MAYURBHAI HIRABHAI SINDHAV ( MALDHARI),RAJKOT vs. INCOME TAX OFFICER WARD 2(1)(2), RAJKOT

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

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

1. In the present case, the appellate order u/s. 250 was passed on 02.01.2017. The appellant does not have the exact date of receipt of the order since, as per his records, the order was never received by him. From the date of passing of the appellate order, the appeal was required to be filed latest by 03.03.2017. 2. However

MAYURBHAI HIRABHAI SINDHAV (MALDHARI),RAJKOT vs. INCOME TAX OFFICER WARD 2(1)(2), RAJKOT

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

Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)

1. In the present case, the appellate order u/s. 250 was passed on 02.01.2017. The appellant does not have the exact date of receipt of the order since, as per his records, the order was never received by him. From the date of passing of the appellate order, the appeal was required to be filed latest by 03.03.2017. 2. However

SAILESHKUMAR MAGANLAL PATEL ,SURENDRANAGAR vs. THE ITO WARD-2, SURENDRANAGAR., SURENDRANAGAR

In the result, both appeals of the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.441 & 442/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Saileshkumar Maganlal Patel The Ito, Ward-2 बनाम Parshavnath Chambers, Surendranagar Navyug Cinema Road, Vs. Surendranagar, 263310, Gujarat Pan : Acdpp2564P (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

section 271(1) (C ) of the Act. Shri Anish Hasan Bakhai ITA No.132 /RJT/2024 (AY : 2017-18) 2 2. The appeal filed by the assessee in ITA No. 442/RJT/2024 [u/s. 271(1)(c) Penalty Appeal) for the Assessment Year 2016-17, is barred by limitation by 214 days, before this Tribunal. The assessee moved a petition requesting the Bench

SHAILESHKUMAR MAGANLAL PATEL,SURENDRANAGAR vs. THE ITO WARD-2, SURENDRANAGAR., SURENDRANAGAR

In the result, both appeals of the assessee is allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.441 & 442/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Saileshkumar Maganlal Patel The Ito, Ward-2 बनाम Parshavnath Chambers, Surendranagar Navyug Cinema Road, Vs. Surendranagar, 263310, Gujarat Pan : Acdpp2564P (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M. Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

section 271(1) (C ) of the Act. Shri Anish Hasan Bakhai ITA No.132 /RJT/2024 (AY : 2017-18) 2 2. The appeal filed by the assessee in ITA No. 442/RJT/2024 [u/s. 271(1)(c) Penalty Appeal) for the Assessment Year 2016-17, is barred by limitation by 214 days, before this Tribunal. The assessee moved a petition requesting the Bench

KHADAKALA SEVA SAHKARI MANADLI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

In the result, appeal filed by the assessee is dismissed, as indicated above

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.199/Rjt/2025 "नधा"रण वष"/Assessment Year :2018-19 Khadakala Seva Sahkari Mandali Income Tax Officer Ltd. Ward 3(1)(4), Amreli बनाम/ Savarkundla, Amreli, 364515 Gujarat - 365650 Vs [C/O. D. R. Adhia Om Shri Padamlaya, Near Trikamrayji Haweli, 16- Jagnath Plot, Dr. Yagnik Road, Opp. Imperial Hotel, Rajkot, Gujarat 360001] "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabak3647B (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 : 28/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M:

11. Taking into consideration legal, statutory, factual and administrative aspects no addition as made ought to have been made. The Ld CIT(A) has also erred in confirming the same. The same needs cancellation. Page 2 of 8 Khadakala Seva Sahkari Mandali Ltd. vs. ITO 12. The Ld. A.O. erred in law as well as on facts in not giving

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

delay and hence the same may kindly be condoned. 8. It is also settled position of law that limitation of additional ground would relate backs to original grounds as held in the following cases. a. Shilpa Associates VS ITO -263 ITR 0317(Raj):- b. Madad Lal Ansari Vs DCIT-272 ITR 560(Raj)- 9. The appellant shall be highly grateful

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

delay and hence the same may kindly be condoned. 8. It is also settled position of law that limitation of additional ground would relate backs to original grounds as held in the following cases. a. Shilpa Associates VS ITO -263 ITR 0317(Raj):- b. Madad Lal Ansari Vs DCIT-272 ITR 560(Raj)- 9. The appellant shall be highly grateful

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

delay and hence the same may kindly be condoned. 8. It is also settled position of law that limitation of additional ground would relate backs to original grounds as held in the following cases. a. Shilpa Associates VS ITO -263 ITR 0317(Raj):- b. Madad Lal Ansari Vs DCIT-272 ITR 560(Raj)- 9. The appellant shall be highly grateful

M/S. IMPACT FORGING, RAJKOT,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

delay and hence the same may kindly be condoned. 8. It is also settled position of law that limitation of additional ground would relate backs to original grounds as held in the following cases. a. Shilpa Associates VS ITO -263 ITR 0317(Raj):- b. Madad Lal Ansari Vs DCIT-272 ITR 560(Raj)- 9. The appellant shall be highly grateful

M/S. IMPACT FORGING, ,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, , RAJKOT

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita Nos.307 To 311/Rjt/2018 निर्धररवरध/Asstt. Years: (2011-2012 To 2015-16) M/S. Impact Forging, D.C.I.T, 6, Mani Nagar, Vs. Central Circle-1, Near Popullar Roller, Rajkot. Mavdi Plot, Rajkot. Pan: Aadfi1340Q

delay and hence the same may kindly be condoned. 8. It is also settled position of law that limitation of additional ground would relate backs to original grounds as held in the following cases. a. Shilpa Associates VS ITO -263 ITR 0317(Raj):- b. Madad Lal Ansari Vs DCIT-272 ITR 560(Raj)- 9. The appellant shall be highly grateful

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

11. Taking into consideration legal, statutory, factual and administrative aspects no addition as made ought to have been made. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 12. The Ld. A.O. erred in law as well as on facts in not giving due deductions while completing assessments. The Ld. CIT(A) has also

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

11. Taking into consideration legal, statutory, factual and administrative aspects no addition as made ought to have been made. The Ld. CIT(A) has also erred in conforming the same. The same needs cancellation. 12. The Ld. A.O. erred in law as well as on facts in not giving due deductions while completing assessments. The Ld. CIT(A) has also

ARJAN LILA GORANIYA,PORBANDAR vs. ITO WARD 2(4), PORBANDAR

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

Bench: Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainibefore Dr. Arjun Lal Sainiआयकरअपीलसं आयकरअपीलसं./Ita No.378/Rjt/2025 "नधा"रणवष" "नधा"रणवष" / Assessment Year: (2013-14) Arjan Lila Goraniya Vs. Ito Ward 2 (4), Inajiya Vadi Vistar, Porbandar - 360575 Porbandar Bhojeshwar S.O, Porbandar Bhojeshwar S.O, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./ ./Pan/Gir No.: Bbwpg1554P (Appellant) (Respondent)

c) of the I.T. Act, 1961. 3. That, the findings of Ld. CIT(A) are not justified That, the findings of Ld. CIT(A) are not justified and bad-in-law. 4. That, the Ld. CIT(A) has wrongly confirmed the order passed u/s 144 of the I.T.Act, That, the Ld. CIT(A) has wrongly confirmed the order passed

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD 2, SURENDRANAGAR, SURENDRANAGAR

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

C’ Bench Kolkata in the case of in the case of M/s. Garg Bros. Pvt. Ltd. & Others vs. DCIT [ITA Nos.2519 to 2521/Kol/2017, order dated 18.04.2018], ITA Nos.519 & 521/Rjt/2025 (AY 13-14 & 14-15) Jivanbhai D Sarla wherein under similar set of facts and reasons, the Hon'ble Tribunal was pleased to condone the delay of 211 days by holding

JIVANBHAI DE vs. HIBHAI SARLA,THANGADH, DIST. SURENDRANAGARVS.THE ITO WARD-2, SURENDRANAGAR, SURENDRANAGAR

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

C’ Bench Kolkata in the case of in the case of M/s. Garg Bros. Pvt. Ltd. & Others vs. DCIT [ITA Nos.2519 to 2521/Kol/2017, order dated 18.04.2018], ITA Nos.519 & 521/Rjt/2025 (AY 13-14 & 14-15) Jivanbhai D Sarla wherein under similar set of facts and reasons, the Hon'ble Tribunal was pleased to condone the delay of 211 days by holding

SHREE SAMARTH SWITCHGEAR AND TRANSMISSION PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

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

condone the delay of 120 days in ITA No.612/RJT/2024,as also 119 days’ delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024, and admit these respective appeals for hearing. 7. For the sake of convenience, the grounds as well as the facts narrated in ITA No.612/RJT/2024, for assessment Year 2018-19, have been taken into consideration for deciding

SHREE SAMARTH ELECTRICALS PVT LTD,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

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

condone the delay of 120 days in ITA No.612/RJT/2024,as also 119 days’ delay, each in filing, the appeals in ITA No.609 and 610/RJT/2024, and admit these respective appeals for hearing. 7. For the sake of convenience, the grounds as well as the facts narrated in ITA No.612/RJT/2024, for assessment Year 2018-19, have been taken into consideration for deciding

BHAVARSINH ANESINH RAJPUT,ANJAR vs. INCOME TAX OFFICER, WARD - 1, GANDHIDHAM, GANDHIDHAM

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.418 & 388/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2009-10 Shri Bhavarsinh Anesinh Rajpput Income Tax Officer, बनाम Survey No. 188, House No. 175/176 Ward-1, Gandhidham Meghpar, Anjar, Gujarat-370110 Vs. (Gujarat) Pan : Apepr3624N (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Kapil Sanghavi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

Section 5 of the Limitation Act should receive a liberal construction so as to advance substantial justice, when the delay is not on account of any dilatory tactics, want of bona fides, deliberate inaction or negligence on the part of the appellant. We note that medical ground is a sufficient cause to condone delay.We note that the reasons given