/s 271(1 )(C) of the Act is initiated for concealment of income.” 30. The ld.CIT(A) has confirmed the addition of Rs.9,000/- on the ground that the assessee has not shown from which property this rental income was received. The stand of the assessee is that since this is the assessment order framed under section 153A, therefore