THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

section 124(3)(b) of the I.T. Act, 1961 in terms of which jurisdiction of an Assessing Officer cannot be called in question by on assessee after expiry of one month from date on which he was served with a notice for reopening assessment under section 148 of the I.T Act. 2. Thee learned

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions

SHRI CHANDUBHAI RAMJIBHAI KAQTHIRIYA,JASDAN, DIST. RAJKOT-364490 vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Or At The Time Of Hearing Of Appeal.”

68 r.w.s. 115 BBE of the Act. Therefore, in our view it is not a case where the AO had not made due enquiries and also not the case where the AO had not applied his mind during the course of assessment proceedings on the issue in hand. Regarding the scope of proceedings

M/S. EMBOZA GRANITO PVT. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

In the result, appeal filed by assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 240/Rjt/2019 िनधा"रण वष"/Asstt. Years: 2016-2017

68 of the Act in respect of share capital & unsecured loan introduced/raised during the year and the claim of depreciation and additional depreciation. The Pr. CIT-3 made the following observations while passing the Order:- In view of the above, since the twin conditions namely, (i) the order of the Assessing Officer sought to be revised is erroneous

M/S. PERTH CERAMIC PVT. LTD.,MORBI vs. THE PR. CIT-3, RAJKOT, RAJKOT

In the result, appeal filed by assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 191/Rjt/2019 िनधा"रण वष"/Asstt. Years: 2015-2016 M/S. Perth Ceramic Pvt. Ltd., The Principal Commissioner Of At. Unchi Mandal, Vs. Income Tax-3, Opp. 66 Kva Sub Station, Rajkot. Morbi-363641. Pan: Aahcp6296P

68 of the Act in respect of share capital of Rs. 15,15,02,000/- out of total share capital introduced of Rs. 19,99,00,000/- and gave a direction to revise the income, after allowing an opportunity of hearing to the assessee. The Pr. CIT-3 made the following observations while passing the Order:- “9. As noted above

CORUS VITRIFIED PVT. LTD.,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

68 of the Act in the assessment for A.Y. 2013-14. The assessee had filed appeal against the aforesaid order and the appeal was finally closed under the Vivad Se Vishwas Scheme. Accordingly, once the unsecured loans have been taxed in the hands of the assessee at the time when they were received by the assessee

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

section 68 on unexplained cash credits is the correct position of law. It is\nrequested to sustain the unexplained cash credits u/s 68 of the IT Act and dismiss the\nappeal of the assessee while confirming the appeal of the Department.\"\n46. On the other hand, Ld. Counsel for the assessee submitted that during\nappellate proceedings Ld.CIT(A) called

THE ACIT, CEN. CIR.-1,, RAJKOT-GUJARAT vs. M/S. SIYARAM METAL UDYOG PVT. LTD.,, JAMNAGAR

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

section 68 of the Act and added to the total income of the assessee. 8. The aggrieved assessee preferred an appeal before the learned CIT(A) who deleted the addition made by the AO by observing as under: “8. The contents of the assessment order and submission of the appellant have been perused. The AO treated the amount

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

section 124(3)(b) of the I.T. Act, 1961 in terms\nof which jurisdiction of an Assessing Officer cannot be called in question by on\nassessee after expiry of one month from date on which he was served with a notice for\nreopening assessment under section 148 of the I.T Act.\n2. Thee learned

SHRI BHARATKUMAR ISHWARBHAI BHATIYA,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1,, RAJKOT-GUJARAT

section 124(3)(b) of the I.T. Act, 1961 in terms\nof which jurisdiction of an Assessing Officer cannot be called in question by on\nassessee after expiry of one month from date on which he was served with a notice for\nreopening assessment under section 148 of the I.T Act.\n2. Thee learned

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

section 143(3) r.w.s. 263 of the Act and\nAssessing Officer made following addition:\n34\n1. BHARATKUMAR ISHWARBHAI BHATIYA\n2. DHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI\ni.\nAddition an account of commission income of Rs. 8,61,446/-.\nii.\nAddition of peak credit in bank account of Rs. 46,50,353/-.\nOn appeal, before Ld. CIT(A), the assessee

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

section 124(3)(b) of the I.T. Act, 1961 in terms\nof which jurisdiction of an Assessing Officer cannot be called in question by on\nassessee after expiry of one month from date on which he was served with a notice for\nreopening assessment under section 148 of the I.T Act.\n2. Thee learned

THE DY. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT vs. BHARATKUMAR ISHWARBHAI BHATIYA,, RAJKOT

section 143(3) r.w.s. 263 of the Act and\nAssessing Officer made following addition:\n34\nH\nBHARATKUMAR ISHWARBHAI BHATIYA\nDHAMJIBHAI & KHIRAJMAL LEKHRAJBHAI THALVANI\ni.\nAddition an account of commission income of Rs. 8,61,446/-.\nii.\nAddition of peak credit in bank account of Rs. 46,50,353/-.\nOn appeal, before Ld. CIT(A), the assessee did not press

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

section 68 of\nthe Act, where any sum is found credited in the books of an assessee maintained\nfor any previous year and the assessee offers no explanation about the nature\nand source there of or the explanation offered by him is not in the opinion of the\nA.O. satisfactory the sum so credited may be charged to Income

ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM vs. KAMLESH DEORAJ JAIN, GANDHIDHAM

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dr. Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 594/Rjt/2025 "नधा"रणवष" / Assessment Year: (2017-18) (Hybrid Hearing) Assistant Commissioner Of Income Vs. Kamlesh Deoraj Jain, Tax, Bbz-N-108, Khanna Market, Plot No. 20/A, Sector No. 8, Gandhidham, Gandhidham Gandhidham Gujarat 370201 Gujarat 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (Appellant) (Respondent) Appellant By : Shri Sunil Maloo, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 01 / 12 /2025 Date Of Pronouncement : 21/ 01 /2026

108, Khanna Market, Plot No. 20/A, Sector No. 8, Gandhidham, Gandhidham Gandhidham Gujarat 370201 Gujarat 370201 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: ADOPJ1769Q (Appellant) (Respondent) Appellant by : Shri Sunil Maloo, Ld. AR Respondent by : Shri Abhimanyu Singh Yadav Ld. SR. DR Date of Hearing : 01 / 12 /2025 Date of Pronouncement : 21/ 01 /2026 आदेश / O R D E R PER, Dr. DINESH

SHIV SHAKTI GINNING AND PRESSING PVT. LTD,ADIPUR KUTCH vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 102/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 M/S Shiv Shakti Ginning & Pressing The Principal Commissioner Private Limited, Vs. Of Income Tax, Plot No.1, Ward No.1/B, Rajkot-1, Opp. Aum Mandir, Rajkot. Industrial Area, Adipur-370205 (Gujarat)

68 of the Act. Accordingly, the PCIT initiated the proceedings under section 263 of the Act vide show cause notice dated 16 January 2022. 4.1 The assessee in response to such show cause notice submitted that during the assessment proceeding detailed enquiries were made by the AO and the necessary required details were duly submitted. Thereafter, the AO after