RAKESH BASANTILAL LADDHA,,JAMNAGAR. vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

68,692/- whose fine under section 234E was determined at Rs.12,48,800/- on the basis of number of days calculated by the AO. However, in the case of Rakesh B. Ladha, TCS was Rs.68,656/-. Penalty was restricted equivalent to this amount. Similar exercise was carried out in respect of other assessees. Dissatisfied with this levy of penalty

JAYESHBHAI KANJIBHAI DANGARIYA,,JAMNAGAR. vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

68,692/- whose fine under section 234E was determined at Rs.12,48,800/- on the basis of number of days calculated by the AO. However, in the case of Rakesh B. Ladha, TCS was Rs.68,656/-. Penalty was restricted equivalent to this amount. Similar exercise was carried out in respect of other assessees. Dissatisfied with this levy of penalty

PARAG MAKANBHAI PARSANA,JAMNAGAR vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

68,692/- whose fine under section 234E was determined at Rs.12,48,800/- on the basis of number of days calculated by the AO. However, in the case of Rakesh B. Ladha, TCS was Rs.68,656/-. Penalty was restricted equivalent to this amount. Similar exercise was carried out in respect of other assessees. Dissatisfied with this levy of penalty

VISHAL ENTERPRISE, ,JAMNAGAR vs. INCOME TAX OFFICER, TDS-3,, JAMNAGAR.

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr.

68,692/- whose fine under section 234E was determined at Rs.12,48,800/- on the basis of number of days calculated by the AO. However, in the case of Rakesh B. Ladha, TCS was Rs.68,656/-. Penalty was restricted equivalent to this amount. Similar exercise was carried out in respect of other assessees. Dissatisfied with this levy of penalty

SHRI VAJUBHAI N. KANANI,AMRELI vs. THE ITO, WARD-2(4),, AMRELI

In the result, assessee’s appeal is dismissed

Bench: Smt.Annapurna Gupta & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 29/Rjt/2020 ("नधा"रण वष" / Assessment Year : 2007-08) Shri Vajubhai N. Kanani The I.T.O., बनाम/ Prop. Of M/S. Krishna Ward-2(4), Amreli Vs. Construction, At – Malsika, Tal. Dhari, Amreli "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Afppk0597L .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : Written Submission (None) ""यथ" क" ओर से / Shri B. D. Gupta, Sr.D.R. Respondent By : सुनवाई क" तार"ख / Date Of 05/04/2023 Hearing घोषणा क" तार"ख /Date Of 20/04/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal At The Instance Of The Assessee Is Directed Against The Order Dated 13.01.2020 Passed By The Commissioner Of Income Tax (Appeals)-3, Rajkot, (Hereinafter Referred To As ‘The Cit(A)’) Arising Out Of The Penalty Order Dated 25.04.2013 Passed By The Learned Ito, Ward-2(4), Amreli Under Section 271(1)(C) Of The Income Tax Act, 1961 (Hereinafter Referred As To ‘The Act’) For Assessment Year 2007-08. Ita No. 29/Rjt/2020 (Shri Vajubhai N. Kanani Vs. Ito) A. Y. 2007-08 - 2- 2. None Appeared At The Time Of Call On Behalf Of The Assessee. However, The Ld. Dr Appeared & Made His Submission In Favour Of The Orders Passed By The Authorities Below In Imposing Penalty For Furnishing Inaccurate Particulars Of Income.

68 of the Act to the tune of Rs.24,90,000/-. Penalty proceeding under Section 271(1)(c) of the Act was separately initiated against the assessee for furnishing inaccurate particulars of income. 6. During the course of penalty proceeding, show cause dated 29.12.2009 and 09.11.2012 were issued to the assessee as to why the penalty under Section

MEDI SEVA SAHAKARI MANDALI LTD.,MEDI, DIST. AMRELI vs. THE ADIT (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

154/- under section 80P of the Act. The I.T.A No. 38/Rjt/2022 A.Y. 2019-20 Page No 6 Medi Seva Sahakari Mandali Ltd. vs. ADIT(CPC) issue for consideration before us is that whether once the return of income is filed beyond the prescribed date under section 139(1) of the Act, can the deduction under section

M/S. MAGNUM CERAMICS PVT. LTD. ,MORBI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, MORBI CIRCLE, MORBI

In the result, appeal of assessee is allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2012-13 M/S.Magnum Ceramic P.Ltd. The Acit, Morbi Circle Plot No.207/24, Gidc Estate Vs Morbi. 8-A, National Highway At. Refaleshwar Morbi 362 268 Pan : Aafcm 2216 G

154 of the Act was incorrect. Aggrieved by this order of the ld.CIT(A) the assessee is now before us , raising the above grounds. 4. Vis-à-vis the ground nos.1 & 4, they are general in nature and need no adjudication. Vis-à-vis ground no.2, that the ld.CIT(A) had dismissed the assessee’s appeal ex parte without considering

RAMJU HAROONBHAI KEWAR,GANDHIDHAM vs. INCOME TAX OFFICER WARD 2 GANDHIDHAM, GANDHIDHAM

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

section 154\nof the Income Tax Act, 1961 (in short “the Act\").\n2. Grounds of appeal raised by the assessee are as followed:\n1) The order of the learned CIT(A) u/s. 250 is bad in law and contrary to the facts of\nthe case.\n2) The learned CIT(A) has erred in confirming the addition

DHIRAJLAL GOVINDBHAI PATEL ,RAJKOT vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

The appeal of the assessee is treated as allowed

Bench: Dr. Arjun Lal Saini, Am. & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.299/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Dhirajlal Govindbhai Patel Vs. The Ito, Ward – 1(2)(1), Mayurpankh Industries, K-1/49, Aayakar Bhawan, Race Course Road-D, Phase-I, Aji Gidc, 80Ft Ring Road, Road, Rajkot – 360001 Rajkot – 360003 Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agepp0489N (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 22 /10 /2024 Date Of Pronouncement : 22 /01 /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 08.05.2024, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 154 Of The Income Tax Act, 1961 (In Short “The Act”).

section 154 of the Income Tax Act, 1961 (in short “the Act”). 2. Grounds of appeal raised by the assessee are as followed: ITA No.299/RJT/2024 A.Y. 2020-21 Dhirajbhai Govindlal Patel v. ITO 1) The Learned Commissioner of Income – tax (Appeals), NFAC, Delhi erred in confirming action of CPC in making addition of Rs. 68

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

PARI ANIL GANDHI,RAJKOT vs. INCOME TAX OFFICER, WARD - 2(1)(1), RAJKOT, RAJKOT

In the result, both the assessee’s appeals are allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 896 & 897/Rjt/2024 िनधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Pari Anil Gandhi Vs. Income Tax Officer, Ward-2(1)(1), C-702 Sadguru Vatika, Airport Road, 2- Aayakar Bhavan Race Course Ring Maruti Nagar, Rajkot - 360001 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bahpg7804E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 09 / 10 /2025 Date Of Pronouncement : 05 / 01 /2026 आदेश/Order Per Dinesh Mohan Sinha, Jm; Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year 2013-14, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 22/11/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The I.T. Act, On Dated 28/03/2022. 2. Since, The Issues Involved All These Appeals Are Common & Identical; Therefore, These Appeals Have Been Heard Together & A Consolidated Order Are Being Passed For The Sake Of Convenience, We Shall Take The Lead Case In Ita No.896/Rjt/2024 For Assessment Year 2013-14. Ita No. 896&897/Rjt/2024 Pari Anil Gandhi Rajkot

section 68 of the it Act it is totally wrong. Unwarranted, unjustified and bad in law. 4. The learned commissioner of income tax (appeals), national faceless appeal centre has erred in confirming the action of the assessing officer in respect of initiated the penalty proceedings u/s.271(1)(c) of the it Act it is totally wrong, unwarranted, unjustified

PARI ANIL GANDHI,RAJKOT vs. INCOME TAX OFFICER, WARD - 2(1)(1) RAJKOT, RAJKOT

In the result, both the assessee’s appeals are allowed for statistical purpose

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 896 & 897/Rjt/2024 िनधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Pari Anil Gandhi Vs. Income Tax Officer, Ward-2(1)(1), C-702 Sadguru Vatika, Airport Road, 2- Aayakar Bhavan Race Course Ring Maruti Nagar, Rajkot - 360001 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bahpg7804E (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 09 / 10 /2025 Date Of Pronouncement : 05 / 01 /2026 आदेश/Order Per Dinesh Mohan Sinha, Jm; Captioned Two Appeals Filed By The Assessee, Pertaining To Assessment Year 2013-14, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 22/11/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 147 Read With Section 144B Of The I.T. Act, On Dated 28/03/2022. 2. Since, The Issues Involved All These Appeals Are Common & Identical; Therefore, These Appeals Have Been Heard Together & A Consolidated Order Are Being Passed For The Sake Of Convenience, We Shall Take The Lead Case In Ita No.896/Rjt/2024 For Assessment Year 2013-14. Ita No. 896&897/Rjt/2024 Pari Anil Gandhi Rajkot

section 68 of the it Act it is totally wrong. Unwarranted, unjustified and bad in law. 4. The learned commissioner of income tax (appeals), national faceless appeal centre has erred in confirming the action of the assessing officer in respect of initiated the penalty proceedings u/s.271(1)(c) of the it Act it is totally wrong, unwarranted, unjustified

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-,\nmade on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

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

154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

VITARAG EXPORT INDUSTRIES,JUNAGADH ROAD vs. ITO, WARD - 2(1)(1), RAJKOT, AAYAKAR BHAVAN

In the result, ground No.5 raised by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.354/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2012-13) (Physical Hearing) Vitrang Export Industries, Vs. The Ito, Junagadh Road, Near Railway Ward – 2(1)(1), Crossing, Dhoraji, Gujarat - 360140 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfv2407M (Appellant) (Respondent)

section 154 of the Act, and also requested the Bench to provide sufficient time to get the rectification done. Accordingly, the Bench, vide order sheet entry dated 22.07.2024, had re- fixed the case for hearing on 14.08.2024 and time was given to the ld. DR to get the rectification done on or before 3rd October 2024. Further time