SMT. MEENABEN KETANKUMAR MAKIM,JAMNAGAR vs. THE PR, CIT, JAMNAGAR, JAMNAGAR

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

Bench: Shri Waseem Ahmed & Shri T.R Senthil Kumar

section 143(3) of the Act. However, the Ld. PCIT was satisfied with the submission of the assesses. Accordingly, the Ld. A.Y. 2015-16 3 PCIT held the order of the AO as erroneous in so far prejudicial to the interest of revenue by observing as under: 8.1. The main contention of the assessee is that the while completing

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 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

M/S. JAYSHRI EXPORTS (INDIA) LTD.,JETPUR vs. THE DCIT, CIRCLE-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपील सं /Ita No. 56/Rjt/2020 िनधा"रण वष"/Assessment Year : 2004-05 बनाम/ M/S. Jayshri Exports (India) The Deputy Commissioner Of Dhoraji Road, Navagadh, Income-Tax Circle-1, Rajkot Vs Jetpur, Gujarat - 360370 "ायीलेखासं./जीआइआर सं./Pan/Gir No.: Aabfj8267B (अपीलाथ"/Assessee) (""थ"/Respondent)

81,465/-. The return of income so filed by the assessee, was accompanied with Audit Report in Form No. 3CB, 3CD, 10CCB & 10CCAC. The return of income was processed u/s 143(1) of the I.T. Act on 27.01.2005, without any modification. The notice u/s. 143(2) of the I.T. Act dated 07.02.2005, was issued and served upon the assessee

THE ACIT.,GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S. WOCO TECH POLYMERE KANDLA LTD.,, KANDLA, GANDHIDHAM-KUTCH

In the result, the appeal for the assessment year 2011-12 is also allowed

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

transfer agreement and the technical services, even though interlinked, is quite distinct and separate. [17] In any event, in addition to establishing arm's length price under the TNMM, the assessee has performed a supplementary CUP analysis which shows that the fees for technical services was at an arm's length, as shown below: Assessment Average rate per day Amount

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)

81,890/- under section 68 of the Act, based on the documents placed on record, the assessing officer has not recorded any reason as to why the addition can be made under section 68 of the Act and on what reasons and why the evidences placed on record which are the third- party evidences are not considered. The assessing officer

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

81,130/-. In support of the same, 1 am enclosing herewith the copy of assessment order supra at Annexure-C. Therefore, your authority is requested to kindly consider the submission as above and drop the present proceedings, as the once entire amount has been taxed in the case of one of the co-owners case, then if considered then

BABUBHAI KANJIBHAI SAKARIA,JETPUR vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 156/Rjt/2025 (Assessment Year: 2016-17) Babubhai Kanjibhai Sakariya Vs. Ito, Wd 1(2)(1), Rajkot Plot No. 82 Satyam Park, Amarnagar Aaykar Bhavan, Race Course Ring Road, Jetpur,(Rajkot-Gujarat) -360370 Road, Rajkot 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Agnps7407C (अपीलाथ"/Appellant) (""थ"/Respondent)

81,129/- as income in the hands of the assessee and this way, the ld CIT(A) upheld the addition made by the assessing officer. 7. Aggrieved by the order of the Ld.CIT(A), the assessee is in appeal before us. 8. Learned Counsel for the assessee invited our attention to the order dated 27.08.2025 passed

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.

transferred to the travel agents the assessee should have deducted TDS by treating such discount as commission. 42. On appeal, the ld.CIT(A) has confirmed disallowance. The ld.counsel for the assessee contended that the issue in dispute is squarely covered by the decision of the Hon’ble Gujarat High Court in the case of Ahmedabad Stamp Vendors Association Vs. Union

DUSHYANT BHARATBHAI MEHTA,RAJKOT vs. ITO WD-(2)(1)(2) , RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.422/Rjt/2024 (निर्धारणवर्ष / Assessment Year: (2015-16) Dushyant Bharatbhai Mehta (Physical Hearing) C/O Bhabha Fashions 34/35 Bhabha Bazzar, Ghee Kanta Road, Vs. The Ito, Ward -2(1)(2), Aaykar Bhawan, Rajkot Rajkot 360001 (Gujarat) स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahgpm4763P (Assessee) (Respondent) Assessee By Respondent By : Shri Vijay Mehta, Ld. Ar : Shri Abhimanyu Singh, Yadav, Ld. Sr. Dr Date Of Hearing : 01/05/2025 Date Of Pronouncement : 30/06/2025 आदेश / Order Per, Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged Correctness Of The Order Dated 27-05-2024 Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The

section 45(2) of the Act, provides that although such a conversion of capital assets into stock- in- trade of a business, carried on by the assessee, will be a transfer in the previous year, in which the assets is so converted, but actual capital gain will not arise in the previous year in which assets is converted into stock

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)

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 (AY) 2013-14, it was observed by Ld. PCIT that the order passed by the assessing officer prima facie erroneous

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

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ITO, WARD-1 (1) (2),, RAJKOT

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

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

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

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 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

THE ITO WARD-1 (2) (1),, RAJKOT vs. SHRI KHRAJMAL LEKHRAJBHAI THAVRANI, RAJKOT

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

SHRI DAMJIBHAI LEKHRAJBHAI THAVRANI,,JUNAGADH vs. THE INCOME TAX OFFICER-WARD 1(2)(4),, RAJKOT

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income

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

section 292(C) of the Act, it is considered that these bank accounts pertain to the appellant & the transactions shown in these accounts are true & correct. On considering these transactions as turnover of the appellant, income on these transactions has to be estimated. Apart from these deposits & withdrawals in these accounts, there is no other evidence to decide the income