SHRI SANJAYBHAI GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 ,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 68 of the Act. Accordingly, the amount of ₹68 lakhs was added to the total income of the assessee. Aggrieved assessee preferred an appeal to the learned CIT (A). ITA Nos.174/Rjt/2014 and 26 appeals Shri Dineshbhhai G.Jakasania vs. DCIT and 3 Other Groups AYs – 2005-06 to 2008-09 & 2010-11 & 2011-12 6. The assessee before

SHRI KISHOR GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 68 of the Act. Accordingly, the amount of ₹68 lakhs was added to the total income of the assessee. Aggrieved assessee preferred an appeal to the learned CIT (A). ITA Nos.174/Rjt/2014 and 26 appeals Shri Dineshbhhai G.Jakasania vs. DCIT and 3 Other Groups AYs – 2005-06 to 2008-09 & 2010-11 & 2011-12 6. The assessee before

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

68 of I.T. Act)\nThe assessee has not furnished any explanation on Income Tax expenses that have been\nclaimed to the tune of Rs.8850/- and debited to the P&L_A/c_during the year under\nconsideration. It is an inadmissible item of expense not allowable as per Income Tax Act,\nTherefore, Rs.8850/- is added back to the income of the assessee

KATARIA SNACK PELLETS PRIVATE LIMITED,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

In the result, appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

112) ITA No.- 2189/Del/2018 dated 16.05 2018, which is reproduced below: "For all these reasons, we are of the considered opinion that there has not been any possibility of verifying the correctness or otherwise of the data supplied by the assessee to the merchant banker, in the absence of which the correctness of the result of DCF method cannot

ANSHOYABEN BHAGVANJIBHAI BHOJANI,MORBI vs. INCOME TAX OFFICER, WARD-1, MORBI, MORBI

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 13/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2017-18) Anshoyaben Bhagvanjibhai Bhojani, Income Tax Officer, Ward 1, Morbi Shreeji Nagar, B/H. Chhatralaya Road, Vs. Income Tax Office, Aayakar Vibhag, B/H New Bus Stand, Morbi, J.K. Chamber, National Highway-8-A, Gujarat 363641 At- Lalpar, Morbi Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brnpb6281R (अपीलाथ"/Appellant) (""यथ"/Respondent)

112 in case of Rajeev Bansal (supra). 64. Considering the observations and directions issued by the Hon'ble Apex Court in case of Rajeev Bansal (supra)and applying the same to the facts of the case, we are of the opinion that approval granted by the specified authority as per section 151(i) of the Act for issuance

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

68 ELT 548, 551(All.) In the present case no such circumstances are warranted as in the list of beneficiaries to whom the unaccounted money was routed into their account/books in the garb of Long Term Capital Gain were provided by the said group categorically contains the name and address of the assessee, further the group has categorically admitted that

KAUSHALIYA SAMPATLAL DUDANI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(6), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.659/Rjt/2025 िनधा"रण वष"/Assessment Year :2012-2013 Kaushaliya Sampatlal Dudani The Ito, Ward-2(6), बनाम/ K-1/79/4 G.I.D.C., Shanker Ayakar Bhawan, Jamnagar Vs Tekri, Udyognagar, Jamnagar Jamnagar. Gujarart-361005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Abnpd8662P (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज" की ओर से/Revenue By : Shri Abhimanyu Singh, Ld. Sr-Dr

section 10(38) of The Act. Kiran Kothari Vs ITO [ITA 443/Kol/2017] "we note that the assessee had furnished all relevant evidence in the form PARTMENT of bills. contract notes, demat statement and bank account to prove the genuineness of the transactions relevant to the purchase and sale of shares resulting in long term capital gain. Neither these evidences

THE ACIT, CENTRAL CIRCLE-2,, MORBI vs. M/S. KISHAN PLUS MINARALS, RAJKOT

In the result, appeal filed by the Revenue (In ITA No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2021 With Cross Objection No.02/Rjt/2022 "नधा"रणवष"/ Assessment Year: 2019-20 Acit, Cent.Cir.2 M/S.Kishan Plus Minerals बनाम Rajkot. Jetpar Road, Nr. Pavadiyali Temple, Jasmatgadh Vs. Morbi. Pan : Aaqfk4689P (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld. Counsel राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 29/01/2025 (Originally Heard Refixed On 05.06.2025 घोषणा क" तार"ख /Date Of Pronouncement : 20/06/2025 Order Per Dr. Arjun Lal Saini:

section 68 of the Act. 10. Aggrieved by the order of the assessing officer, the assessee carried the matter in appeal before the Ld. CIT(A) who has partly allowed the appeal of the assessee. The Ld. CIT(A) noticed that the first finding of the assessing officer is that the statement given by Shri Bhagwanjibhai was on oath

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

112 in case of Rajeev Bansal (supra). 64. Considering the observations and directions issued by the Hon'ble Apex Court in case of Rajeev Bansal (supra)and applying the same to the facts of the case, we are of the opinion that approval granted by the specified authority as per section 151(i) of the Act for issuance

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

112 in case of Rajeev Bansal (supra). 64. Considering the observations and directions issued by the Hon'ble Apex Court in case of Rajeev Bansal (supra)and applying the same to the facts of the case, we are of the opinion that approval granted by the specified authority as per section 151(i) of the Act for issuance

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

112 ITR 592.\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

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

112 ITR 592.\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

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

112 ITR 592.\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

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

112 ITR 592.\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

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

112 ITR 592.\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

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

112 ITR 592.\n\nIn connection to the above, it is submitted that it is well settled proposition of law the\nlegal fiction crated by section 40(a)(ia) will not apply to the provisions of Section\n271(1)(c) of the Act, the disallowance made simply by invoking the provisions of\nSection

CHAMPALAL COMPANY,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for\nstatistical purposes

112 (Ahd.) (Mag). wherein, it was held\nthat -\n\"loose papers and documents seized from premises of third parties and statement recorded at\nback of assessee without it being afforded opportunity to interrogate said documents and without\nbringing on record any supporting evidence, could not be made basis for adding undisclosed\nincome in hands of assessee.\"\n3 Section 292C

SHRI RAMJI HAMIR VIRDA,GANDHIDHAM vs. THE DCIT, CENTRAL CIRCLE-1, RAJKOT

In the result, all these appeals filed by the different assessees, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrids Hearing) आयकरअपीलसं./Ita No.400/Rjt/2023 Assessment Year: (2021-22)

112 (Ahd.) (Mag). wherein, it was held that - “loose papers and documents seized from premises of third parties and statement recorded at back of assessee without it being afforded opportunity to interrogate said documents and without bringing on record any supporting evidence, could not be made basis for adding undisclosed income in hands of assessee.” 3 Section 292C shows