M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

68 being unaccounted money\nintroduced in the books of account in the garb of cash sales. It is quite\nevident from the details available on record that the then assessing officer\nfailed to examine this issue and failed to make required addition by\ncarrying out proper investigation in the matter. Therefore, ld.PCIT was of\nthe view that not carrying

SMT. KRUSHNABA PRAVINSINH JADEJA,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CIR.-1(1),, RAJKOT-GUJARAT

76,000/-, out of\nsundry creditors, under section 68 of the Act.\n7. Succinct facts qua ground Nos. 1 and 2 are that

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. SMT. KRUSHNABA P. JADEJA,, RAJKOT-GUJARAT

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

76,000/-, out of sundry creditors, under section 68 of the Act. 7. Succinct facts qua ground Nos. 1 and 2 are that

GRENIC TILES PRIVATE LIMITED,WANKANER-MORBI vs. ASST.COMMISSIONER OF INCOME-TAX CIRCLE 1(1) RKT, RAJKOT

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

section 68 to prove the identity, capacity, and genuineness of the cash\ncredits, as the alleged cash sales and receipts from debtors remained wholly\nunverifiable and most notices u/s 133(6) were either unserved or replied to by the\nassessee itself.\n(3) The Ld. CIT(A) erred in accepting self-generated records such as cash book,\nVAT

ACIT CIRCLE-1(1), RAJKOT, RAJKOT vs. GRENIC TILES PVT LTD, MORBI

The appeal of the assessee is allowed, whereas\nappeal of the revenue is dismissed

Section 68 to prove the identity, capacity, and genuineness of the cash\ncredits, as the alleged cash sales and receipts from debtors remained wholly\nunverifiable and most notices u/s 133(6) were either unserved or replied to by the\nassessee itself.\n(3) The Ld. CIT(A) erred in accepting self-generated records such as cash book,\nVAT

M/S. LEOPARD VITRIFIED PVT. LTD.,VILLAGE MATEL, DIST. MORBI vs. THE PR. CIT-1, RAJKOT , RAJKOT

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

Bench: Shri Pramod M. Jagtap & Shri Mahavir Prasad, Judicial Memebr

section 68 of the Act is as under:- "Provided that when the assessee is a company (not being a company in which the public are substantially interest) and the sum so credited consists of share application money, share capital share premium or any such amount by whatever name called, any explanation offered by such assessee- company shall be deemed

CLAYMINE MICRONS LLP,WANKANER vs. PRINCIPAL CIT 1, RAJKOT

In the result, the appeal of the assessee in ITA No

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं. / Ita No. 216/Rjt/2024 Assessment Year: (2018-19) (Physical Hearing) Claymine Microns Llp Vs. Pcit Survey No. 59 At Ratavirda, Nr. Capron Aayakar Bhawan, Race Course Ceramic Sartanpar Road, Wankaner, Ring Road, Rajkot, Gujarat - Gujarat - 363641 360001 Pan/Gir No.: Aamfc4286C (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Hardik Vora, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit. Dr सुनवाई की तारीख/Date Of Hearing : 16/02/2026 घोषणा की तारीख/Date Of Pronouncement : 11/03/2026

76,57,263 as the contribution from its partners. That must result in a situation, where section 68 of the Act can no longer

PARAS RAMESHCHANDRA DOSHI,RAJKOT vs. THE PCIT - 1, RAJKOT , RAJKOT

76 CCH 0869, the High\nCourt of Gujarat has held that: \"As far as law is concerned, the AO has taken a\nparticular view on the basis of evidence produced before him. On the basis of the\nsaid material and materials which were collected by the CIT in revisional\nproceedings, the CIT has taken a different view. However

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

68. In the result, assessee`s, ground no. 4 in IT(SS) No. 8/RJT/2019 for AY 2012-13, is dismissed. Pankajbhai ChimanlalLodhiya v. DCIT IT(SS)A No. 6 to 9 & 46 to 49 & 102/Rjt/2019 AY (2010-11 to 2014-15) 69. The Assessee`s summarized and concise ground no.14 is reproduced below for ready reference: “(14).The Commissioner

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

68. In the result, assessee`s, ground no. 4 in IT(SS) No. 8/RJT/2019 for AY 2012-13, is dismissed. Pankajbhai ChimanlalLodhiya v. DCIT IT(SS)A No. 6 to 9 & 46 to 49 & 102/Rjt/2019 AY (2010-11 to 2014-15) 69. The Assessee`s summarized and concise ground no.14 is reproduced below for ready reference: “(14).The Commissioner

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

68. In the result, assessee`s, ground no. 4 in IT(SS) No. 8/RJT/2019 for AY 2012-13, is dismissed. Pankajbhai ChimanlalLodhiya v. DCIT IT(SS)A No. 6 to 9 & 46 to 49 & 102/Rjt/2019 AY (2010-11 to 2014-15) 69. The Assessee`s summarized and concise ground no.14 is reproduced below for ready reference: “(14).The Commissioner

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. VAIBHAV GINNING SPINNING MILL PVT. LTD., RAJKOT

In the result, the Appeal of the Department is dismissed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपील सं./ Ita No. 826/Rjt/2024 िनधा"रण वष" / Assessment Year: (2017-18) (Physical Hearing) Dcit Vs. Vaibhav Ginning & Spinning Central Circle-2, Rajkot Mill Private Limited “Amruta Estate”, 2Nd Floor, Mg Road, National Highway – 27, Gondal Rajkot-360001 Rajkot Highway At Bhojpara, Gondal, Gujarat - 360311 Pan/Gir No.: Aadcv4397D (Assessee) (Respondent) िनधा"रती की ओर से/Assessee By : Shri Rajendra Singhal, Ar राज" की ओर से/Respondent By : Shri Sanjay Punglia, Cit.Dr सुनवाई की तारीख/Date Of Hearing : 26/02/2026 घोषणा की तारीख/Date Of Pronouncement : 10/04/2026

section 68." 6.14.2 The Hon'ble Mumbai ITAT in case of R. S. Diamonds India (P.) Ltd. Vs. ACIT[2022] 145 taxmann.com 545 held that "Where assessee deposited cash into bank account during demonetization period from cash balance available in account books, no addition u/s 68 can be made." 6.14.3 The Hon'ble Delhi ITAT in the case

AMRUTPUR SEVA SAHKARI MANDALI LTD.,VILLAGE: - AMRUTPUR TALUKA DHARI, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated 08.12.2020 for proposed adjustment under

AMBARADI SEVA SAHKARI MANDALI LTD.,AMBARADI , DIST. AMRELI vs. THE DCIT(CPC), BANGALURU, BENGALURU

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated 08.12.2020 for proposed adjustment under

DHARESHWAR SEVA SAHAKARI MANDALI LTD. ,VILLAGE: - DHARESHWAR, TALUKA: - RAJULA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated 08.12.2020 for proposed adjustment under

SHREE SANALIYA SEVA SAHKARI MANDLI LTD.,LITAL MOTALILIYA SANALIYA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated 08.12.2020 for proposed adjustment under

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