SHRI DHILAN BHUPATRAI BHATHA,RAJKOT vs. THE ITO-WARD-1 (1), JAMNAGAR, JAMNAGAR

In the result, all the three appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Mahavir Prasad

Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition

SHRI DHILAN BHUPATRAI BHATHA,RAJKOT vs. THE ITO-WARD-1 (1), JAMNAGAR, JAMNAGAR

In the result, all the three appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Mahavir Prasad

Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition

SHRI DHILAN BHUPATRAI BHATHA,RAJKOT vs. THE ITO-WARD-1 (1), JAMNAGAR, JAMNAGAR

In the result, all the three appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Mahavir Prasad

Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition

CLAYMINE MICRONS LLP,WANKANER vs. PRINCIPAL CIT 1, RAJKOT

In the result, the appeal of the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

section 68 of the Act i.e. Identity, Capacity and Genuineness of transition are discharged by the LL.P 8. Judiciaries have time and again held that the assessing authority should restrict the verification of cash credit received to the extent of verification of source/creditworthiness of creditor and not to verify the "source of source In this regard, reliance is placed

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

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

section 68, 69, 69A to 69D of the IT Act and as such, in the light of non- disputed fact that unexplained credit whether found in the bank statement of the assessee, who regularly maintain books of accounts. Ld. ITAT should have agreed to legal- plea of the Revenue that till onus with respect to identity, credit worthiness

SHREE SAMARTH ELECTRICALS PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

120 days in ITA No.612/RJT/2024,as also 119 days’ delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024, and admit these respective appeals for hearing. 7. For the sake of convenience, the grounds as well as the facts narrated in ITA No.612/RJT/2024, for assessment Year 2018-19, have been taken into consideration for deciding the above appeals

SHREE SAMARTH SWITCHGEAR AND TRANSMISSION PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

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

120 days in ITA No.612/RJT/2024,as also 119 days’ delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024, and admit these respective appeals for hearing. 7. For the sake of convenience, the grounds as well as the facts narrated in ITA No.612/RJT/2024, for assessment Year 2018-19, have been taken into consideration for deciding the above appeals

SHRI JAWAHIR RAVICHANDRA MEHTA,DUBAI(UAE) vs. THE DCIT, CIRCLE-2, RAJKOT, RAJKOT

In the result appeal of the assessee vide ITA/81/Rjt/2020 stands dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Amarjit Singh, Accountant Memebr

120, 121/Rjt/ 2020 and 01, 02/Rjt/2021 for A.Y. 2006-07 and A.Y. 2007-08 the said bank account belongs to assessee and therefore any income arising therefore should be taxed in the hands of assessee on substantive basis and not on protective basis. It is also submitted that income offered to tax on which tax has been paid same cannot

DAWN CHEMICALS,RAJKOT vs. ACIT, CIRCLE-2(1), RAJKOT, RAJKOT

The appeal of the assessee is allowed for statistical purpose

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

120/-. 5. That the assessee filed an appeal against the order of the AO before the Ld. CIT(A) dated 21/03/2024. That the Ld. CIT(A) dismissed the appeal with following remarks; “Further, appellant challenged reopening u/s. 148. However, it is seen that AO complied to Hon’ble Supreme Court decision on in the case of: “CASE NO: Appeal (civil

S. S. WHITE TECHNOLOGIES P. LTD., RAJKOT,RAJKOT vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarasstt.Year :2017-18 S.S. White Technologies P.Ltd. Pr.Cit-3 Survey No.2788/3 Vs Ahmedabad. Nr.Krishna Petrol Pump Wadhwan-Ahmedabad-Highway Wadhwan, Surendranagar. Pan : Aahcs 2396 B

120/- has been claimed through a journal entry passed in the books for the following items: Foreign gain on notional entries Rs.3,29,29,838/- Foreign loss on notional entries Rs.3,97.40,959/- Net forex loss on notional entries Rs. 68,11,121/- The foreign exchange loss was an artificial loss created through journal entries in the books of accounts

LILAVANTIBEN GORDHANBHAI PADARIYA,RAJKOT vs. ITO, WARD 1(1)(3), RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 372/Rjt/ 2023 ("नधा"रणवष" / Assessment Year: (2013-14) Lilavantiben Gordhanbhai Padariya Vs. Ito, Wd – 1(1)(3), Rajkot Vrajdham, Shardanagar Main Road, Aayakar Bhavan, Race Course Mabdi Road, Rajkot – 360001 Ring Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acgpp7067E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld.Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 24/06/2025 Date Of Pronouncement : 19/09/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld. Cit(A)”] Vide Order Dated 09.09.2023, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 04.12.2017. 2. Grounds Of The Appeal Raised By The Assessee Are As Follows: 1. The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Upholding Validity Of Assessment U/S 147 By Issue Of Notice U/S 148 Of The Act. 2 The Learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi Erred In Confirming Action Of Assessing Officer In Making Addition Of Rs. 1,11,13,196/- By Way Of Alleged Difference Between Sales As Per Annual Vat Return & Sales As Per Audited Accounts By Failing To Appreciate That The Alleged Difference Was Duly Reconciled & Explained.

120/- Edu. Cess on sales Rs. 1,68,429/- S & H Edu. Cess on sales Rs. 84,054/- Add. Duty on sales Rs. 5,77,063/- Difference between total VAT Return – total sales Rs. 1,11,13,196/- 11. On the contrary, the Ld. Sr. DR for the revenue has relied upon the order

SHRI TULSHIBHAI POLABHAI SAKARIYA,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, appeal filed by assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकरअपीलसं./Ita No. 93/Rjt/2021 िनधा"रणवष" िनधा"रणवष"/Asstt. Year:2015-16 िनधा"रणवष" िनधा"रणवष" Shri Tulsibhai Polabhai Sakariya Vs. The Pr. C.I.T, 2-Bombay Housing Society, Rajkot-1, Meghdhara, University Road, Rajkot. Opp. G. K. Dholakiya, Rajkot

68 of the paper book where the notice under section 142(1) of the Act and reply of assessee along with documentary evidences were placed. Thus, the learned AR contended that the AO after considering the reply of the assessee along with evidences has taken a view, therefore, it cannot be said that the assessment order is erroneous

THE DY. COMMR. OF INCOME TAX, CIRCLE-3(1),, RAJKOT-GUJARAT vs. M/S SAURASHTRA GRAMIN BANK,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royअपील सं./Ita No.376/Rjt/2016 िनधा"रण वष"/Asstt. Year: 2012-2013 D.C.I.T., M/S. Saurashtra Gramin Bank, Circle-3(1), Vs. Gopalnaga, Opp. Andh Mahila Rajkot. Vikas Gruh, Rajkot.

68,516 as provision against NPA in the profit and loss account, which was claimed as deduction in terms of section 36 (1) (vii) of the Act. The Assessing Officer did not allow the deduction claimed as aforesaid on the ground that the provision of NPA was not in the nature of expenditure or loss but more

SHREE MALIYA KADVA PATEL SEVA SAMAJ,,JUNAGADH vs. THE INCOME TAX OFFICER, WARD-1(3),, VERAVAL

Appeal of the assessee is dismissed in above terms

120-125 Ahmedabad Rana Caste Association 140 ITR 01 SC 126 111 ITD 238 RAJKOT Rajkot Visha Shrimali Jain Samaj 1-4 Trib. Shia Dawoodi Bohra Jamat Waqf 64 SOT 173 Kol Trib. 22-27 I.T.A No. 187/Rjt/2016 A.Y. 2011-12 Page No 5 Shree Maliya Kadva Patel Seva Samaj vs. ITO 7. In present case, not only the objects

ADITYA BIRLA GLOBAL TRADING (INDIA) PRIVATE LIMITED,GUJARAT vs. DCIT-ACIT CENT-2 RKT, RAJKOT

In the result, appeal filed by the assessee, in ITA No

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

120 taxmann.com 315 (Gujarat) dated) 17.02.2020, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The head note of the decision is as under: 128- ITA Nos. 284, 353, 225 & 226/RJT/2024 Aditya Birla Global Trading (India) Pvt. Ltd. "Section 9, read with section 195, of the Income-tax Act. 1961 and article

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 , RAJKOT vs. ADITYA BIRLA GLOBAL TRADING(INDIA) PVT.LTD. (SWISS SINGAPORE INDIA PVT. LTD.), GANDHIDHAM

In the result, appeal filed by the assessee, in ITA No

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

120 taxmann.com 315 (Gujarat) dated) 17.02.2020, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The head note of the decision is as under: 128- ITA Nos. 284, 353, 225 & 226/RJT/2024 Aditya Birla Global Trading (India) Pvt. Ltd. "Section 9, read with section 195, of the Income-tax Act. 1961 and article

ADITYA BIRLA GLOBAL TRADING (INDIA) PRIVATE LIMITED,GUJARAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, GANDHIHDAM, GANDHIDHAM, GUJARAT

In the result, appeal filed by the assessee, in ITA No

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

120 taxmann.com 315 (Gujarat) dated) 17.02.2020, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The head note of the decision is as under: 128- ITA Nos. 284, 353, 225 & 226/RJT/2024 Aditya Birla Global Trading (India) Pvt. Ltd. "Section 9, read with section 195, of the Income-tax Act. 1961 and article