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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

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)

unexplained money u/s.69A of the Income Tax Act, 1961. Accordingly, addition to this extent of 10% of cash deposits/credits which comes to Rs.15,86,480/- was confirmed by ld.CIT(A) and balance addition was deleted. 9. During the appellate proceedings, before learned CIT(A), the assessee has raised additional technical/legal grounds, such as notice under section 147/148

LATE OGHADBHAI KARABHAI ODEDRA (L/H BABUBHAI ODEDRA),PORBANDAR vs. INCOME TAX OFFICER, WARD - 2(4), PORBANDAR, PORBANDAR

In the result, appeal filed by the assessee is partly allowed, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.915/Rjt/2024 िनधा"रणवष" / Assessment Year: (2010-11) (Hybrid Hearing) Late Oghadbhai Karabhai Odedara Vs. Income Tax Officer, (L/H Babubhai Oghadbhai Odedara) Ward-2(4), At Bavalvav, Porbandar, Porbandar Gujarat-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajpo3410B (Appellant) (Respondent) Appellant By : Shri Dushyant Maharshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. (Dr) Date Of Hearing : 05/ 03/2025 Date Of Pronouncement : 29/05/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am

reassessment. 6. Hon'ble CIT (Appeals) erred in upholding addition of Rs. 7,70,000/- u/s. 69A as unexplained money

RAMJI HARAKHJI FEFAR (HUF),RAJKOT vs. ITO, WARD-1(1)(3), RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.397/Rjt/2024 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Ramji Harakhjifefar(Huf), Vs. The Ito, Ward-1 (1) (3), “Gayatri”, 3- Navjyot Park, Kalawad Aaykar Bhavan, Race Course Road, Off 150Feet Ring Road, Ring Road, Rajkot - 360001 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanhr5839R (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shriabhimanyu Singh Yadav, Ldsr Dr Date Of Hearing : 20 /12/2024 Date Of Pronouncement : 06 /03/2025

unexplained money in the bank account of the assessee in absence of substantial supporting evidence.” 11. We note that the appellant has maintained books of account and recorded the transaction with five persons in books of account which was duly submitted before the AO as mentioned in para 3.0 of the assessment order. In such circumstances provision of section

SHRI SANJAY GORDHANDAS VAJA,AHMEDABAD vs. THE ITO, INTERNATIONAL TAXATION, GANDHIDHAM-KUTCH, GANDHIDHAM-KUTCH

In the result, this appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.89/Rjt/2024 Assessment Year: 2018-19 Sanjay Gordhandas Vaja Income Tax Officer Int. 202, Harmony Heights, Capital Road, बनाम Tax), Gandhidham, Income- Science City, Ahmedabad-380 060 Tax Office, Amruta Estate /Vs. Building, Nr. Girnar Cinema, M.G. Road, Rajkot-360 001 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Ahtpv 3289 L (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Aseem Takkar, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 31/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 30/09/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2018-19, Is Directed Against The Final Order Passed By The Assessing Officer, (After Incorporating Findings Of Dispute Resolution Panel-2 Mumbai, Dated 29.12.2023), Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) .

unexplained money at the end of financial year u/s 69A of the Act, the ld DRP noticed that the correct difference between the closing balance and the opening balance for the financial year under consideration is Rs. 95,222/- instead of Rs.4,03,914/-. Therefore, in the view of the panel, the addition herein u/s 69A Sanjay G Vaja would

SMT. SUMARIBEN R. ODEDARA,PORBANDAR vs. THE INCOME TAX OFFICER, WARD-2(3), PORBANDAR

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

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

unexplained money and added as the income of the assessee and demanded tax thereon. I.T.A No. 288/Rjt/2019 A.Y. 2010-11 Page No 3 Smt. Sujariben R. Odedra vs. ITO 3. Aggrieved against the same, the assessee filed an appeal before the Ld. Commissioner of Income Tax (Appeals), Jamnagar. The assessee submitted that she filed Return of Income declaring

SHRI MAHESH K. BHUTIYA,PORBANDAR vs. THE INCOME TAX OFFICER, WARD-2(3), PORBANDAR

unexplained money and such addition of the AO is hereby confirmed. Thus the ground of appeal of the appellant is dismissed. 6. We have heard both the parties. We have noted that the Revenue has accepted the income returned by the assessee from his business by I.T.A No. 289/Rajkot/2019 A.Y. 2010-11 Page No 6 Mahesh K. Bhutiya

MS ADITYA PLASTIC,RAJKOT vs. THE INCOME TAX OFFICER, WARD 3(1)(1), RAJKOT-, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

unexplained money. 4. Aggrieved by the order of the AO, the assessee carried the matter in appeal before the ld.CIT(A) who has confirmed the action of the AO. 5. Dissatisfied with the order of the Ld.CIT(A), the assessee is in further appeal before us. 3 ITA No.185&186/Rjt/2024 (AY 2013-14) Aditya Plastic

MS ADITYA PLASTIC,RAJKOT vs. THE INCOME TAX OFFICER, NFAC, DELHI, DELHI

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./I.T.A. No.185 & 186/Rjt/2024 (िनधा"रणवष" / Assessment Year :2013-14) बनाम/ M/S Aditya Plastic The Income Tax Officer Umiya Industrial Building Ward-3(1)(1) Vs. Near New Nehru Nagar Rajkot -360 001 Main Road, Dhebar Road Rajkot – 360 004 "ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aajfa 4558 In (अपीलाथ"/Appellant) .. (""थ" / Respondent) Assessee By : Shri D.M. Rindani, Ld.Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr सुनवाईकीतारीख/ Date Of Hearing 05/06/2025 घोषणाकीतारीख/Date Of Pronouncement 03/09/2025 आदेश / O R D E R Per Bench-: Captioned Two Appeals Filed By The Same Assessee Pertaining To Assessment Year (Ay) 2013-14 Are Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Cit(A)-[(In Short “Ld.Cit(A)”] Vide Order Dated 01/02/2024, Which In Turn Arises Out Of An Assessment Order Dated 29/09/2021Passed By The Assessing Officer (Ao) U/S. 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short, “The Act”) Pertaining To Assessment Year (Ay) 2013-14. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows:

unexplained money. 4. Aggrieved by the order of the AO, the assessee carried the matter in appeal before the ld.CIT(A) who has confirmed the action of the AO. 5. Dissatisfied with the order of the Ld.CIT(A), the assessee is in further appeal before us. 3 ITA No.185&186/Rjt/2024 (AY 2013-14) Aditya Plastic

SHRI PRASHANT JENTILAL RAMANI,RAJKOT vs. THE ITO 3 (1) (3), RAJKOT, RAJKOT

In the result, these Tax Appeals are also allowed

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

unexplained money by invoking the provisions of Section 69A of the Income Tax Act, 1961. 3. The Appellant craves leaves to add, to amend, alter, modify and/or withdraw any or all of the above grounds of appeal, each of which are without prejudice to one another. 5. It is seen from record, the case is listed for hearing 5th time

SHRI PRASHANT JENTILAL RAMANI,RAJKOT vs. THE ITO 3 (1) (3), RAJKOT, RAJKOT

In the result, these Tax Appeals are also allowed

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

unexplained money by invoking the provisions of Section 69A of the Income Tax Act, 1961. 3. The Appellant craves leaves to add, to amend, alter, modify and/or withdraw any or all of the above grounds of appeal, each of which are without prejudice to one another. 5. It is seen from record, the case is listed for hearing 5th time

HARIDAS MULJI RUGHANI,PORBANDAR vs. INCOME TAX OFFICER - WARD 2(3), PORBANDAR

In the result, the appeal filed by the assessee is partly allowed

reassessment order u/s. 147 of the Act is bad in law. 3. The learned Assessing Officer has erred in law as well as on facts for making an addition of cash deposits pertaining to Specified bank notes of Rs.9,80,000/- treating them as unexplained money

KISHORBHAI DATTANI,JAM KHAMBHALIA vs. INCOME TAX OFFICER, WARD -1, DWARKA, DWARKA

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 555/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Kishorbhai Dattani Vs. Income Tax Office, Hospital C/O. Sarda & Sarda (Ca), Sakar 1St Road, Near Rajdhani Hotel, Floor, Dr. Radha-Krishnan Road, Dwarka, Gujarat 361335 Opp. Rajkumar College, Rajkot, Rajkot Gujarat 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakpd7272M (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 03 / 11 /2025 Date Of Pronouncement : 02/ 02 /2026

reassessment order u/s. 147 r.w.s. 144B of the Act is bad in law. 2. The reopening of assessment u/s. 147 of the Act is bad in law. 3. The learned Assessing Officer has erred in law as well as on facts in making the addition of Rs. 10,00,000/- under section 69A read with section 115BBE