KANATALAW SEVA SAHAKARI MANDALI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

delay may not be condoned and appeal of Assesee may be dismissed. 2. Without prejudice to above, brief submissions on merit are as under: a) It is undisputed that ROI of subject AY 2018-19 was not filed by Assesee within due date. b) As per section BOAC of chapter VIA of Income tax act applicable from

KANATALAW SEVA SAHAKARI MANDALI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

delay may not be condoned and appeal of Assesee may be dismissed. 2. Without prejudice to above, brief submissions on merit are as under: a) It is undisputed that ROI of subject AY 2018-19 was not filed by Assesee within due date. b) As per section BOAC of chapter VIA of Income tax act applicable from

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Appeals of the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing)

Exemption), the assessee- trust is in appeal before us. 17. We have heard both the parties. Learned Counsel for the assessee, submitted that Tribunal has power to condone the delay

KRUPA VILAS GAU SEVA TRUST,KUTCH vs. CIT(EXEMPTION), AHMEDABAD

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 162/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No. 163/Rjt/2023 (Assessment Year: Na) (Hybrid Hearing) Krupa Vilas Gau Seva Trust, Vs. Cit(Exemption), Kutch. Ahmedabad. Anjar, Anjar Road, Bhimasar Taluka Anjar, Kutch-370240. स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaetk8746K (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारितीकीओरसे/Assessee By : Shri Kalpesh Doshi, Ar राजस्वकीओरसे/Respondent By : Shri Sanjay Punglia, Cit Dr सुनवाईकीतारीख / Date Of Hearing : 09/01/2025 घोषणाकीतारीख / Date Of Pronouncement : 24/03/2025 1 | Page

Exemption), the assessee- trust is in appeal before us. 17. We have heard both the parties. Learned Counsel for the assessee, submitted that Tribunal has power to condone the delay

SHRI RAJKOT VISHASHRIMALI JAIN SAMAJ ,RAJKOT vs. THE ITO, EXEMPTION WARD-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

delay has been condoned by CIT(Exemptions), Ahmedabad. In the case of Sarvodaya Charitable Trust v. ITO (Exemptions) [2021] 125 taxmann.com

SHRI BHUJ LOHANA MAHILA VIKAS,BHUJ vs. CIT (EXEMPTION), AHMEDABAD

In the result, appeal of the assessee-trust is allowed, for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 262/Rjt/2025 िनधा"रण वष"/ Assessment Year: Na Hybrid Hearing बनाम Shri Bhuj Lohana Mahila Vikas Cit (Exemption) Vs. 16, C/O Harjivan Velji Popat Ghanshyam Room No. 609, Floor-6, Aaykar Nagar, Bhawan (Vejapur), Near Sachin Bhuj – 370001 (Gujarat) Tower, 100 Foot Road, Anandnagar – Prahladnagar Road Ahmedabad-380015 "थायीलेखासं/.जीआइआरसं/.Pan No. : Aafas4626N (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri R.B. Shah, Ld. Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit (Dr) सुनवाई क" तारीख/Date Of Hearing : 19/08/2025 घोषणा क" तारीख/Date Of Pronouncement : 29/08/2025 आदेश/Order Per, Dr. A. L. Saini, Am:

condone the delay. 8. On merit, Ld. Counsel submitted that Ld. CIT (Exemption) has denied. registration on the reason that

SHRI JINAM EDUCATION AND CHARITABLE TRUST,NAKHATRANA vs. CIT(EXEMPTION), AHMEDABAD

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

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinha

Exemption), Ahmedabad.” 4. On the other hand, Ld. CIT-DR for the Revenue opposed the prayer of the assessee for condonation of delay

SHABBIR SAIFUDDIN MAKATI,JAMNAGAR vs. THE ITO, WARD-3(1),, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.419/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Shabbir Safuddini Makati बनाम Income Tax Officer, Ward-2(6), Jamnagar, Aaykar /Vs. C-2/333, Gidc, Shankar Bhwan, Jamnagar-361 004 Tekari, Udyog Nagar, Jamnagar-361004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acdpm8899E (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay or default for hearing, default may be condoned and penalty to be deleted. 4. The Hon’ble Commissioner of Income Tax (Appeals) has erred in passing an order against the assessee on the grounds that sufficient opportunity of being heard was provided. However, appellant not aware of any communication from department under the unforeseen circumstances of AR. Therefore

KHIMJI HARIDAS MODI KAUTUMBIK TRUST,STATION ROAD vs. ITO EXEMPTION WD 2 RAJKOT, RAJKOT

In the result, ground raised by the assessee in both the appeals are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini, Am. आयकर अपील सं./Ita No.79&80/Rjt/2025 "नधा"रणवष" / Assessment Year: (2018-19 & 2019-20)

Exemption), Trust, Station Road, Porbandar- Ward-2, Rajkot, IT Office, New Vs. 360575 Aaykar Bhawan, Vatiaka, Rajkot- 360 001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.:AAATS8926R (Assessee) (Respondent) Assessee by : Ms. Janvi Shah, Ld. AR Respondent by : Shri Abhimanyu Singh Yadav , Ld. Sr. (DR) Date of Hearing : 12/03/2025 Date of Pronouncement : 30/04/2025 आदेश / O R D E R Per, Dr. ARJUNLAL SAINI

KHIMJI HARIDAS MODI KAUTUMBIK TRUST,STATION ROAD vs. ITO EXEMPTION WD 2 RAJKOT, RAJKOT

In the result, ground raised by the assessee in both the appeals are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini, Am. आयकर अपील सं./Ita No.79&80/Rjt/2025 "नधा"रणवष" / Assessment Year: (2018-19 & 2019-20)

Exemption), Trust, Station Road, Porbandar- Ward-2, Rajkot, IT Office, New Vs. 360575 Aaykar Bhawan, Vatiaka, Rajkot- 360 001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.:AAATS8926R (Assessee) (Respondent) Assessee by : Ms. Janvi Shah, Ld. AR Respondent by : Shri Abhimanyu Singh Yadav , Ld. Sr. (DR) Date of Hearing : 12/03/2025 Date of Pronouncement : 30/04/2025 आदेश / O R D E R Per, Dr. ARJUNLAL SAINI

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

exempt from tax, and therefore, the addition made of Rs. 11,93,673/- u/s 50C, is against the provisions of the law. 3. The appeal filed by the assessee for assessment year (A.Y.) 2016-17 is barred by limitation by 80 days. The assessee has moved a petition for condonation of delay

LATE ARJAN KANJI PUJARA SMARK CHARITABLE TRUST BHACHAU,BHACHAU vs. DEPUTY COMMISSIONER, INCOME TAX (CPC), BANGALORE, BANGALORE

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

condone the delay in filing Form No.10B is vested u/s. 119(2) of the Act by the Commissioner of Income Tax (Exemption

JIGNESH NARENDRABHAI MANDALIYA,RAJKOT vs. THE INCOME TAX OFFICER, WARD 2(1)(1), RAJKOT, RAJKOT

In the result, ground raised by the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini

exemption while completing assessment by Ld. AO. 4. The Ld. CIT(A) erred in law as well as on facts in upholding an addition of Rs.7,50,000/- without giving proper opportunity and adequate considering the matter and irrelevant consideration. 5. The Ld. CIT(A) erred in law as well as on facts that order u/s 250 passed

MOTA DADVA MAHILA DOODH UTPADAK SAHKARI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(2)(1), RAJKOT

In the result, both appeals filed by the assessee, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.37 & 38/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 Mota Dadva Mahila Utpadak Sahakari The Ito, Ward-1(2)(1) बनाम At Mota Dadva, Gondal, Rajkot Rajkot Gujarat-360311 Vs. Pan : Aakfm7170M (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Samir Bhuptani, Ld.Ar राज"व क" ओर से/Revenue By : Ms. Monica Pandey, Sr-Dr

condoned in filing both these appeals. 5. On merit, At the outset, Learned Counsel for the assessee, begins by pointing out that assessee has not attended the proceedings before the assessing officer and before learned CIT(A), as the assessee is uneducated and reside in remote area, where internet facility is not available, therefore, notices of hearing were not served

MOTA DADVA MAHILA DOODH UTPADAK SAHKARI,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1(2)(1), RAJKOT

In the result, both appeals filed by the assessee, are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.37 & 38/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 Mota Dadva Mahila Utpadak Sahakari The Ito, Ward-1(2)(1) बनाम At Mota Dadva, Gondal, Rajkot Rajkot Gujarat-360311 Vs. Pan : Aakfm7170M (अपीलाथ"/Appellant) : (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Samir Bhuptani, Ld.Ar राज"व क" ओर से/Revenue By : Ms. Monica Pandey, Sr-Dr

condoned in filing both these appeals. 5. On merit, At the outset, Learned Counsel for the assessee, begins by pointing out that assessee has not attended the proceedings before the assessing officer and before learned CIT(A), as the assessee is uneducated and reside in remote area, where internet facility is not available, therefore, notices of hearing were not served

SAKINABAI SAIFUDDIN MAKATI,JAMNAGAR vs. AO, AAYKAR BHAWAN, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.403/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Sakinabai Saifuddin Makati बनाम Income Tax Officer, /Vs. C-2/333 Gidc Shanker Tekri, Ward-3(1), Jamnagar, Aaykar Udyog Nagar, Udyog Nagar S.O. Bhawan, Jamnagar-361 005 Jamnagar-361004 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatpv770N (अपीलाथ"/Appellant) (""यथ"/Respondent)

exempt under section 10(10D) of IT Act and properly disclosed in the return on income filed by the assessee.” 3. The appeal filed by the assessee, for Assessment Year 2014-15, is barred by limitation by 591 days. The assessee has moved a petition requesting the Bench to condone the delay

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(4), DWARKA, DWARKA

In the result, appeal filed by the assessee, in ITA No

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

SAPNA NAINESH JATANIA,RAJKOT vs. INCOME TAX OFFICER, WARD 1(1), JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee, in ITA No

Bench: Dr. Arjun Lal Saini

condone the delay in both appeals. 3. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated in ITA No.449/RJT/2025, for assessment Year 2012-13, have been taken into

SHIA IMMAMI ISMALIA GIRLS ACADEMY,BHUJ vs. CIT (EXEMPTION), AHMEDABAD

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.50/Rjt/2025 (निर्धारण वर्ष / Assessment Year: N.A.) Shia Immami Ismalia Girls Academy, Vs. Bhaveshwar Nagar, Bhuj, Kutch, Gujarat-370001 Commissioner Of Income Tax (Exemption), Ahmedabad स्थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abbts3142F (Appellant) (Respondent) Appellant By Respondent By Date Of Hearing Date Of Pronouncement : Shri R. B. Shah, Ar : Shri Sanjay Punglia, Cit Dr : 02/06/2025 : 30/06/2025 आदेश / Order Per Dr. A. L. Saini, Am: Captioned Appeal Filed By The Assessee, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Exemption), Ahmedabad Vide Order Dated 04.09.2024, Wherein Ld. Commissioner Of Income Tax (Exemption) Rejected The Application Filed By The Assessee In Form No. 10Ab Under Section 12A(1)(Ac)(Ii) Of The Act Holding That The Application Filed By The Assessee Under Section 12A(1)(Ac)(Ii) Of The Act In Form No. 10Ab Is Prima Facie Not Maintainable. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Learned Cit (Exemption) Has Erred Both On Facts & In Law In Not Granting Registration To The Appellant Trust On The Mere Ground That In The Application Made In Form No. 10Ab Of The Income Tax Rules, Section 12A(1)(Ac)(Ii) Of The Income Tax Act Had Inadvertently Been Typed On Account Of Typographical Error Instead Of Section 12A(1)(Ac)(Iii) Of The Act. 2. The Appellant Craves Leave To Add, Alter & Amend Or Delete Any Of The Grounds Of Appeal Before Or At The Time Of Hearing.”

Exemption) has erred both on facts and in law in not granting registration to the appellant Trust on the mere ground that in the application made in Form No. 10AB of the Income Tax Rules, section 12A(1)(ac)(ii) of the Income Tax Act had inadvertently been typed on account of typographical error instead of section