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

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

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

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

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

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 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

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

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

154(3) of the Act.\n3. The facts of the case which can be stated quite shortly are as follows: The\nassessee e-filed its return of income for assessment year (A.Y.) 2020-21 on\n28.01.2021, declaring total income Rs.58,44,15,970/-, which was processed u/s\n143(1) of the Income Tax Act, 1961 by the CPC, Bengaluru

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

154(3) of the Act. 3. The facts of the case which can be stated quite shortly are as follows: The assessee e-filed its return of income for assessment year (A.Y.) 2020-21 on 28.01.2021, declaring total income Rs.58,44,15,970/-, which was processed u/s 143(1) of the Income Tax Act, 1961 by the CPC, Bengaluru

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

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

154 (Gujarat) dated 09.10.2018, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The findings of the Hon'ble Court is reproduced below: "Section 9, read with sections 195 and 40(a)(i), of the Income-tax Act 1961 and article 7 of the OECD Model Convention Income Deemed to accrue

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

154 (Gujarat) dated 09.10.2018, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The findings of the Hon'ble Court is reproduced below: "Section 9, read with sections 195 and 40(a)(i), of the Income-tax Act 1961 and article 7 of the OECD Model Convention Income Deemed to accrue

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

154 (Gujarat) dated 09.10.2018, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The findings of the Hon'ble Court is reproduced below: "Section 9, read with sections 195 and 40(a)(i), of the Income-tax Act 1961 and article 7 of the OECD Model Convention Income Deemed to accrue

DCIT, 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

154 (Gujarat) dated 09.10.2018, wherein the Hon'ble High Court has decided the appeal in favour of the assessee. The findings of the Hon'ble Court is reproduced below: "Section 9, read with sections 195 and 40(a)(i), of the Income-tax Act 1961 and article 7 of the OECD Model Convention Income Deemed to accrue

M/S. DHARTI ESTATE,JUNAGADH vs. THE PR.CIT-3, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

68, 69, 69A, 69B, 69C and 69D, provisions of section 115BBE were not attracted. The ITAT Jaipur in the case of Hari NarainGattani [2021] 123 taxmann.com 8 (Jaipur - Trib.) held that where assessee surrenders undisclosed income during search action for relevant year, it is not necessary that tax rate has to be charged as per provision of section

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