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

147\nof the I.T. Act was issued on 15.3.2013 by the ITO Ward 5(4) Morbi.\nAs the assessee had not filed return of income in response to the notice\nissued u/s. 148 of the I.T. Act, a notice u/s. 142(1) was issued on\n14.12.2013. The assessee again did not co-operate with the reopening of\nproceedings and therefore

SHRI RAJKOT DISTRICT COOPERATIVE BANK LTD.,,RAJKOT-GUJARAT vs. THE PR. COMMR. OF INCOME TAX-1,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2011-12 Shri Rajkot District Cooperative Vs. Pr.Cit, Rajkot-1 Bank Ltd. Rajkot. ‘Jilla Bank Bhavan’, Kasturba Road Opp: Chaudhari High School Rajkot. Pan : Aaaar 0564 K 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri S.N. Soparkar, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 17/11/2022 घोषणा क" तार"ख /Date Of Pronouncement: 15/02/2023

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner,— (a) the order is passed without making inquiries or verification which should have been made

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

147 r.w.s. 144B of the MansukhbhaiKanjibhai Sakariya Vs. Pr.CIT 4 Income tax Act, 1961 on 28.03.2022, is erroneous and prejudicial to the interest of the revenue. 4.Considering above such facts, notice u/s 263 of the Income-tax Act, 1961, was issued by ld.PCIT, on 29.02.2023 and duly served upon the assessee.The ld. PCIT stated in the notice that assessee case

SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

The appeal is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.196/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2011-12) Shri Rajkot District Co-Operative Vs. The Deputy Commissioner Of Bank Ltd., Income-Tax, Circle-1(1), Jilla Bank Bhavan, Kasturba Road, Aayakar Bhavan, Race Course Ring Opp. Chaudhary High School, Road, Rajkot-360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Commissioner Of Income Tax Office [(In Short “Ld.Cit(A)”] Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(1) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 30.03.2023 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

Transfer Pricing Officer, as the case may bej shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner,- (a) the order is passed without making inquiries or verification which should have been made; Page

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)

147 of the Act" ITA No. 104/RJT/2024/AY.2013-14 Hansa Jitendra Haria vs. PCIT 16. We note that due to non-availability of documents and evidences, the assessing officer has failed to conduct the minimum enquiry or verification, during the course of assessment of penny stock case. The assessing officer has simply asked general questions in his notices, on which the assessee

BHIKHALAL PRAHALADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

price of the company Vax Housing Finance Corporation Limited is reproduced as under (downloaded from moneycontrol.com…..” ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF 4. During the assessment proceedings, the assessing officer issued notice to the assessee to explain the above transactions with documentary evidences. However, the assessee has not submitted any reply before the assessing officer. Therefore

BHIKHALAL PRAHLADRAI AGARWAL HUF,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX GANDHIDHAM CIRCLE, GANDHIDHAM

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

price of the company Vax Housing Finance Corporation Limited is reproduced as under (downloaded from moneycontrol.com…..” ITA Nos.779&780/RJT/2024/AYs.2011-12&2016-17 Bhikhalal Prahladrai Agarwal-HUF 4. During the assessment proceedings, the assessing officer issued notice to the assessee to explain the above transactions with documentary evidences. However, the assessee has not submitted any reply before the assessing officer. Therefore

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)

price. As per IT Act, any purchase in cash above Rs. 20,000 (now 10,000) is not permitted. Buyers across India deposit the cash purchase- amount into the bank-account of self-styled Angadiya/shroff, who remitted cash to seller, after deducting commission. In certain instances, such Bank-accounts were also used for layering and delayering of funds

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI DEEPAK MOHANLAL PURSWANI, RAJKOT

147 of the Income Tax Act,\n1961.\n2.Since, the issues involved in all the appeals are common and identical,\ntherefore, these appeals have been heard together and are being disposed of by\nthis consolidated order.\n3. Although, these appeals filed by the assessee and appeals filed by the revenue,\ncontain multiple ground of appeals. However, at the time of hearing

SHRI CHHAGANBHAI MULJIBHAI PATOLIYA,JETPUR vs. THE ITO WARD-1 (2) (3) RAJKOT, RAJKOT

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.477/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) Chhaganbhai Muljibhai Patoliya, Vs The Ito Ward 1(2)(3), Radhe Park, Shreeji School, Aayakar Bhavan, Race Course, . Amarnagar Road, Rajkot (Gujarat) - 360001 Jetpur (Gujarat) - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ddrpp2365A (Appellant) (Respondent)

price also and he sustain addition made U/s. 50C thus he considered that transaction pertain to capital gain while invoking provisions of section 50 C but erred in not considering deduction due in respect of purchase cost with index 3. The Id CIT(A) has erred in law and facts in passing appeal order on 30-06-2025 without considering

MAYURBHAI JAYSUKHLAL SHAH,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 319/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Mayurbhai Jaysukhlal Shah Vs. Principal Commissioner Of 601, Cross Way, P.N. Marg, Income Tax, Jamnagar Jamnagar, Gujarat-361001 Office Of The Principal Commissioner Of Income Tax.Pcit, Jamnagar "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afgps1754J (अपीलाथ"/Assessee) (""यथ"/Respondent)

147 rws 144B of the Act was passed on 31/03/2022, making an addition of Rs. 81,75,900/-, u/s. 68 of the Act to the total income of the assessee. 3. Later on, the Ld. PCIT exercised his jurisdiction under section 263 of the Income tax Act, 1961.On perusal of assessment records for assessment year

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

price received by the seller of the units for which the seller has already incurred the cost in order to acquire or process the inventory. Therefore, it is the realization of excess consideration over the cost incurred which should be assessed as profit or income, in other words, profit component embedded in the sales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

RK DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJKOT

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. R K DREAMLAND, RAJKOT

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently

R K DREAMLAND,RAJKOT vs. ACIT, CC-1, RAJKOT, RAJOKT

price received by the seller of the units for which the seller has already\nincurred the cost in order to acquire or process the inventory. Therefore, it is the\nrealization of excess consideration over the cost incurred which should be\nassessed as profit or income, in other words, profit component embedded in the\nsales could be treated as income. Recently