VIREN VALLABHDAS DHAKAN,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -2(1), RAJKOT, RAJKOT

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

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

234b, 234c It Is Totally Wrong, Unwarranted, Unjustified And Bad In Law. 6. Your Applicant Reserves The Right In Addition Or Alteration In The Grounds Of Appeal At The Time Of Hearing.” 3. At the outset, that the appeal filed late by 363 days. The Ld. AR of the assessee has filed an application for condonation of delay, supported

BHARATKUMAR ISHWARBHAI BHATIYA,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.-1,, RAJKOT

section 143(3) read with section 263 of the Act and some of the\nassessment orders were passed by the Assessing Officer under section 153A r.w.s.\n143(3) of the Income Tax Act, 1961 (in short ‘the Act').The main ground of appeal by\nthe department (Revenue) is pertaining to assailing and deletion of 70% of additions

M/S. HINDUSTAN PROJECTS,,RAJKOT vs. THE INCOME TAX OFFICER, WARD- 2 (1) (1), RAJKOT

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

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

68 of the I.T. Act, 1961. 4. The learned Commissioner of Income Tax (Appeals) erred on facts as well as in law by confirming the addition by Rs.12,77,083/- made by the learned Assessing Officer under section 36(1)(iii) of the I.T. Act, 1961. 5. The learned Commissioner of Income Tax (Appeals) erred on facts as well

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

234B and 234C is not justified.\nIn the case of Escorts Ltd. v. CIT [2002] 257 ITR 468, Hon'ble Delhi High Court\nwas concerned with claim of an assessee for grant of refund under section 244 of the\nAct, which was denied to an assessee by the revenue on the ground that the assessee\nhimself was responsible

ANSHOYABEN BHAGVANJIBHAI BHOJANI,MORBI vs. INCOME TAX OFFICER, WARD-1, MORBI, MORBI

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 13/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2017-18) Anshoyaben Bhagvanjibhai Bhojani, Income Tax Officer, Ward 1, Morbi Shreeji Nagar, B/H. Chhatralaya Road, Vs. Income Tax Office, Aayakar Vibhag, B/H New Bus Stand, Morbi, J.K. Chamber, National Highway-8-A, Gujarat 363641 At- Lalpar, Morbi Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brnpb6281R (अपीलाथ"/Appellant) (""यथ"/Respondent)

68 was unjustified. 4. On the facts and circumstances of the case as well as law on the subject, the Ld. CIT(A) has erred in sustaining the addition merely on conjectures and surmises, disregarding the evidentiary value of the documents furnished by the assessee, including lender confirmations and their financial statements. 5. On the facts and circumstances

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

section 124(3)(b) of the I.T. Act, 1961 in terms\nof which jurisdiction of an Assessing Officer cannot be called in question by on\nassessee after expiry of one month from date on which he was served with a notice for\nreopening assessment under section 148 of the I.T Act.\n2. Thee learned

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

section 124(3)(b) of the I.T. Act, 1961 in terms\nof which jurisdiction of an Assessing Officer cannot be called in question by on\nassessee after expiry of one month from date on which he was served with a notice for\nreopening assessment under section 148 of the I.T Act.\n2. Thee learned

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:

234B and 234C. The same needs suitable reduction. 3 M/s. Ambitious Finance & Investment Pvt Ltd Vs. ITO AY : 1997-98 8. Without prejudice, the assessment made is bad in law and deserves annulment. 9. Without prejudice, no adequate, sufficient and reasonable opportunity has been provided while framing assessment. The assessment needs annulment. 10. Without prejudice, no adequate, sufficient and reasonable

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

68 of\nthe I.T. Act, 1961 on account of unexplained credit.\n4 The Ld. CIT(A) has wrongly confirmed applicability of provisions of section\n115BBE of the I.T. Act, 1961.\n5 The Ld. CIT(A) has confirmed levy of interest u/s 234A, 234B

GHANSHYAMBHAI MOHANBHAI PATEL,AT PO UMARDA vs. INCOME TAX OFFICER WARD 4 SURENDRANAGAR, INCOME TAX OFFICE IRISH BUILDING

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

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 382/Rjt/2025 ("नधा"रण वष" / Assessment Year: (N.A.) (Hybrid Hearing) Ghanshyambhai Mohanbhai Patel Income Tax Officer, Ward-4, Surendranagar, Income Tax Near Swaminarayan Mandir, At Umarda, Vs. Office, Irish Building, Opp. Mela Ta.Muli, Dist. Surendranagar-363 510 Medan, Surendranagar-363 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Brjpp 6166 K (Appellant) (Respondent)

Sections 234A and 234B may be recomputed based on th revised income. • Relief may kindly be granted in the interest of equity, justice, and fair play. • Set aside the appellate order dated 17/12/2024 passed by CIT(A), Ahmedabad-7. • Delete the additions made u/s 69A and u/s 44AD amounting to ?10,87,340/-. • Restore the matter

TRICOT IMPEX PVT. LTD.,,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, RAJKOT

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

Bench: Hearing Of Appeal.”

68 amounting to Rs.10,80,342/-. 4. The learned Commissioner of Income Tax (Appeals ) erred on facts as well as in law in confirming the charging of interest u/s. 234A 234B, and 234C of the Act, when addition itself not sustainable. Your Honour's appellant craves leave to add, amend, alter or withdraw any one or more grounds of appeal

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

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

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

SHRI RAHIM UMARBHAI RAVKARDA,RAJKOT vs. THE ACIT, CIRCLE-3(1),, RAJKOT

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

68 of the I.T. Act. 3. That, the Ld. CIT(A) has wrongly confirmed initiation of penalty proceedings u/s 274 r.w.s. 271(1)(c) of the I.T. Act, 1961. 4. That, the Ld. CIT(A) has wrongly confirmed levy of interest u/s 234A, 234B and 234C of the I.T. Act, 1961. 5. That, the findings

AKSHAR JEWELLERS,JUNAGADH vs. DEPUTY / ASSISTANT COMMISSIONER OF INCOME TAX, RAJKOT

In the result, appeal filed by the assessee is allowed

68,10,310/- on estimation basis.\n4.That, the Ld. CIT(A) has wrongly confirmed initiation of penalty proceedings\nu/s 270A of the I.T. Act, 1961.\n5.That, the Ld. CIT(A) has wrongly charged interest u/s 234B and 234C of the I.T.\nAct, 1961.\n6.That, the findings of the Ld. CIT(A) are not justified and are bad-in-law.\n7.The

URVASHI GIRISHBHAI LAL,RAJKOT vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini

68 of the I.T. Act, 1961. 3. That, the Ld. CIT(A) has wrongly confirmed interest u/s 234A, 234B, 234C and 234D of the I.T. Act, 1961. 4. That, the Ld. CIT(A) has wrongly confirmed initiation of penalty proceedings u/s 271(1)(c) of the I.T. Act, 1961. 5. That, the findings

KISHAN BEEJ,JAMNAGAR vs. ITO WARD 2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.384/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Kishan Beej Ito, Wared-2(1) बनाम Kashivishvanath Road Jamnagar – 361 001 Nr. P & T Office Vs. Jamnagar – 361 001 Pan : Aacfk 2114 P (अपीलाथ"/Appellant) (""यथ"/Respondent) :

234B and 234C of the I.T. Act, 1961. 6.That, the Ld. CIT(A) has wrongly confirmed initiation of penalty u/s 271AAC and 272(A)(1)(d) of the Act,1961. 7.The assessee craves leave to add, amend, alter, or withdraw any aforesaid grounds of appeal. 3. The facts of the case which can be stated quite shortly are as follows

SHRI MANOJ DHANJIBHAI PANSURIYA,RAJKOT vs. THE NFAC, DELHI, DELHI

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

Bench: Hri Waseem Ahmed & Shri Siddhartha Nautiyal

234B, 234C and 234D of the I.T. Act, 1961. 8. That, the findings of the Ld. AO and Ld. CIT(A) are not justified and are bad-in-law. 9. The appellant craves to add, amend, alter or delete any of the above grounds of appeal.” 3. The brief facts of the case are that the assessee is an individual