SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 62/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2018-19) Kamlesh Deoraj Jain Income Tax Officer, Ward-1, Plot No 35-36, Devashish Gandhidham, Income Tax Vs. Sector-5 Gandhidham 370201 Office, Plot No.32, Sector No.3, Near Iffco Colony, Gandhidham-370 201 "ायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (अपीलाथ"/Appellant) (""थ"/Respondent)

section 250 of the Income Tax Act, 1961 (in short ‘the Act’) dated 14.11.2024, which in turn arises out of an order passed by the Assessing Officer, dated 25.03.2023, u/s 147 r.w.s. 144B of the Act. 2. Grounds of appeal raised by the assessee are as follows: Kamlesh Deoraj Jain 1. The Learned CIT (A) gravely erred

KALPESH RAVJIBHAI SOJITRA,JASDAN vs. THE INCOME TAX OFFICER, WARD 2(1)(2), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha(Hybrid Hearing) Kalpesh Ravjibhai Sojitra, Vs. The Ito, Prop. Sojitra Petrolium, Bypass Ward-2(1)(2), Circle Atkot Road, Jasdan, Rajkot 360050, Rajkot-( Guj) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bqmps8120G (/Appellant) (/Respondent)

68 amounting to Rs. 90,39,290/- is duly justified, owing to the failure of the assessee to explain the nature and source of cash deposits; no violation of principles of natural justice has been established and no supporting documentary evidence has been submitted either at assessment, therefore findings of the assessing officer, was confirmed by the learned

SOLO STEEL TECH,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is dismissed

sections": [ "263", "147", "144B", "69A", "115BBE", "68", "69", "69A", "69D" ], "issues": "Whether the assessment order passed under section

SAMEER SHAH (HUF),1 "SWAPNEEL" ,OPP. GURUDATATREY TEMPLE PALACE ROAD vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.248/Rjt/2025 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Sameer Shah (Huf), Vs. The Ito Ward 1(3), 1 “Swapneel”, Opp. Jamnagar - 361001 Gurudatatrey Temple, Palace Road, Jamnagar - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawhs3749E (Appellant) (Respondent)

144B of the Income Tax Act, 1961. Sameer Shah HUF, 2. Grievances raised by the assessee, which, being interconnected, will be taken up together, are as follows: 1. The order passed by the Ld. FAO as well as order passed by National Faceless Appeal Centre under Section 250 is bad in law as well as on facts

LUNAR CERAMICS,WANKANER vs. PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed for statistical purposes

sections": [ "147", "144B", "263", "133(6)", "131", "142(1)", "68" ], "issues": "Whether the PCIT was justified in invoking section

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

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 of the Act. 3. Facts

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

144B of the Income- tax Act, 1961, on 01/04/2021, accepting returned income of Rs. 40,510/-. 3. Later on, Learned Principal Commissioner of Income-tax (in short “Ld PCIT”), has exercised his jurisdiction under section 263 of the Income-tax Act, 1961. On perusal of case records, it was observed by ld PCIT that the assessee firm had introduced

SHITALBEN JYOTIKUMAR RAYCHURA,PORBANDAR vs. ITO, PORBANDAR

In the result, the appeal of the assessee is allowed for statistical purposes

sections": [ "147", "144", "144B", "69A", "68" ], "issues": "The appeal was filed late by 360 days due to non-communication

PARAS RAMESHCHANDRA DOSHI,RAJKOT vs. THE PCIT - 1, RAJKOT , RAJKOT

144B of\nthe Income Tax Act.\"\n8. The Ld. AR of the assessee submitted that, in view of this avery issue has\nbeen examined by the Assessing Officer. Hence the action u/s. 263 is\nunwarranted, since, there is no question of lack of inquiry/ no adequate\ninquiry by the Assessing Officer. The Ld. AR further relied on the under-\nmentioned

KUNJAN JAGDISHCHANDRA SEDANI,JAMANGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.197/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Kunjan Jagdishchandra Sedani Principal Commissioner Of Vs. 18B, Parikunj, Mahavir Society, Income Tax, Jamnagar Room No. 101, 1St Floor Aayakar Bedi Bunder Road, Jamnagar- 361008 Bhavan, Nr. Subhash Bridge, Jamnagar-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Erips2050H (Assessee) (Respondent) Assessee By : Shri Dushyant Maharshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 23/06/2025 Date Of Pronouncement : 25/08/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 21.02.2025 Passed By The Learned Principal Commissioner Of Income-Tax (In Short “Ld Pcit”), Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As 'The Act'), For The Assessment Year 2015- 16.Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: 1. Hon'Ble Pr. Cit, Jamnagar Has Erred In Law & In Facts In Setting-Aside The Order Passed By The Assessing Officer Under Section 147 R W.S. 144B Of The Income-Tax Act, 1961 By Invoking The Provisions Of Section 263 Of The Income-Tax Act, 1961 Even When The Order As Passed By The Assessing Officer Was Neither Erroneous Nor Prejudicial To The Interests Of The Revenue. 2. Hon'Ble Pr. Cit, Jamnagar Erred In Law & In Facts By Setting-Aside The Order Passed By The Assessing Officer Under Section 147 R.W.S. 144B Of The Income-Tax Act, Kunjan Jagdishchandra Sedani

section 68 of the Act, assessee is not required to explain source of source for unsecured loan accepted. 4. Hon'ble Pr. CIT, Jamnagar erred in doubting the genuineness of the loan transaction amounting to Rs. 45,00,000/-without considering the fact that all the loans have been repaid during the subsequent year. Assessee submits that where

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)

section 263 of the Act, 1961, Therefore, I intend to revise the order passed by the AO u/s 147 rws 1448 of the Act dated 30/03/2022 for the AY 2013-14. 8. Under the circumstances, you are requested to show cause as to why the order u/s 147 rws 144B of the Act dated 30/03/22

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

144B of the Act. Accordingly, we accept the contention of the Assessee that in the facts and circumstances of the present case the doctrine of merger would apply. Therefore, we reject the contention of the Revenue that the CIT(A) erred in entertaining and adjudicating the grounds raised by the Assessee in appeal before the CIT(A) challenging the adjustments

DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. VASANTBHAI MULJIBHAI KANANI, JAMNAGAR

In the result, appeal filed by the revenue is dismissed, whereas appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Dy. Cit, Cir-1 Vasantbhai Muljibhai Kanani बनाम Jamnagar. Plot No.7, Ambica Enterprise Vs. Sardar Patel Ind. Estte-4 Indira Road Opp: Jakat Naka, Jamnagar-361004 (Guj) Pan : Aitpk 8038 P आयकर अपील सं /.Ita No.08/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Vasantbhai Muljibhai Kanani Dy. Cit, Cir-1 बनाम Plot No.7, Ambica Enterprise Jamnagar. Sardar Patel Ind. Estte-4 Vs. Indira Road Opp: Jakat Naka, Jamnagar- 361004 (Guj) Pan : Aitpk 8038 P (अपीलाथ"/Assessee) : (""यथ"/Respondent)

144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'), vide order dated 26.03.2024. 2. The grounds of appeals raised by the Revenue are follows: “1. The Ld. CIT(A) has erred on the facts and in law in deleting the addition of Rs.3,47,91,594/-, made by the assessing officer resorting to the provisions

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) :

144B of the Act. 2. The Grounds of appeal, raised by the assessee, are as follows: Kataria Snack Pellets Pvt. Ltd. ITA No.468 /RJT/2024 (AY : 2015-16) 2 1.The Ld. CIT(A) erred in confirming reopening of assessment u/s 147 of the Act, as valid. 2.The Ld. CIT(A) erred in confirming addition of Rs. 3,99,20,000/- made

CHAMPABEN NARESH LIMBANI,VILLAGE NANI KHAKHAR, TAL. MANDAVI, DIST. KUTCHH vs. THE ITO WARD-3, GANDHIDHAM(BHUJ-1), GANDHIDHAM

In the result, the appeal of the assessee is allowed for statistical purposes

sections": ["147", "144B", "148A(d)", "148B", "68", "115BBE", "234A", "234B", "234C", "271(1)(c)", "271F"], "issues": "Whether the CIT(A) erred

SUNIL KUMAR,GANDHIDHAM vs. INCOME TAX OFFICER WARD-2, GANDHIDHAM

In the result, the appeal of the assessee is allowed for statistical\npurposes

sections": [ "147", "148", "142(1)", "133(6)", "68", "271(1)(c)", "144", "144B" ], "issues": "Whether the assessee was properly

ACTIONWARE INDIA PRIVATE LIMITED ,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.317/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Actionware India Pvt. Ltd. The Pr.Cit-1 बनाम 316, Sagar Arcade Rajkot. Gandal Road Vs. Opp: Union Bank Of India Rajkot 360 002 (Gujarat) Pan : Aacck 3445 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

144B of the Income-tax Act, 1961, on 30/03/2022, accepting returned income of Rs.96,67,640/-. 4. Later on, Learned Principal Commissioner of Income-tax (in short “Ld PCIT”), exercised his jurisdiction, under section 263 of the Income-tax Act, 1961. On perusal of record, it was noticed by ld PCIT that during the course of search action carried

SHRI VISHAL MEHTA ,RAJKOT vs. THE ITO WARD-2(1) (2) RAJKOT, RAJKOT

Appeals of the assessee are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपीलसं/.Ita No.74 To 77/Rjt/2024 "नधा"रण वष"/ Assessment Years: (2012-13 To 2015-2016) Vishal Mehta Income Tax Officer, बनाम Pravin Chamber, 1St Floor, Ward-2(1)(2), Rajkot Kothariya Naka Soni Bazar, Vs. Rajkot-360 001 Pan/Gir No.Ahtpm 7247 B "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ar & Shri Brijesh Parekh, Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr & Shri Abhimanyhu Singh, Sr-Dr

144B and u/s 271B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. Since in these four appeals, filed by the assessee, the identical and similar issues are involved, hence, all these appeals are clubbed and ITA Nos.74-77/Rjt/2024 (AYs-12-13 to 15-16) Vishal Mehta 2 heard together and a consolidated order is being passed