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.

68 of the Act. The assessee has pointed out to the ld.CIT(A) that the AO has erred in assuming narrations mentioned in these papers as representing cash credit. Remand report was called for by the ld.CIT(A) and ultimately, it was held by the ld.CIT(A) that rough entries having value of Rs.38,77,759/- could not reconciled

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

section 68 of the Act."” 23. However, the Assessing Officer, rejected the above contention of the assessee and observed that assessee has failed to prove identity, ITA Nos.572&577/RJT/2015/AY.2012-13 Krushnaba Pravinsinh Jadeja genuineness and creditworthiness of the transactions, therefore, made addition of Rs. 83,00,000/- u/s. 68 of the Act. 24. On appeal, by the assessee

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.572/Rjt/2015 (निर्धारण वर्ष / Assessment Year: 2012-13) Krushnaba Pravinsinh Jadeja Vs. Deputy Commissioner Of Income Tax, Circle-1(1), Rajkot, Aaykar Bhavan, Race Course Ring Road, Rajkot-360 001 C.O. R.K. Shukla & Co., 201, 2Nd Floor, Opera Tower, Jawahar Road, Rajkot-360 001 (Assessee) (Respondent) आयकर अपील सं./Ita No.577/Rjt/2015 (निर्धारण वर्ष / Assessment Year: 2012-13) Deputy Commissioner Of Income Tax, Circle-1(1), Rajkot, Aaykar Bhavan, Race Vs. Krushnaba Pravinsinh Jadeja, C.O. R.K. Shukla & Co., Course Ring Road, Rajkot-360 001 201, 2Nd Floor, Opera Tower, Jawahar Road, Rajkot-360001 (Assessee) (Respondent) Assessee By Respondent By Date Of Hearing Date Of Pronouncement : Shri D.M. Rindani, Ld. Ar : Shri Sanjay Punglia, Ld. Cit-Dr : 03/06/2025 : 30/07/2025 Per, Dr. A. L. Saini, Am: आदेश / Order Captioned Cross Appeals Filed By The Assessee & Revenue, Pertaining To Assessment Year (A.Y.) 2012-13, Are Directed Against The Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1 Rajkot, Which In Turn Arise, Out Of A Common Assessment Order, Passed By The Assessing Officer, Under Section 143(3) Of The Income Tax Act, 1961, Vide Order Dated 17.02.2015.

section 68 of the Act." However, the Assessing Officer, rejected the above contention of the assessee and observed that assessee has failed to prove identity, Page | 14 ITA Nos.572&577/RJT/2015/AY.2012-13 Krushnaba Pravinsinh Jadeja genuineness and creditworthiness of the transactions, therefore, made addition of Rs. 83,00,000/- u/s. 68 of the Act. 24. On appeal, by the assessee

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

section 68, 69, 69A to 69D of the IT Act and as such, in the light of non- disputed fact that unexplained credit whether found in the bank statement of the assessee, who regularly maintain books of accounts. Ld. ITAT should have agreed to legal- plea of the Revenue that till onus with respect to identity, credit worthiness

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

section 68, 69, 69A to 69D of the IT Act and as such, in the light of non- disputed fact that unexplained credit whether found in the bank statement of the assessee, who regularly maintain books of accounts. Ld. ITAT should have agreed to legal- plea of the Revenue that till onus with respect to identity, credit worthiness

M/S. EMBOZA GRANITO PVT. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

In the result, appeal filed by assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 240/Rjt/2019 िनधा"रण वष"/Asstt. Years: 2016-2017

section 68 for domestic companies with regard to source of source we have enclosed Personal balance sheets of all possible shareholders, while proofs relating to identity genuineness and creditworthiness are as per Annexure-1 1 During the year under consideration Share capital of A sheet showing the Rs.18,50,00,000/- has been introduced. You have acceptance, conversion

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. BUILDCON CREATIONS LLP, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT vs. BUILDCON CREATIONS LLP, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. BUILDCON CREATIONS LLP, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

BUILDCON CREATIONS LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL-1, , RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

DCIT, CENTRAL CIRLCLE 1, RAJKOT, RAJKOT vs. BUILDCON CREATIONS LLP, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 539 To 542/Rjt/2024 (Assessment Year: 2019-20 To 2022-23) (Hybrid Hearing)

79,68,556/- being unaccounted profit was made by the assessing officer, over and above the regular business income reported by the assessee in the Income-tax Return filed for the year under consideration, invoking provisions of section

THE INCOME TAX OFFICER-WARD-2, , GANDHIDHAM - KUTCH vs. M/S. RIDDHI SIDDHI JEWELLERS, GANDHIDHAM - KUTCH

In the result, appeal of the Revenue isdismissed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Royassessment Year :2014-15 Ito, Ward-2 Vs. M/S.Riddhi Siddhi Jewellers Gandhidham. Shop No.1, Plot No.68 Bba (Sough) Gandhidham-Kutch. 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri B.D. Gupta, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 11/04/2023 घोषणा क" तार"ख /Date Of Pronouncement: 05/07/2023

68, 69A, 69B & 69C fall under Chapter VI. 12 8. On the other hand, ld. DR submitted that addition under section 69 has to be separately made following the decision of Hon. Gujarat High Court in Fakir Mohmed Haji Hasan vs. CIT (supra) and no set off against business loss has to be allowed. 9. We have considered

THE INCOME TAX OFFICER-WARD-2,, JUNAGADH vs. SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,, JUNAGADH

In the result, appeals filed by the Revenue, in ITA No

section 68, 69, 69A to 69D of the IT Act and as such, in the light of non- disputed fact that unexplained credit whether found in the bank statement of the assessee, who regularly maintain books of accounts. Ld. ITAT should have agreed to legal- plea of the Revenue that till onus with respect to identity, credit worthiness

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

79,400/- on account of undisclosed income which used for purchase of cheques/DDs from M/s. Siddhanath Enterprise.” [This is common ground no.6 in Revenue’s appeal in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 7 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 8 in ITA No. 48/RJT/2019 for AY 2012-13] 29.This summarized and concise

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

79,400/- on account of undisclosed income which used for purchase of cheques/DDs from M/s. Siddhanath Enterprise.” [This is common ground no.6 in Revenue’s appeal in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 7 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 8 in ITA No. 48/RJT/2019 for AY 2012-13] 29.This summarized and concise

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

79,400/- on account of undisclosed income which used for purchase of cheques/DDs from M/s. Siddhanath Enterprise.” [This is common ground no.6 in Revenue’s appeal in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 7 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 8 in ITA No. 48/RJT/2019 for AY 2012-13] 29.This summarized and concise