GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

TDS u/s 194A of the Act; d) The Ld. assessing officer did not conduct any sort of enquiry/investigation and had not issued any notices u/s.133(6)/131 to the lenders and their bankers to verify the transactions; e) The Ld. assessing officer had not provided the copies of contrary material/evidence and statements of 3rd parties for rebuttal and also

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section 148 of the Act and not the JAO. 7. In this regards

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

147 of the Act and inapplicable till the issuance of notice under Section 148 of the Act. 6. The Scheme is clearly applicable for issuance of notice under section 148 of the Act and accordingly, it is only the FAO which can issue the notice under section 148 of the Act and not the JAO. 7. In this regards

AMARDEEP EXPORTS,JAMNAGAR vs. INCOME TAX OFFICERWARD 1(3), JNR, JAMNAGAR

In the result, the appeal is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

TDS return – other interest (section 164A) Rs. 1,64,527/- 3. Cash transaction of Rs. 100000 and more Rs. 15,00,000/- 4. Shipping bill for exports for value exceeding Rs. 5 Lakh (Custom export) Rs. 10,21,87,070/- Total Rs. 10,89,13,197/- 4. The case was reopened for reassessment u/s 147

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

TDS\nu/s 194A of the Act;\nd) The Ld. assessing officer did not conduct any sort of\nenquiry/investigation and had not issued any notices u/s.133(6)/131_to\nthe lenders and their bankers to verify the transactions;\ne) The Ld. assessing officer had not provided the copies of contrary\nmaterial/evidence and statements of 3rd parties for rebuttal and also\ndid

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

147 r.w.s. 144B of the MansukhbhaiKanjibhai Sakariya Vs. Pr.CIT 4 Income tax Act, 1961 on 28.03.2022, is erroneous and prejudicial to the interest of the revenue. 4.Considering above such facts, notice u/s 263 of the Income-tax Act, 1961, was issued by ld.PCIT, on 29.02.2023 and duly served upon the assessee.The ld. PCIT stated in the notice that assessee case

KASHYAP WIND & SOLAR ENERGY PVT. LTD.,JAMNAGAR vs. THE ITO WARD 1 (3) JAMNAGAR, JAMNAGAR

The appeal is dismissed

Bench: DR. ARJUN LAL SAINI (Accountant Member), DR. DINESH MOHAN SINHA (Judicial Member)

147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), vide order dated 13.12.2024. 2. Grounds of appeal raised by the assesse, are as follows: “ 1. The Ld. CIT(A), NFAC has erred in law and on facts in dismissing the appeal filed by the Appellant by treating it as non-maintainable without affording

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

TDS return etc. of the parties with whom alleged\ntransactions made.\n(viii) On the basis of facts and circumstances, AO has correctly adopted\nthe figures of G.P of Rs.2,40,30,182/- which is as per show cause notice.\nHowever, assessee was free to substantiate its claim with documentary\nevidences, which assessee failed even in response to draft assessment

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

TDS return etc. of the parties with whom alleged transactions made. (viii) On the basis of facts and circumstances, AO has correctly adopted the figures of G.P of Rs.2,40,30,182/- which is as per show cause notice. However, assessee was free to substantiate its claim with documentary evidences, which assessee failed even in response to draft assessment order

KRUPALU METALS P. LTD.,JAMNAGAR vs. THE NFAC CIT(A), DELHI, DELHI

In the result, assessee’s appeal ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita Nos.111 To 113/Rjt/2024 "नधा"रणवष" /Assessment Years: 2013-14 To 2015-16

TDS return etc. of the parties with whom alleged transactions made. (viii) On the basis of facts and circumstances, AO has correctly adopted the figures of G.P of Rs.2,40,30,182/- which is as per show cause notice. However, assessee was free to substantiate its claim with documentary evidences, which assessee failed even in response to draft assessment order

DREAM INFRASTRUCTURE,RAJKOT vs. THE INCOME TAX OFFICER, WARD - 1(1)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 220/Rjt/2025 ("नधा"रण वष" / Assessment Year: 2011-12) Dream Infrastructure, Vs. Income Tax Officer, Mavdi Survey No. 358, B/H. Mavdi Ward-1(1)(1), Village, Kankot Road, Mavdi, Rajkot Rajkot-360004(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfd2565L (Assessee) (Respondent) Assessee By : Shri D.M. Rindani, Ar Respondent By : Shri Abhimanyu Singh Yadav, Sr. Dr Date Of Hearing : 22/09/2025 Date Of Pronouncement : 04/12/2025

u/s. 142(1)r.w.s 129 of the I T Act was issued on 19.11.2018 for further required details. 4.In response, of the above notices, the assessee submitted its reply, before the assessing officer. The assessee has objected to the reopening the case. Order disposing off objections passed on 07.12.2018. In response to the above notices issued, the assessee attended

H J ENTERPRISE,RAJKOT vs. ACIT, CIRCLE-1(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

147 of the Act is invalid and assessment made on such invalid initiation deserves to be quashed and may kindly be quashed. 3. The Id. CIT(A) erred on facts as also in law in confirming addition of Rs. 48,00,000/-being alleged accommodative entries in the form of unsecured loan of Rs. 48,00,000/- from M/s. Bhoomidev

K.G.N.ENTERPRISE,VERAVAL vs. INCOME TAX OFFICER, VERAVAL

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.181/Rjt/2025 िनधा"रण वष"/Assessment Year : 2019-20 K.G.N. Enterprise बनाम/ Income Tax Officer Al Iraki Bageraza Lucky Colony, Vs Ward – 4, Range 201, Junagarh, Ner Somnathtokish, Behind Amit Veraval Akela Clinic, Veraval, Gir Somnath, Gujarat - 362264 "ायीलेखासं./जीआइआरसं./Pan/Gir No.:Aatfk8798E (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri R. B. Shah, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख /Date Of Hearing : 15/09/2025 घोषणा की तारीख /Date Of Pronouncement : 09/12/2025 आदेश/Order

u/s 139(1) of the Act. The information has been received in the case of the assessee that the assessee, during the year under consideration, had received contractual receipts amounting to Rs. 11,87,999/- but had not filed the return of income for the year under consideration. Therefore, undeclared income from these receipts and non-filing of return

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

147 of the Act on the basis of the information received from the Investigation Wing that M/s Moral Alloy (P) Ltd is an accommodation entry provider and the assessee company is a beneficiary of such accommodation entity through M/s Ankit Metals in the form of non-genuine purchase and/or credits to the tune of Rs.1,07,50,000/- during

SHIV EXTRUSION,JAMNAGAR vs. INCOME TAX OFFICER, JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 646/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Shiv Extrusion Vs. Income Tax Officer Plot No.3978 Phase Iiiroad Income Tax Office, Ito Ward No.-R Dared, Jamnagar 2(10), Jamnagar, Income 361004, Gujarat, India, Jamnagar Tax Office, Shiv Smruti, Jamnagar, Jamnagar, Gujarat, 361008, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abkfs7199F (Appellant) (Respondent) Appellant By : Shri Ramesh M. Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23/12/2025 Date Of Pronouncement : 12/03/2026

147 read with section 144B of the I.T. Act. Shiv Extrusion vs. ITO 2. The Grounds of appeal raised by the assessee are as follows: - 1. 1. Jurisdictional Defects (Limitation and Threshold Failure) 1. Invalid Assumption of Jurisdiction due to Retrospective Failure of Monetary Tinreshold (Section 149(1)(b)): The NFAC erred in sustaining the reassessment initiated under the extended