VIJAY ANANDBHAI CHAVDA,GONDAL vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT , RAJKOT

In the result, the order passed by the PCIT u/s 263 of the Act is hereby dismissed

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

68 2. 18,83,64,331/- Unexplained sundry Section not creditors mentioned by the A.O. 3. 6,00,56,842/- 5% of purchase Section not mentioned by the A.O. 4. 1,34,27,150

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. M/S REAL PROCON PVT. LTD.,, RAJKOT-GUJARAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.498/Rjt/2015 िनधा"रण वष"/Asstt. Year: 2012-2013 D.C.I.T., M/S Real Procon Pvt. Ltd., Circle-1(1), Vs. Saneshwar Complex, Rajkot. Opp. Balalji Hall, 150 Ft. Ring Road, Rajkot.

150 ft. Ring Road, Rajkot. PAN: AAECR8684A (Applicant) (Respondent) Revenue by : Shri S.S. Rathi, Sr.D.R Assessee by : Shri Kalpesh Doshi, A.R सुनवाई क" तारीख/Date of Hearing : 22/03/2022 घोषणा क" तारीख /Date of Pronouncement:27/04/2022 आदेश/O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The captioned appeal has been filed at the instance of the Revenue against

THE DCIT, MORBI CIRCLE, , MORBI vs. M/S. CLAYRIS CERAMICS PVT. LTD.,, MORBI

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकरअपीलसं./Ita No. 287/Rjt/2018 With Co No. 28/Rjt/2018 निर्धररवरध/Asstt. Year: 2013-14 D.C.I.T, M/S. Clayris Ceramic Pvt. Ltd., Morbi Circle, Vs. Opp. Soriso Ceramics, Morbi. B.H Fame Ceramics Pvt., 8A-Nh, Morbi.

section 68 of the Act by treating the unsecured loans as unexplained cash credit. 2.2 The facts in brief are that the assessee in the present case, a private limited company, is engaged in the business of manufacturing of tiles. During the ITA no.287/Rjt/2018 with C.O No.28/Rjt/2018 Asstt. Year 2013-14 3 year under consideration, the assessee has shown

FUSION GRANITO PRIVATE LIMITED,MORBI vs. THE PR. COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

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

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.190/Rjt/2023 (िनधा"रण वष" / Assessment Year: (2018-19) (Physical Hearing) Fusion Granito Pvt. Ltd. बनाम/ Principal Commissioner Of Income Revenue Survey No.555/P1/91, Tax-1, Vs. Nr. Khokhra Hanuman Temple, 2Nd Jetpar Road, Morbi-363641 Rajkot, Floor, “Aayakar Bhawan”, Race Course Ring Road, Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcf 0696 B (अपीलाथ"/Appellant) (""थ" /Respondent) अपीलाथ" ओर से/ Appellant By Shri Bandish Soparkar, Ar ""थ" की ओर से/Respondent By Shri Praveen Verma, Cit Dr सुनवाई की तारीख/Date Of Hearing 24/06/2025 घोषणा की तारीख /Date Of Pronouncement 10/09/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax - 1, Rajkot [In Short ‘Ld. Pcit’], Dated 27.03.2023, Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The ‘Act’] For The Assessment Year (Ay) 2018-19. 2. Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: “1. The Revision Order U/S 263 Of The Act Dated 28.03.2023 Is Bad In Law. 2. The Hon’Ble Pr. Cit-1, Rajkot Has Erred In Law As Well As On Facts In Completing The Revision Proceedings U/S 263 Of The Act Hurriedly In Short Span Of Time Fusion Granito Pvt. Ltd.

68 of the Act. We also make it clear that in case of unsecured loan source of the source is not applicable to the assessee under consideration for A.Y. 2018-19. However, we note that assessee could not prove the source of the source about share capital, because assessee was not given adequate opportunity of being heard, during the revision

THE ACIT, CIRCLE-1,, JAMNAGAR vs. M/S. SENOR METALS PVT. LTD., JAMNAGAR

In the results the appeal of the revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Suchitra Raghunath Kambleआयकर अपील सं./Ita No. 260/Rjt/2015 िनधा"रण वष"/Asstt. Year:2011-12

68 087 77 55 982 1 73 60 002 1 93 45 151 (Increase )/Decrease in stock Opening stock By product 1 28 206 2 86 589 Work in process 5 86 46 481 6 63 78 651 Finished goods 1 11 79 254 77 63 967 Total 6 99 53 941 7 44 29 207 Closing stock By product

SHRI MAGANBHAI BACHUBHAI RUPAPARA,SHAPAR (VERAVAL), RAJKOT vs. THE ITO, WARD-1(1)(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

2. The learned CIT(A) erred on facts as also in law in confirming the addition of Rs. 5,07,150/- made by treating agricultural income as unexplained. The addition made u/s. 68 of the Act may kindly be deleted.” 3. The assessee has also taken the following additional Grounds of appeal: “3. Limited Scrutiny Assessment was initiated to verify

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

2,68,090/ ii) Addition under Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition under Section 68 of the Act - Rs.58,65,320/- AY 2012-13 Addition under Section 68 of the Act - Rs.42,57,500/- 3. Against the orders passed by the Assessing Officer

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

2,68,090/ ii) Addition under Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition under Section 68 of the Act - Rs.58,65,320/- AY 2012-13 Addition under Section 68 of the Act - Rs.42,57,500/- 3. Against the orders passed by the Assessing Officer

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

2,68,090/ ii) Addition under Section 68 of the Act - Rs. 31,18,120/ AY 2010-11 Total Rs.33,86,210/- AY 2011-12 Addition under Section 68 of the Act - Rs.58,65,320/- AY 2012-13 Addition under Section 68 of the Act - Rs.42,57,500/- 3. Against the orders passed by the Assessing Officer

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

2) The glaring examples of huge investment when compared to meager income returned as mentioned in para-3 of the SCN and as evident from the fact that the investment/loan given to the assessee- company is dis- proportionally high to the income returned, called for verification/ enquiry by the AO. The averment by the assessee that most of the shareholders

FORTUNE DEVELOPERS,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

150 Feet Ward-2(1)(1), Ring Road, Rajkot-360005 Rajkot PAN: AACFF3536A (Applicant) (Respondent) Assessee by : None Revenue by : Shri B. D. Gupta, Sr. DR सुनवाईक"तार"ख/Date of Hearing : 21/12/2022 घोषणाक"तार"ख/Date of Pronouncement: 04/01/2023 आदेश/O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The captioned appeal has been filed at the instance

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

150 taxmann.com 71 (Surat Trib.);\n8.1. Further, Ld. AR of the assessee relied, there is no intimating material\navailable with Ld. Pr. CIT(A) with M/s. National Shroff Company, hence,\nLd. Pr.CIT(A) has no jurisdiction u/s. 263 of the Act. The Ld. AR also relied\non \"Reliance is placed upon the decision of Gujarat High Court in an\nidentical

M\S. LEXICO CERAMICS,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalassessment Year : 2015-15 M/S Lexico Ceramics, C/O Kalpesh S. Doshi & Co., Vs Principal Commissioner Of Chartered Accountants, Income-Tax-1, 1006-09, The Spire-2, Near Sheetal Rajkot Park Brts Stop, 150 Ft. Ring Road, Rajkot-360005 Pan : Aaefl 8870 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Kalpesh Doshi, Ar Revenue By : Shri Shramdeep Sinha, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/04/2023 घोषणा की तारीख /Date Of Pronouncement: 12/05/2023 आदेश/O R D E R Per Waseem Ahmed, Am :

150 Ft. Ring Road, Rajkot-360005 PAN : AAEFL 8870 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Kalpesh Doshi, AR Revenue by : Shri Shramdeep Sinha, CIT-DR सुनवाई की तारीख/Date of Hearing : 19/04/2023 घोषणा की तारीख /Date of Pronouncement: 12/05/2023 आदेश/O R D E R PER WASEEM AHMED, AM : This appeal filed by the assessee is directed against

M/S AMBITIOUS FINANCE & INVESTMENT PVT. LTD.,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-2(4),, RAJKOT-GUJARAT

The appeal of the assessee is dismissed

Bench: Mrs. Annapurna Gupta & Mrs. Madhumita Royिनधा"रणवष"/Assessment Year: 1997-98 M/S. Ambitious Finance & Vs. Income Tax Officer, Investment Pvt. Ltd., Ward- 2(4), 107, Kapad Market, Para Bazar, Rajkot Rajkot Pan : Aabca 8076 C अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Written Submission Revenue By : Shri V.J. Boricha, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 14.12.2022 घोषणा क" तारीख /Date Of Pronouncement: 06.03.2023 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta:

Section 144 of the I.T. Act on the best judgment and on the basis of material available with Department and inquiries conducted in this regard to establish interconnection between the deposits made by the depositors and introduction of the same into the books of accounts of the assessee. 6. The assessee is doing finance business. During

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

2) of the Act issued. Further, notice under section 142(1) of the Act has been issued confronting various incriminating documents impounded during the Income-tax Survey and seeking assessee's response on the same. Issue Involved: 5. The brief facts of the case are that a survey u/s 133A of the Act at the premises of the assessee

THE DEPUTY COMMR. OF INCOME TAX, CEN. CIR.1,, RAJKOT vs. JAYESH HARAKHJI PATEL,, RAJKOT

In the result, all appeals filed by the different assessee's and Revenue\nare allowed for statistical purposes

68 is being proposed because the\nassessee has been maintaining books of accounts in one form or another. Alternatively,\nassessee can be considered owner of cash-deposited in bank-accounts owned by the\nassessee under Sec. 69A, even under general provisions of taxation, as per relied upon\nauthorities, supra.\n13. Notice of hearing of this appeal was sent

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

150 crores in addition to the deposits of the directors, shareholders\nand relatives in the companies. A chart showing year-wise exposure of debt was\nsubmitted before the assessing officer. It was submitted that properties & assets\nmortgaged for taking finance from the bank are all accounted for in the books of\naccount of relevant group concern or in the books

ASHISHKUMAR BHAGVANJIBHAI KANSAGRA,RAJKOT vs. ACIT CIR - 2(1), RKT, RAJKOT

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

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.409/Rjt/2025 िनधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Ashishkumar Bhagvanjibhai Vs. Acit Kansagara, Circle – 2(1), C-507, Imperial Heights, Rajkot - 360001 150 Feet Ring Road, Rajkot - 360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acspk6893P (Appellant) (Respondent)

150 Feet Ring Road, Rajkot - 360005 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: ACSPK6893P (Appellant) (Respondent) Appellant by : Ms. Alpa V. Makadiya, Ld. AR Respondent by : Shri Abhimanyu Singh Yadav, Ld. Sr. DR Date of Hearing : 02/09/2025 Date of Pronouncement : 23/09/2025 आदेश / O R D E R Captioned appeal filed by the assessee, pertaining to Assessment Year 2016-17, is directed against