LATE SMT. PRITI A. GANDHI L/R. SHRI ANILBHAI A. 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

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)

139(1) of the Income Tax Act, 1961 (the Act) on 27.07.2013 declaring total income of Rs. 3,31,950/-. The Long term capital gain on sale of security of Rs. 5,26,730/- was reported as exempt u/s. 10(38) of the Act. In response to notice u/s. 148 of the Act, Return of Income was filed

SHRI PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CEN. CIR.-2, RAJKOT

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

Bench: Ms. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Transfer Pricing Officer-2, Ahmedabad and therefore the time limitation for completion of scrutiny was extended. Assessment in this case was completed u/s 143(3) r.w.s. 92CA of the Act vide order dated 24/12/2018 and the total income was determined at Rs.2,62,08,060/- by making addition of Rs.1,80,000/- on account of deemed rent. Since the assessee

NARESH KANTILAL THACKER,,GANDHIDHAM vs. INCOME TAX OFFICER, WARD-2,, GANDHIDHAM

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2014-15. I.T.A No. 28/Rjt/2018 A.Y. 2014-15 Page No 2 Naresh Kantilal Thacker vs. ITO 2. The brief facts of the case is that the assessee is an individual and engaged in the business of Trading of timber

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

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

price within a short span of time. He has merely taken care to manage paper work to give the colour of genuineness to otherwise sham transactions. In such transactions the theory of probability comes into play. 11. The ld.PCIT noticed that with effect from 01/06/2015, Explanation 2 to the section 263(1) has been inserted which reads as under: "Explanation

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

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

price within a short span of time. He has merely taken care to manage paper work to give the colour of genuineness to otherwise sham transactions. In such transactions the theory of probability comes into play. 11. The ld.PCIT noticed that with effect from 01/06/2015, Explanation 2 to the section 263(1) has been inserted which reads as under: "Explanation

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

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

price within a short span of time. He has merely taken care to manage paper work to give the colour of genuineness to otherwise sham transactions. In such transactions the theory of probability comes into play. 11. The ld.PCIT noticed that with effect from 01/06/2015, Explanation 2 to the section 263(1) has been inserted which reads as under: "Explanation

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

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

price within a short span of time. He has merely taken care to manage paper work to give the colour of genuineness to otherwise sham transactions. In such transactions the theory of probability comes into play. 11. The ld.PCIT noticed that with effect from 01/06/2015, Explanation 2 to the section 263(1) has been inserted which reads as under: "Explanation

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

139(1) declaring total\nincome Rs. 3,91,859/-. The case was reopened u/s 147 of the Income Tax\nAct, 1961 (Herein after, 'Act') for the reason that as per information is\nreceived from the DCIT, Central Circle-1, Rajkot vide letter No. DCIT/CC-\n1/RJT/Angadiya/National Shroff/17-18 dated 08/02/2018, Survey Action u/s\n133A was carried out on 18 September

SIX TWENTY REALTY PVT. LTD.,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

139 of the Act i.e. Rs. 2,79,91,980/-. Notice under section 143(2) of the Act issued. Further, notice under section 142(1) of the Act has been issued confronting various incriminating documents impounded during the Income-tax Survey and seeking assessee's response on the same. Issue Involved: 5. The brief facts of the case are that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE vs. MARUTI ENTERPRISE, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhasr. It(Ss)A No Assessment Assessee Name Respondent Name No. Year 1. 12/Rjt/2024 2014-15 Deputy Commissioner Shri Chetan Dhirajlal Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Pan.:Afkpr4637P 2. 13/Rjt/2024 2014-15 Deputy Commissioner Shri Nikhilbhai Jamnadas Of Income-Tax, Central Patel Circle-1, Rajkot, P-1, Decora Highland, “Amruta Estate” 2Nd Avadh Main Road, Opp. Floor, M.G. Road, Classic Party Plot Rajkot- Rajkot-360 001 360 005 Pan No.: Agipp 1294 K 3. 17/Rjt/2024 2013-14 Deputy Commissioner Shri Dhirajlal Ravji Rokad Of Income-Tax, Central 1, Pearl Plaza, 150 Ft Ring Circle-1, Rajkot, Road, Near G.T. School “Amruta Estate” 2Nd Rajkot-360 001 Floor, M.G. Road, Rajkot-360 001 Panno.:Abopr5408A 19 & 2017-18 & Deputy Commissioner Shri Rohitkumar Maganlal 4. 20/Rjt/2024 2018-19 Of Income-Tax, Central Sanepara Circle-1, Rajkot, Kangshiyani Road, Opp. “Amruta Estate” 2Nd Sundaram Vidhyalaya, Floor, M.G. Road, Dholra Chokdi, Kothariya, Rajkot-360 001 Rajkot-360 004 Panno.:Aaopp4848H 5. 59-60/Rjt/2023 2017-18 & Deputy Commissioner M/S Maruti Enterprise 2018-19 Of Income-Tax, Central Decora West Hills, Near Classic Party Plot, Opp. Circle-1, Rajkot, Kalawa Road, Rajkot-360 “Amruta Estate” 2Nd 005 Floor, M.G. Road, Rajkot-360 001 Panno.:Abdfm3140K 6. 228/Rjt/2023 2019-20 Deputy Commissioner M/S Maruti Enterprise Of Income-Tax, Central

139 of the Act, on 31.05.2018, showing therein income of Rs.2,48,320/-. The assessee-firm was constituted on 06.07.2016 with the following partners: 1. M/s Decora Housing LLP – 60% 2. Shri Arvind Parshottambhai Patel – 5% stake 3. Shri Chirag Arvind Patel – 5% stake 4. Shri Ujash Janadas Vachhani – 5% stake 5. Shri Kaushik Popatlal Rathod – 5% stake 6. Shri

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE vs. ARYAN ARCADE LIMITED , RAJKOT

section 143(3)/153A r.w.s. 143(3) of the Income Tax\nAct, 1961 (in short ‘the Act').\n2.\nSince, the issues involved in all the appeals are common and identical;\ntherefore, these appeals have been heard together and are being disposed of\nby this consolidated order.\n3.\nIn this group of five appeals, four appeals are pertaining to M/s Aryan

THE DEPUTY COMMR. OF INCOME TAX, CEN. CIR.1,, RAJKOT vs. JAYESH HARAKHJI PATEL,, RAJKOT

In the result, all appeals filed by the different assessee's and Revenue\nare allowed for statistical purposes

139(1) on 07.08.2008\nPage 3\nITA Nos. 59 & 76/RJT/2018 (Jayesh Harakhji\nPatel & IT(SS)A Nos. 86 to 89 & 97 to 99/Rjt/2018\n(Ravi V. Hirani)\nvide acknowledgement NO 0514005243 showing income of Rs 48,360/-\nas the return filed in response to the notice issued u/s. 148 of the I.T. Act.\nAccordingly, a notice

JAYESH HARAKHJI PATEL,,RAJKOT vs. ASSTT. COMMR. OF INCOME TAX, CEN. CIR.1,, RAJKOT

139(1) on 07.08.2008\nPage 3\nITA Nos. 59 & 76/RJT/2018 (Jayesh Harakhji Patel & IT(SS)A Nos. 86 to 89 & 97 to 99/Rjt/2018 (Ravi V. Hirani)\nvide acknowledgement NO 0514005243 showing income of Rs 48,360/-\nas the return filed in response to the notice issued u/s. 148 of the I.T. Act.\nAccordingly, a notice u/s. 143(2) was issued

JAMNADAS PURSHOTAM PATEL,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX CENTER-1, RAJKOT

1. On the facts and in the circumstances of the case and in law, learned Commissioner\n(Appeals) erred in deleting the addition of Rs.12,28,16,100/- in respect of unaccounted\non-money receipts, ignoring the facts that during the course of search proceedings,\nvarious incriminating materials pertaining to “Decora Westhill Project” found and\nseized from the premise

DILIP KANTILAL KUBAVAT,PORBANDAR vs. ITO WD 2(3), PORBANDAR, PORBANDAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.522/Rjt/2025 "नधा"रण वष"/Assessment Year :2016-17 Dilip Kantilal Kubavat Ito बनाम/ Prop. Vijay Dairy Farm, Ward 2 (3), Vs Near Ramdhun S V P Road, Porbandar 360575 Porbandar - 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Azfpk8009B (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 09/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 14 /10/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M The Present Appeal Has Been Filed By The Assessee, Against The Order Passed By The Learned Commissioner Of Income Tax (Appeal) [Hereinafter Referred To As “Cit(A)”], Dated 21.03.2025, Arising In The Matter Of Assessment Order Passed U/S 143(3) Of The Income Tax Act, 1961 (Here-In-After Referred To As “The Act”) Relevant To The Assessment Year 2016-17. 2. In This Appeal, The Assessee Has Raised Multiple Grounds Of Appeal. However, The Solitary Grievance Of The Assessee Is That The Ld Cit(A) Erred In Not To Consider The Basic Fact That The Assessee Has Gifted The Property To His Sister In Law (Younger Brother'S Wife) That Is, To A Relative For A Consideration Dilip Kantilal Kubavat

1.T. Act, accepting the returned income. The assessee`s case was selected under limited scrutiny assessment by CASS and notice u/s 143(2) of the Income-tax Act, 1961 was issued by the assessing officer on 09.08.2018 and served upon assessee on 10.08.2018.The assessee has sold a non -agricultural land for Rs.4,90,000/-, vide sale deed

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

section 153A of the Income-tax Act, 1961 which requires the total income to be brought under tax without any restrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in and on facts in holding that such assessment or re-assessment u/s.153A of the Income

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

section 153A of the Income-tax Act, 1961 which requires the total income to be brought under tax without any restrictions and On the facts and in the circumstances of the case and in law, the Id. CIT(A) has erred in law in and on facts in holding that such assessment or re-assessment u/s.153A of the Income