THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

bogus nature of the transactions or receipt back of cash from M/s Terapanth Foods Pvt. Ltd. The purchases by the group concerns and sale by the assessee are duly vouched, paid for by account payee cheques, supported by audited books of accounts. It was further submitted that F.Y. 2008-09 is the first year of trading activity of export

GLOBAL EXTRUSIONS PVT. LTD. ,JAMNAGAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.203/Rjt/2024 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Global Extrusions Private Limited. Vs. Pcit Jamnagar, Ca Govind Sonecha Taranjali Building, “S&A House”, Near Golden City, Jamnagar 361008 80Ft Road, Khodiyar Colony, B/H Saru Section Police Headquarters, Jamnagar 361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcm4319E (Appellant) (Respondent) Appellant By : Ms. Amoli Gusani, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. (Cit)Dr Date Of Hearing : 19/03 /2025 Date Of Pronouncement : 09/06/2025

purchase transaction is backed up by supportive documentary evidences, the same nowhere remains bogus or unexplained in any case. Also, the Ld. AO has duly verified the records and evidences furnished before him during the course of Assessment Proceedings. Hence, Vide para 8 it is being contended referring the Explanation 2 of Section 263 of the Act that, the order

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

transferred in demat account even after one year of the purchase, what was the source of funding of the purchase of shares and whether any third party evidence exists to prove the genuineness of purchase transaction, etc. VII. Further, in the most recent judgement the Hon'ble Supreme Court dismissed the SLP filed by the assessee in the case

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

transferred in demat account even after one year of the purchase, what was the source of funding of the purchase of shares and whether any third party evidence exists to prove the genuineness of purchase transaction, etc. VII. Further, in the most recent judgement the Hon'ble Supreme Court dismissed the SLP filed by the assessee in the case

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

transferred in demat account even after one year of the purchase, what was the source of funding of the purchase of shares and whether any third party evidence exists to prove the genuineness of purchase transaction, etc. VII. Further, in the most recent judgement the Hon'ble Supreme Court dismissed the SLP filed by the assessee in the case

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

transferred in demat account even after one year of the purchase, what was the source of funding of the purchase of shares and whether any third party evidence exists to prove the genuineness of purchase transaction, etc. VII. Further, in the most recent judgement the Hon'ble Supreme Court dismissed the SLP filed by the assessee in the case

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

bogus accommodation entry of Long Term Capital Gain/Short Term Capital Loss. b. The assessee submitted copy of audit report, P & L account, Balance sheet of the said company, however, failed submit the reliable documents in respect of economic or financial justification for rise in the sale price of these shares. c. During the assessment proceedings, the assessee provided copy

SINGHVI TRADELINK PRIVATE LIMITED,GANDHIDHAM vs. ITO, WARD - 2, GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is partly allowed

transferred to\nand shall vest in the limited liability partnership without further assurance, act or\ndeed.\"\nTherefore, any legal proceeding initiated against the private limited company will\ncontinue against the LLP as it steps into the shoes of the company.\n7. Argument against the Contrary Position:\nIf the interpretation that the LLP is not liable for the previous legal proceedings

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

transfer /sale of the impugned property, the assessee has stated that the deal did not materialize and therefore she had to return the amount of Satakhat to the aforesaid persons by way of cheques as per the following particulars: Sr. Name of person in whose favour cheque Cheque Date Amount No. is drawn No. 1. Shri Anilsinh Chandubha Jadeja

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

transfer /sale of\nthe impugned property, the assessee has stated that the deal did not\nmaterialize and therefore she had to return the amount of Satakhat to the\naforesaid persons by way of cheques as per the following particulars:\nSr. No. Name of person in whose favour cheque Cheque Date\nNo. is drawn\n1.\n2.\n3.\n4.\n5.\nShri Anilsinh

KAUSHALIYA SAMPATLAL DUDANI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(6), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.659/Rjt/2025 िनधा"रण वष"/Assessment Year :2012-2013 Kaushaliya Sampatlal Dudani The Ito, Ward-2(6), बनाम/ K-1/79/4 G.I.D.C., Shanker Ayakar Bhawan, Jamnagar Vs Tekri, Udyognagar, Jamnagar Jamnagar. Gujarart-361005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Abnpd8662P (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज" की ओर से/Revenue By : Shri Abhimanyu Singh, Ld. Sr-Dr

transfer of shares in Tuni Textiles was bogus. Hence the addition was deleted by the ITAT. In the present case, the assessee has already placed on record the contract notes/bill for sale of shares and this substantiates the fact that assessee or his broker was not involved in price ragging or manipulation activities as alleged by assessing officer. Further, assessing

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)

bogus LTCG and price ragging activity without having direct nexus or any concrete evidence to disprove the facts brought on record by the assessee. Even the lower authority failed to deal with the set of evidence already on record. Further, no evidence is brought on record by the order passed by the Ld. FAO as well as order passed

NISHANT PAREKH- LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD-1(3), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.215/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-2016) Nishant Parekh – Legal Heir Of Vs. Income Tax Officer Mina Parekh Aaykar Bhavan 322 Madhav Square, Opp 361001, Gujrat Avantika Complex, Limda Lane Road, Gujrat-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (Appellant) (Respondent)

price of the share, it can be said that assessee received the penny stock gain in order to off-set the loss or to convert the unaccounted money into white money, and that was the reason that the Government has introduced Section 56(2)(viia) of the Act. The assessee received the bogus long term capital gain (LTCG) and that

PRITIBEN JAGDISHBHAI MEHTA,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX-1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

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

transferred from the dematerialized account and received consideration through legitimate banking channels. Assessing officer did not have any independent source or evidence to show an agreement between the assessee and any other party to convert unaccounted money by taking the fictitious loss. The decision of assessing officer was unsupported by any material on record, and the finding was purely

RAJENDRASINH B. JADEJA,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WD-3(2),, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed

Bench: Shri C.M.Garg & Shri O.P.Meenaआयकरअपीलसं. / Ita No.712/Rjt/2014 "नधा"रणवष"/ Assessment Year: 2010-11 Vs. Income Tax Officer, Shri Rajendrasinh B. Jadeja, Plot No.88, Ruda Nagar, Ward-3(2), Sadguru Society, University Road, Rajkot. Rajkot. [Pan: Abkpj 8944R] (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओरसे/Assessee By : Shri M.J. Ranpura, A.R राज"वक"ओरसे/Revenue By : Shri Praveen Verma, Sr. D.R सुनवाईक"तार"ख/Date Of Hearing : 19-11-2018 घोषणाक"तार"ख /Date Of Pronouncement : 19-11-2018 आदेश /Order Per C.M. Garg: This Appeal Has Been Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals)-Iii, Rajkot (‘Cit(A)’ For Short) Dated 16.10.2014 For The Assessment Year (A.Y) 2011-12. 2. The Grounds Raised By The Assessee Read As Follows: ‘’1.0 The Grounds Of Appeal Mentioned Hereunder Are Without Prejudice To One Another.

price has been noted from the same 4 Shri Rajendrasinh B. Jadeja cheque numbers, which have been shown in the copy of the statement of bank account submitted by the assessee at Pages 14 to 19 of assessee’s paper book. The ld. AR also submitted that in this situation, the assessee simply assisted his sister in buying a property

MISS PARI ANIL GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

transfer of shares\ntook place through D-mat account. Further, it has been mentioned that all details\nregarding the purchase/sale of shares i.e. evidence of purchase of shares, evidence\nof payment for purchase of shares made by way of account payee cheque, copy of\nbank statement, copy of balance sheet disclosing investments, copy of demat account\nstatement reflecting purchases, evidence