SHRI GIRISHKUMAR RAMNIKLAL DOSHI,,SURENDRANAGAR vs. THE INCOME TAX OFFICER, WARD-2,, SURENDRANAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.297/Rjt/2017 ("नधा"रण वष" / Assessment Year: (2011-12) (Hybrid Hearing) Shri Girishkumar Ramniklal Vs. Income Tax Officer Doshi Ward-2, Surendranagar B-601, Retreat, Near Shyamal Cross Road, Satellite, Ahmedabad - 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ablpd2297E (Assessee) (Respondent)

68,77,783/- on account of unexplained investment u/s. 69 of the Income Tax Act. 2. That on the facts and circumstance of the case, the learned assessing officer has grossly erred in making impugned addition under Section

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.

77,759 2.16% 2005-06 90,84,157 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

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

77,320/- after making addition of Rs. 9,15,56,045/- being unexplained investment under Section 69 of the Act and Rs. 10 lakhs under Section 68

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

77,320/- after making addition of Rs. 9,15,56,045/- being unexplained investment under Section 69 of the Act and Rs. 10 lakhs under Section 68

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

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

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

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

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

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

section 68 of the Act. The decision taken by the A.O. during the assessment proceedings cannot be regarded as erroneous even on any different ground alleging inadequate verification/inquiries by the A.O. It is clearly evident from the assessment records that the A.O. had carried out independent inquiries by issue of notices u/s 133(6) of the Act and called

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

section 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

SAPPHIRE RECLAIM RUBBER PRIVATE LIMITED,SHAPAR, RAJKOT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX -1, RAJKOT

In the result, appeal filed by the Assessee is rejected

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 272/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Sapphire Reclaim Rubber Pvt. Ltd. Vs. The Principal Commissioner Of Bhoomi Industrial Area, Plot No: Income Tax-1, 2Nd Floor Aayakar Bhawan, Race 1/44, National Highway 27, Veraval (Shapar), Course Ring Road, Rajkot - 360311 Rajkot Gujarat - 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aapcs6205B (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 30/07/2025 Date Of Pronouncement : 28/10/2025

77 taxmann.com 78 (SC) Section 68, read with section 263, of the Income-tax Act, 1961- Cash credit

DY. COMMR. OF INCOME TAX, MORBI CIRCLE,, MORBI vs. M/S QUTONE CERAMIC P. LTD., MORBI

In the result, appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2013-14

68 of the Income Tax Act, 1961 in respect of unsecured loan received from M/s. Pankaj Piyush Trade & Investment Limited amounting to Rs.50,00,000/- and unsecured loan accepted and later on issued shares against the same loan of M/s. Oswal Services Pvt. Ltd. amounting to Rs.2,00,00,000/-. In response to the notice under Section

M/S. SARJU VITRIFIED PVT. LTD.,MORBI-363641 vs. THE PR. CIT-1, RAJKOT, RAJKOT

section 68 of the Act. Thus, it is not a case of lack of inquiry as assumed by the ld. PCIT. There is a clear difference between ‘lack of inquiry' and 'inadequate inquiry'. The ld. PCIT cannot revise the assessment order u/s. 263 merely because he has a different opinion regarding the extent of inquiries than that is made

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)

77, Hon'ble Apex Court referred to the provisions of TOLA wherein it is categorically observed that: "The test to determine whether Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 will apply to section 151 of the new regime is this if the time limit of three years from the end of an assessment year

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 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

M/S. WINMAX CERAMIC PVT. LTD.,WAKANER vs. THE PR. CIT-3, RAJKOT,, RAJKOT

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

68 of the Act i.e. identity, genuineness and creditworthiness. As such, where there is a factual mistake in the order of the AO, the learned PCIT is empowered to direct the AO to conduct the necessary enquiries. The learned DR Vehemently supported the order of the Ld. PCIT passed under section 263 of the Act. 7. We have heard