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

unexplained cash credit under section 68 of the Act. Hence the AO added the sum of Rs. 39 lakhs to the total income of the assessee. Aggrieved assessee preferred an appeal to the learned CIT (A) who has also confirmed the order of the AO. Being aggrieved by the order of the learned CIT (A), the assessee is in appeal

HOLLIS VITRIFIED PRIVATE LIMITED,MORBI, GUJARAT, INDIA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT, GUJARAT, INDIA

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 363/Rjt/2024 (Assessment Year: 2018-19) (Hybrid Hearing) Hollis Vitrified Pvt. Ltd. Vs. The Pr. Commissioner Of Income Revenue Survey No. 756/P1/P1/P1, Opp. Tax-1, Rajkot Antique Granito, Ghuntu,-Lakhdhirpur Road, Morbi (Gujarat)-363642 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacch5628Q (अपीलाथ"/Appellant) (""थ"/Respondent)

section 68 of the Income Tax Act, 1961. 3.8.5 In view of the above facts and material on record a detailed Show- Cause Notice (SCN) was sent to the assessee requiring him to explain as to why the unsecured loan amounting to Rs.11,17,22,379/-credited in his books of accountsis not considered as unexplained cash credit u/s 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

unexplained investment under Section 69 of the Act and Rs. 10 lakhs under Section 68 of the Act, being unexplained

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

unexplained investment under Section 69 of the Act and Rs. 10 lakhs under Section 68 of the Act, being unexplained

INCOME TAX OFFICER, MORBI vs. MAHENDRAKUMAR BHAGVANDAS RANPURA, MORBI

Investment as envisage\nin the provision of section 69B of the Income Tax Act. That provision of section 68\nto 69D are residuary sections and the same is applied only where the amount was\nnot taxed under any specific chapter. In the present case in hand, the respondent\nassessee company is engaged in the business of Jewellery. The difference

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

unexplained investment in the stock, which had to disclosure by the appellant during the survey. Now the A.O.’s argument is that the appellant had failed to submit documentary evidences and other details related to such alleged trading and therefore it cannot be said that such investment has been derived and hence part of the same business cannot be accepted

THE DCIT, MORBI CIRCLE, , MORBI vs. M/S. CLAYRIS CERAMICS PVT. LTD.,, MORBI

In the result, the appeal of the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकरअपीलसं./Ita No. 287/Rjt/2018 With Co No. 28/Rjt/2018 निर्धररवरध/Asstt. Year: 2013-14 D.C.I.T, M/S. Clayris Ceramic Pvt. Ltd., Morbi Circle, Vs. Opp. Soriso Ceramics, Morbi. B.H Fame Ceramics Pvt., 8A-Nh, Morbi.

section 68 of the Act. However, the AO while ITA no.287/Rjt/2018 with C.O No.28/Rjt/2018 Asstt. Year 2013-14 10 making final addition given the credit of Rs. 78,37,940 on account separate addition made for credit of unsecured loan. Hence the AO made the final addition of Rs. 5,50,63,800/-. 10.3 On appeal by the assessee

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. M/S REAL PROCON PVT. LTD.,, RAJKOT-GUJARAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.498/Rjt/2015 िनधा"रण वष"/Asstt. Year: 2012-2013 D.C.I.T., M/S Real Procon Pvt. Ltd., Circle-1(1), Vs. Saneshwar Complex, Rajkot. Opp. Balalji Hall, 150 Ft. Ring Road, Rajkot.

unexplained cash credit under section 68 of the Act. 3. The necessary facts in brief are that the assessee in the present case is a private limited company and engaged in the business of construction of residential cum commercial complex. The assessee in the year under consideration has issued shares to the promoter directors as well as to the outsiders

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.

investments. (o) Your Honor will appreciate the fact that, the noting in rough note book cannot be regarded as books of account within the meaning of section 2(12A) of the Act. The casual noting in rough diary are dumb documents having no evidential value. The reliance is placed on following judicial pronouncements”. 10. The ld.AO has submitted his remand

ANIL DHANSUKHLAL,RAJKOT vs. INCOME TAX OFFICER (INT. TAXATION) GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.68/Rjt/2024 "नधा"रणवष"/ Assessment Year: (2018-19) Anil Dhansukhlal Income Tax Officer बनाम Vakhat Niwas 10, Divan Para (Int.Txn), Gandhidham, Vs. Rajkot -360 001 Amruta Estate Building, Jheelwas, Sadar, Rajkot- 360 001 Pan/Gir No.Ajypd6405F "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Bharat Kumar, Ar राज"वक"ओरसे/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

unexplained investment in purchase of immovable property u/s 69 of the Act. 4. Aggrieved by the order of Ld.DRP, the assessee is in further appeal before us. 5. Shri Bharat Kumar, Learned Counsel for the assessee, submitted the paper book, before the Bench, containing pages 1 to 243 and stated that assessee under consideration is a non-resident

SUNBOND CERAMIC PRIVATE LIMITED,MORBI vs. JCIT, MORBI RANGE, MORBI, MORBI

In the result, appeal filed by the assessee is partly allowed, to the extent indicated above

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.739/Rjt/2024 "नधा"रणवष" / Assessment Year: (2014-15)

unexplained cash credits u/s 68 of the Act and be added to the income of the assessee for the year under consideration. 6. In response to the above, show cause notice, the assessee, vide its letter dated 21/12/2016, filed written submissions along with the details in respect of the parties from whom new unsecured loans and money against share application

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

investment was made and not during the year under consideration. 7. So far as addition of Rs.10.00 lakhs made by the AO under section 68 of the Act is concerned, the ld.CIT(A) noticed that the assessee has shown gross contract receipt of Rs.15,75,250/- and offered Rs.1,26,020/- which is 8% of the gross receipt under section

SHRI SANJAY GORDHANDAS VAJA,AHMEDABAD vs. THE ITO, INTERNATIONAL TAXATION, GANDHIDHAM-KUTCH, GANDHIDHAM-KUTCH

In the result, this appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.89/Rjt/2024 Assessment Year: 2018-19 Sanjay Gordhandas Vaja Income Tax Officer Int. 202, Harmony Heights, Capital Road, बनाम Tax), Gandhidham, Income- Science City, Ahmedabad-380 060 Tax Office, Amruta Estate /Vs. Building, Nr. Girnar Cinema, M.G. Road, Rajkot-360 001 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Ahtpv 3289 L (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Aseem Takkar, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr सुनवाई क" तार"ख /Date Of Hearing : 31/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 30/09/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2018-19, Is Directed Against The Final Order Passed By The Assessing Officer, (After Incorporating Findings Of Dispute Resolution Panel-2 Mumbai, Dated 29.12.2023), Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) .

68 of the I.T. Act, 1961 and erred in taxing the same applying the provisions of Sec. 115BBE of the Act only on the basis of the order dated. 29/12/2023 passed by the Hon’ble DRP, Mumbai. 6. The Learned Assessing Officer has erred in making addition of Rs.32,50,000/- treating the investment in purchase of immovable property

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. AXWELL GRANITO PVT. LTD., MORBI

In the result, appeal filed by the Revenue is dismissed

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

unexplained and added back the same in the income of the assessee u/s 68 of the Act. 4. Aggrieved by such partial disallowance, and addition by the assessing officer to the tune of Rs.1,32,68,300/-, the assessee carried the matter in appeal, before the ld. CIT (A), who has confirmed the stand taken by the assessing officer

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

Appeals are dismissed, Assessee's appeals are partly allowed

investment in property at Ahmadabad.\n44.1 At the outset we note that we have deleted the addition on account of undisclosed\ninvestment in the property located at Ahmadabad vide Para No. 43 of this order.\nTherefore the addition made by assessing officer on the ground of rental income of\nsuch property situated in Ahmadabad is also liable to be deleted

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

section 143(3) r.w.s 153A of the Income Tax Act, 1961. The core issue revolves around various additions made by the Assessing Officer and subsequently deleted or restricted by the CIT(A), pertaining to credit entries in foreign bank accounts, gold/silver accounts, cash/premium payments, unexplained investments, disallowed interest, purchase of cheques/DDs, assessment validity under section 153A, deemed rental income, premature

PARESH DAYASHANKAR MADEKA,RAJKOT vs. THE INCOME TAX OFFICER, WARD-2(2)(3), RAJKOT

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

section 68. Copy of the order is also enclosed for your Honours reference\n18. It has been notices from the ledger account of copy of M/s. BCCL in the books of account of the appellant. The appellant has given the inter- corporate loans to M/s. BCCL and subsequently those loans were repaid by m/s. BCCL to the appellant with

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

unexplained cash credit. Therefore in our considered view, the assessee has discharged its onus imposed under 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