OSWAL AGRICOMM PRIVATE LIMITED,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, 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)

153C(1) is invoked for A.Y. 2015-16 to Α.Υ. 2020-21 and 143(3) for A.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case of Vijay Nagda, satisfaction note of the assessee was recorded considering all the facts of the case. Again a satisfaction also recorded in accordance with the provision of the Income

MAHAVIR IMPEX,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, 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)

153C(1) is invoked for A.Y. 2015-16 to Α.Υ. 2020-21 and 143(3) for A.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case of Vijay Nagda, satisfaction note of the assessee was recorded considering all the facts of the case. Again a satisfaction also recorded in accordance with the provision of the Income

NARENDRAKUMAR BHANWERLAL NIMBAVAT HUF,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, 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)

153C(1) is invoked for A.Y. 2015-16 to Α.Υ. 2020-21 and 143(3) for A.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case of Vijay Nagda, satisfaction note of the assessee was recorded considering all the facts of the case. Again a satisfaction also recorded in accordance with the provision of the Income

RISHABH STEEL SUPPLIER,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, 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)

153C(1) is invoked for A.Y. 2015-16 to Α.Υ. 2020-21 and 143(3) for A.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case of Vijay Nagda, satisfaction note of the assessee was recorded considering all the facts of the case. Again a satisfaction also recorded in accordance with the provision of the Income

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)

153C(1) is invoked for A.Y. 2015-16 to Α.Υ. 2020-21 and 143(3) for A.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case of Vijay Nagda, satisfaction note of the assessee was recorded considering all the facts of the case. Again a satisfaction also recorded in accordance with the provision of the Income

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

In the result, appeal filed by the Revenue, in IT(SS) No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआ.(खो और ज).सं./It(Ss)A Nos.11 To 20/Rjt/2022 "नधा"रण वष"/ Assessment Years:2011-12 To 2020-21 बनाम/ Shri Shamjibhai Sadhabhai Deputy Commissioner Of Kangad Income Tax, Central Circle-1, Vs. Bbz-S-60, Zanda Chowk, “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Adepk 3471 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.21 To 23/Rjt/2022 "नधा"रण वष"/ Assessment Years:2014-15, 2016-17 &2017-18 बनाम/ Deputy Commissioner Of Income Shri Shamjibhai Sadhabhai Tax, Central Circle-1, “Amruta Kangad Vs. Estate”, 2Nd Floor, M.G. Road, Bbz-S-60, Zanda Chowk, Rajkot-360001 Gandhidham-370 201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aabca 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.15/Rjt/2023 "नधा"रण वष"/ Assessment Year:2019-20 बनाम/ Deputy Commissioner Of Shri Hetab Shamjibhai Kangad Income Tax, Central Circle-1, Bbz-South-60, Zanda Chowk, Vs. “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aqtpk 7484 M (अपीलाथ"/Assessee) (""यथ"/Respondent)

153C of the Act. But in the instant case, separate search warrant has been issued in the case of the assessee as well in the case of Sh. Ashok Chowdhary and the Assessing Officer has used the material found in the course of search at the premise of Sh. Ashok Chowdhary, which is not permitted in view of the express

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

153C(1) is invoked for A.Y. 2015-16 to A.Y. 2020-21 and 143(3) for\nA.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case\nof Vijay Nagda, satisfaction note of the assessee was recorded considering all\nthe facts of the case. Again a satisfaction also recorded in accordance with the\nprovision of the Income

SHAILESH MAGANLAL RAMANI,RAJKOT vs. INCOME TAX OFFICER WARD -1(2)(5), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.321/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2012-13 Shailesh Maganlal Ramani The Ito, Ward-1(2)(5), बनाम Star Shopping Centre 20 Rajkot New Jagnath, Jugatram, Vs. Raval Marg, Rajkot-360001 Pan : Abupr7272G (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri R. D. Lalchandani & Ms. Monica Patva, Ld. Ars. राज"व क" ओर से/Revenue By : Shri Dheeraj Kumar Gupta, Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 15/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 29/09/2025 Order Per, Dr. Arjun Lal Saini: By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Dated 21-03-2024 Passed By The Learned Commissioner Of Income Tax (Appeals) / National Faceless Appeal Centre, Delhi [In Short ‘Ld. Cit(A)/Nfac’], In The Matter Of Assessment Under Section 143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter Referred As “The Act”) For The Asst. Year 2012-13. Shailesh Maganlal Ramani

section 153C are applicable and order u/s 143(3) could not be passed.” 6. First, we shall adjudicate, ground No. 2 raised by the assessee, along with Form No. 36, which is reproduced below for ready reference: “2. The CIT(A) erred in upholding the addition of Rs. 84,04,625/-. The upholding of the addition is not justified

OSWAL PETROCHEM,GANDHIDHAM vs. DCIT, CC-1, RAJKOT, RAJKOT

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

153C(1) is invoked for A.Y. 2015-16 to A.Y. 2020-21 and 143(3) for\nA.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case\nof Vijay Nagda, satisfaction note of the assessee was recorded considering all\nthe facts of the case. Again a satisfaction also recorded in accordance with the\nprovision of the Income

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

section 132A, then, the provisions of sub-section (1) shall\napply as if such books of account, other documents or assets which had been taken into custody from\nthe person referred to in clause (a) or clause (b) or clause (c), as the case may be, of sub-section (1) of\nsection 132A, had been found

PRIYANSI CORPORATION,DIST RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

153C(1) is invoked for A.Y. 2015-16 to A.Y. 2020-21 and 143(3) for\nA.Y. 2021-22.During the course of assessment proceeding u/s 153A in the case\nof Vijay Nagda, satisfaction note of the assessee was recorded considering all\nthe facts of the case. Again a satisfaction also recorded in accordance with the\nprovision of the Income

OM LAMCOAT PVT LTD,MORBI vs. THE ACIT, CENTRA CIRCLE-1, RAJKOT, RAJKOT

In the result, both appeals filed by the assessee (in ITA Nos

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No. 286 & 287/Rjt/2022 िनधा"रणवष" / Assessment Year: (2016-17 & 2019-20) (Hybrid Hearing) बनाम M/S. Om Lamcoat Pvt. Ltd. The Acit, 8-A, Kandla National Highway, Vs. Central Circle -1, Opp. Dadashri Nagar, At. Morbi – Aayakar Bhavan, Amruta 363642 Estate, M. G. Road, Rajkot – 360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Aabco8163G (अपीलाथ"/Assessee) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. (Dr) सुनवाई क" तार"ख/Date Of Hearing : 16/06/2025 घोषणा क" तार"ख/Date Of Pronouncement : 11/09/2025

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) passed by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax(Appeals) (in short “Ld.CIT(A)”), which in turn arise out of assessment orders passed by the Assessing Officer u/s 153C 143(3) of the Act, dated 09.06.2021. ITA No. 286 & 287/RJT/2025

OM LAMCOAT PVT LTD,MORBI vs. ACIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, both appeals filed by the assessee (in ITA Nos

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No. 286 & 287/Rjt/2022 िनधा"रणवष" / Assessment Year: (2016-17 & 2019-20) (Hybrid Hearing) बनाम M/S. Om Lamcoat Pvt. Ltd. The Acit, 8-A, Kandla National Highway, Vs. Central Circle -1, Opp. Dadashri Nagar, At. Morbi – Aayakar Bhavan, Amruta 363642 Estate, M. G. Road, Rajkot – 360001 "थायीलेखासं/.जीआइआरसं/.Pan No. : Aabco8163G (अपीलाथ"/Assessee) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld. Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. (Dr) सुनवाई क" तार"ख/Date Of Hearing : 16/06/2025 घोषणा क" तार"ख/Date Of Pronouncement : 11/09/2025

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) passed by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax(Appeals) (in short “Ld.CIT(A)”), which in turn arise out of assessment orders passed by the Assessing Officer u/s 153C 143(3) of the Act, dated 09.06.2021. ITA No. 286 & 287/RJT/2025

JAMNADAS PURSHOTAM PATEL,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTER-1, RAJKOT

section 139 of the Act, on\n31.05.2018, showing therein income of Rs.2,48,320/-. The assessee-firm was\nconstituted on 06.07.2016 with the following partners:\n1. M/s Decora Housing LLP – 60%\n2. Shri Arvind Parshottambhai Patel – 5% stake\n3. Shri Chirag Arvind Patel – 5% stake\n4. Shri Ujash Janadas Vachhani – 5% stake\n5. Shri Kaushik Popatlal Rathod – 5% stake

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

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

68\"\n24.\nOur view is further fortified by the judgement of the Hon'ble High Court of\nCalcutta in the case of Kaushalya Dealers (P.) Ltd, [2023] 147 taxmann.com 526\n(Calcutta), wherein, on identical facts, as that of assessee, the revision order passed\nby the ld. PCIT, under section 263 of the Act, was quashed, holding as follows

KIRAN HARUBHAI DANGAR,JUNAGADH vs. ASSESSING OFFICER, RAJKOT

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

153C r.w.s. 153A and section 153B of the Act. (ii). The order of assessment passed u/s 143(3) r.w.s. 147 of the Act and the order u/s 250 of the Act are bad in law as they are passed without Document Identification Number (DIN) mentioning therein and hence they are to be treated as invalid in view of CBDT

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

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

68,000/-). It is to mentioned that this figure not include the amount that has not been received till the date of survey. however, would be received on later date but before the execution of respective conveyance deed. The above impounded Page 6 of 28 ITA Nos. 785 to 787 & 765/Rjt/2024 Six Twenty Realty Pvt. Ltd. documents was shown

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. SIX TWENTY REALTY PRIVATE LIMITED, RAJKOT

68,000/-). It is to mentioned that this figure not include the amount that has\nnot been received till the date of survey. however, would be received on later date\nbut before the execution of respective conveyance deed. The above impounded\ndocuments was shown to Shri Ashutosh Ganatara. From his statement recorded,\nit can be seen that Shri Ashutosh Ganatara

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

68,000/-). It is to mentioned that this figure not include the amount that has\nnot been received till the date of survey. however, would be received on later date\nbut before the execution of respective conveyance deed. The above impounded\ndocuments was shown to Shri Ashutosh Ganatara. From his statement recorded,\nit can be seen that Shri Ashutosh Ganatara