THE DY. COMMR. OF INCOME TAX, CIR.-2,, JAMNAGAR vs. SHRI RASIKLAL KHIMJI MODI,, PORBANDAR

In the result, the aforesaid issues are to restored to the file of Ld

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

27,323/- under Section 68 of the Act on account of unsecured loans. We observe that while granting relief

SMT. CHANDRIKABEN NARANBHAI BHORANIA,MORBI vs. ITO, WARD-1 , MORBI

In the result, the appeal of the assessee is allowed

27-02-2020 Date of pronouncement : 02-06-2020 आदेश/ORDER PER BENCH:- This assessee’s appeal for A.Y. 2015-16, arises from order of the CIT(A)-2, Rajkot dated 17-07-2019, in proceedings under section 143(3) of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has raised following ground of appeal

THE ACIT, CIRCLE- 1,, RAJKOT-GUJARAT vs. SMT. MANISHABEN N. MASHRU,, RAJKOT-GUJARAT

In the result, appeal of the Revenue in ITA No

Bench: Shri Pramod Kumar & Shri Rajpal Yadavsr.No.

27,91,555 61 ,469 0.68% Total 23,93,86,067 10,99,87,129 40,98,852 1.05% 13. At this stage, we would like to make a reference to section 68

THE DEPUTY COMMR. INCOME TAX, CIRCLE-1(2),, RAJKOT vs. M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

section 68 of the Act. In view of the above, we do not find any infirmity in the order of Ld. CIT (A). 23.8 Once the addition made by the AO has been treated by us, holding the loan transaction and share application transaction between the assessee and M/s RNG Finlease Pvt. Ltd, as genuine, the corresponding addition made

M/S RADHE RENEWABLE ENERGY DEVELOPMENT PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSTT. COMMR. INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

section 68 of the Act. In view of the above, we do not find any infirmity in the order of Ld. CIT (A). 23.8 Once the addition made by the AO has been treated by us, holding the loan transaction and share application transaction between the assessee and M/s RNG Finlease Pvt. Ltd, as genuine, the corresponding addition made

THE DY. COMMR. OF INCOME TAX, CIRCLE-1(1),, RAJKOT-GUJARAT vs. M/S. RADHE RENEWABLE ENERGY DEVELOPEMENT PVT. LTD.,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

section 68 of the Act. In view of the above, we do not find any infirmity in the order of Ld. CIT (A). 23.8 Once the addition made by the AO has been treated by us, holding the loan transaction and share application transaction between the assessee and M/s RNG Finlease Pvt. Ltd, as genuine, the corresponding addition made

RADHE RENEWABLE ENERGY DEVELOPMENT PVT LTD,RAJKOT vs. THE PCIT, RAJKOT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

section 68 of the Act. In view of the above, we do not find any infirmity in the order of Ld. CIT (A). 23.8 Once the addition made by the AO has been treated by us, holding the loan transaction and share application transaction between the assessee and M/s RNG Finlease Pvt. Ltd, as genuine, the corresponding addition made

SHRI KISHOR GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

27-10-2016 for AYs 2007-08, 2010-11 & 2011-12) towards penalty under different sections of the Act. ITA Nos.174/Rjt/2014 and 26 appeals Shri Dineshbhhai G.Jakasania vs. DCIT and 3 Other Groups AYs – 2005-06 to 2008-09 & 2010-11 & 2011-12 Assessee’s four appeals (in the case of Shri Ghanshyam Gordhanbhai Jakasania) in ITA Nos.13

SHRI GHANSHYAMBHAI GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

27-10-2016 for AYs 2007-08, 2010-11 & 2011-12) towards penalty under different sections of the Act. ITA Nos.174/Rjt/2014 and 26 appeals Shri Dineshbhhai G.Jakasania vs. DCIT and 3 Other Groups AYs – 2005-06 to 2008-09 & 2010-11 & 2011-12 Assessee’s four appeals (in the case of Shri Ghanshyam Gordhanbhai Jakasania) in ITA Nos.13

SHRI SANJAYBHAI GORDHANBHAI JAKSANIA,,RAJKOT-GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2 ,, RAJKOT-GUJARAT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

27-10-2016 for AYs 2007-08, 2010-11 & 2011-12) towards penalty under different sections of the Act. ITA Nos.174/Rjt/2014 and 26 appeals Shri Dineshbhhai G.Jakasania vs. DCIT and 3 Other Groups AYs – 2005-06 to 2008-09 & 2010-11 & 2011-12 Assessee’s four appeals (in the case of Shri Ghanshyam Gordhanbhai Jakasania) in ITA Nos.13

SHRI VINODKUMAR HIRALAL RAJA,,RAJKOT vs. THE INCOME TAX OFFICER, INTL. TAXN., RAJKOT

In the result, Ground No. 1 of the assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

68 of the Act, being unexplained cash credits. 4. Before the CIT(A), the assessee submitted that the assessee is a non- resident as defined under Section 2(30) of the Act and the “non-resident” status of the assessee has not been disputed by the Assessing Officer. Further, the assessee submitted that the entire funds had come from

SMT. PRATIMABEN V. RAJA,,RAJKOT vs. THE INCOME TAX OFFICER, INTL. TAXN., RAJKOT

In the result, Ground No. 1 of the assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

68 of the Act, being unexplained cash credits. 4. Before the CIT(A), the assessee submitted that the assessee is a non- resident as defined under Section 2(30) of the Act and the “non-resident” status of the assessee has not been disputed by the Assessing Officer. Further, the assessee submitted that the entire funds had come from

M/S AJAY SALT & CHEMICALS,,UNA vs. I.T.O., WARD-1(3),, VERAVAL

In the result, the appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No.296/Rjt/2017 "नधा"रण वष"/Asstt. Year: 2006-2007

section 274 r.w.s. 271(1)(c) of the Act. But the assessee again failed to submit or furnished any reply before the AO. Therefore the AO in absence of any reply or submission held that the assessee has furnished inaccurate particular of income and imposed penalty of Rs. 1,61,568/- being 100% of tax sought to be evaded

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 to the capital receipts prior to the commencement of income generating activities. 4. The Hon’ble Pr.CIT-1, Rajkot has erred in law as well as on facts in not considering the submissions of the appellant in true perspective on the strength of which the assessment order was neither erroneous nor prejudicial to the interest

SHRI JAYANTILAL RUDABHAI BHALANI,JAMNAGAR vs. THE ITO, WARD-1(3), JAMNAGAR

In the result, appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarassessment Year : 2009-10 Jayantilal Rudabhai Bhalani Ito, Ward-1(3) Bilnath Krupa Vs Jamnagar. Opp: Khodiyar Colony Air Force Road, Nilkamal Colony Jamanagar 361 008. (Applicant) (Responent) : Shri Mehul Ranpura, Ar Assessee By Revenue By : Shri S.S. Rathi, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 31/03/2022 घोषणा क" तार"ख /Date Of Pronouncement: 03/06/2022 आदेश/O R D E R

68 of the Act. 5. Aggrieved, the assessee filed appeal before the ld.CIT(A). Before the ld.CIT(A) assessee filed a detailed submissions, which appellate authority has reproduced from page no.4 to 9 of the impugned order. Crux of the submissions made by the assessee before the ld.CIT(A) can be summarized as follows: i) The assessee is mainly engaged

SAMEER SHAH (HUF),1 "SWAPNEEL" ,OPP. GURUDATATREY TEMPLE PALACE ROAD vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.248/Rjt/2025 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Sameer Shah (Huf), Vs. The Ito Ward 1(3), 1 “Swapneel”, Opp. Jamnagar - 361001 Gurudatatrey Temple, Palace Road, Jamnagar - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawhs3749E (Appellant) (Respondent)

section 68. Shares of companies were purchased online, payments were made through banking channels, and shares were dematerialized. Additionally, the shares were transferred from the dematerialized account and received consideration through legitimate banking channels. The assessing officer did not have any independent source or evidence to show an agreement between the assessee and any other party to convert unaccounted

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

68,1867-relevant to the year under consideration in their presence and his three sons had confirmed the contents of that statement recorded u/s 132(4) of the Act. The appellant had also failed to file the affidavits of the two independent witnesses in whose presence the whole search and seizure proceedings were conducted. In view of the above discussion

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

68,1867-relevant to the year under consideration in their presence and his three sons had confirmed the contents of that statement recorded u/s 132(4) of the Act. The appellant had also failed to file the affidavits of the two independent witnesses in whose presence the whole search and seizure proceedings were conducted. In view of the above discussion