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:

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 80AC 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

4. When this appeal was called out for hearing, none appeared on behalf of the assessee nor any request for adjournment was made by the assessee. The notices of hearing of these two appeals have been sent on the address provided by the assessee in Form No.36. However, I have received written submissions, on merit, from the assessee, which

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

4. When this appeal was called out for hearing, none appeared on behalf of the assessee nor any request for adjournment was made by the assessee. The notices of hearing of these two appeals have been sent on the address provided by the assessee in Form No.36. However, I have received written submissions, on merit, from the assessee, which

ARVINDKUMAR DAYALAL CHAVDA,RAJKOT vs. THE ITO WARD-2 (2) (3), RAJKOT

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

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 841/Rjt/2024 Assessment Year: (2019-20) Arvindkumar Dayalal Chavda Vs. Ito, Ward – 2(2)(3), Rajkot 3 – Nilay, Maruti Nagar, Opp. New Aayakar Bhavan, Vatiaka, Krishnam Appartment, Airport Road, Race Course Ring Road, Rajkot – 360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abzpc0502D (Appellant) (Respondent) Appellant By Shri Kumar Pandya, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr. Dr Date Of Hearing 26/06/2025 Date Of Pronouncement 30/06/2025

139(1) 20/07/2019 Within Time 2 Order u/s 143(1) 28-08- 39 days No 2019 Demand 3 Order u/s 154 29/10/2021 832 days delay from Income Tax Department after issued of order u/s 143(1) with Demand of Rs.87,830/- 4 Appeal u/s 246(A) before CIT(A) With 30/06/2024 945 days delay with Delay Condone Application by Assessee

SHRI DHORAJI NAGRIK SHARAFI AND GRAHAK SAHKARI MANDALI LIMITED,DHORAJI vs. INCOME TAX OFFICER, WARD - 1(2)(1), RAJKOT

In the result, the assessee’s appeal is allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita Nos.478/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2018-19) (Physical Hearing) Shri Dhoraji Nagrik Sharafi & Vs. Income Tax Officer Grahak Sahkari Mandali Ltd. Ward – 1(2)(1), C/O. Sarda & Sarda, Sakar, 1St Rajkot. Floor, Dr. Radha – Krishnan Road, Opp. Rajkumar College, Rajkot- 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaad7775Q (Appellant) (Respondent)

4 Act, cannot be allowed, if the return of income is not filed within the time allowed under section 139(1) of the Act, therefore, assessing officer (CPC) has rightly disallowed the deduction claimed by the assessee, under section 80P of the Act. Moreover, the assessee has not availed the benefit of the provisions of section

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)

section 139 of the Act is condoned (ii) In all other cases of belated applications in filing Form No. 10B for years prior to AY. 2018-19, The commissioner of Income-tax are authorized to admit and dispose of by 31-3-2020 such applications for condonation of delay u's 119(2)(b) of the Act The Commissioner will

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

delay is condoned in filing the appeal. 6.Brief facts qua the issue are that the assessee has e-filed its return of income for the assessment year 2016-17, declaring total income of Rs.2,41,110/- and agriculture income of Rs.5,60,400/- on 18.03.2018. The return of income was processed u/s 143(1) of the 1.T. Act, accepting

RUPA VIMAL PADALIYA,RAJKOT vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

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

section 147 r.w.s. 144 of the Income Tax Act, 1961 (in short \"the\nAct\"), vide order dated 27.03.2023.\n2. Grounds of appeal raised by the assessee are as follows:\n1. The grounds of appeal mentioned hereunder are without prejudice to one\nanother.\n2. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal\nCentre, Delhi (hereinafter referred

INCOME TAX OFFICER, MORBI vs. MAHENDRAKUMAR BHAGVANDAS RANPURA, MORBI

delay is condoned in filing the cross objection.\n8. Succinctly, the factual panorama of the case is that assessee before us is an\nIndividual. The assessee has filed his return of income for assessment year (A.Y.)\n2017-18, on 31/01/2018, declaring therein total income of Rs. Nil/-. The return\nof income was processed u/s 143(1) of the Act. Later

SHRI SAJADIALI SARDAR PATEL SEVA SAHKARI MANDLI LTD. ,RAJKOT vs. THE ITO WARD-2(1)(2), RAJKOT., RAJKOT

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.607/Rjt/2024 "नधा"रणवष" / Assessment Year: (2018-19) (Hybrid Hearing) Shri Sajadiali Sardar Patel Seva Ito Ward-2, (1) (2) Vs. Sahkari Mandali Ltd. Rajkot – 360001 At Sajadiyali – Rajkot New Aayakar Bhavan, At Sajadiyali Taluka, Race Course Ring Road, Jamkandorana, Dist, Rajkot – 360001 Sajadiyali – Rajkot 360001 Gujrat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas2374L (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav , Ld .Sr. Dr Date Of Hearing : 28 / 01 /2025 Date Of Pronouncement : 22 / 04/2025

condonation of delay and related reliefs in cases of genuine hardship. The section clearly outlines the administrative procedure for such cases, directing that any grievances against decisions under this provision must be addressed through a writ petition to the High Court." xvii) Application of the Doctrine:  Direct Limitation: ITAT does not have the jurisdiction to entertain cases related to orders

HANIF OSMAN RAVDA,SITLACHAWK OPP. REHEMANI MASJID ,MEMANWAD MEMANWAD vs. INCOME TAX OFFICER, WARD 2(3) , PORBANDAR, GUJARAT

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

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.447/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Hanif Osman Ravda Vs. Ito Ward 2 (3), Sitla Chawk, Rehemani Masjid, Porbandar - 360575 Memanwad, Porbandar – 360575 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acepr8023N (Assessee) (Respondent)

delay is condoned in filing the appeal. 4. The facts of the case which can be stated quite shortly are as follows: The sole issue involved in the present appeal, relates to addition of Rs. 13,71,365/- made by the assessing officer as unexplained money u/s 69A of the I.T. Act. Briefly stated the facts of the present case

SMT. HEENABEN MAHESHBHAI GADHETHARIYA,RAJKOT vs. THE ITO WARD-3 (1) (1), RAJKOT, RAJKOT

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

Bench: Smt.Annapurna Gupta & Miss Suchitra Raghunath Kambleassessment Year :2017-18 Smt. Heenaben Maheshbhai Vs. The Ito, Ward-3(1) Gadhethariya Rajkot. Flat B/21, Copper Elegance Nr.Ambika Township, Mavdi Police Ground Rajkot, Gujarat Pan : Ahwpg 7174 J

section 115BBE of the Act. Therefore, to meet ends of justice, we condone the delay of 59 days in filing the appeal before the Tribunal, and proceed to adjudicate the appeal of the assessee on merit. 4. The grounds raised in the appeal reads as under: “1. On the facts and in law, the CIT (A) has erred in sustaining

SHRI SWAMI VIVEKANAND TRUST,ADIPUR vs. THE DCIT (CPC) , BANGALORE

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

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

139(1) of the Act, Centralized Processing Centre (CPC), Bengaluru vide its communication dated 02-03-2016 intimated the assessee that the Audit Report in Form 10B is not filed alongwith the Return of Income as per Section 12A(1)(B) of the Act. The assesse was ensured to file the corrected Return, incorporating the details of such Audit, failing

SHRI RAKESH MADHUBHAI KANPARIYA,PREMPARA, DHARI, AMRELI-365640 vs. THE ITO, WARD-3 (1) (4), AMRELI, AMRELI

In the result, assessee’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 255/Rjt/2022 ("नधा"रण वष" / Assessment Year : 2017-18) Shri Rakesh Madhubhai The Income Tax Officer बनाम/ Kanpariya Ward-3(1)(4), Rajkot- Vs. Prempara Dhari Prempara Amreli Dhrai, Prempara Dhari Dhari, Amreli – 365640, Gujarat "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Daipk3406F .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant By : None ""यथ" क" ओर से / Shri K. L. Solanki, Sr.D.R. Respondent By : सुनवाई क" तार"ख / Date Of 18/04/2023 Hearing घोषणा क" तार"ख /Date Of 25/04/2023 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal At The Instance Of The Assessee Is Directed Against The Order Dated 29.07.2022 Passed Under Section 250 Of The Income Tax

delay is condoned. 4. We have heard the Ld. DR and also perused the relevant materials available on record including the orders passed by the authorities below. Upon going through the records, it appears that the case relates to deposit of substantial cash in the bank account during demonetization period where no return has been filed by the assessee

SHREE CHALALA VI KA SEVA SAHAKARI MANDALI LTD. ,AMRELI vs. THE ITO WARD 3(1)(4), RAJKOT-AMRELI., RAJKOT

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini, A Ccountant Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 358/Rjt/2025 िनधा"रण वष" / Assessment Year: (2019-20) Shree Chalala Vi Ka Seva Sahakari Vs. The Ito Ward 3(1)(4), Mandali Ltd. Aayakar Bhavan, Race Course Ring Chalala Haveli Road, Road, Dhari Amreli - 365630 Rajkot - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatas2273D (Appellant) (Respondent) Appellant By : Ms. Devina Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 27/08/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm; Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2019-20, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 31/03/2025, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(1) Of The Act. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: - 1. The Learned Addl/Jcit (A)-1, Kolkata Erred In Confirming Action Of Cpc, Bangalore In Disallowing Claim Of Deduction Of Rs. 3,51,828/- U/S Sop Of The Act By Failing To Appreciate That Provisions Of Sec. 143(1)(A)(V) Do Not Provide For Denial Of Deduction U/S 80P Of The Act When The Return Of Income Is Not Filed Within Time Allowed U/S 139(1) Of The Act But U/S 139(4). 2. The Learned Addl/Jcit (A)-1, Kolkata Erred In Upholding Action Of The Cpc, Bangalore In Making Adjustment To The Returned Income Of The Appellant By Way Of Shree Chalala Vikas Seva Sahkari Mandli Ltd.

section; (i) 80P(2)(a)(i) - Rs.8,06,042/- (ii) 80P(2)(a)(iv) - Rs.1,06,063/- (iii) 80P(2)(d) - Rs.3,51,828/- 4. Thereafter, the appellant was in receipt of communication for not granting deduction of Rs. 1263 933/- claimed in the return of income u/s 80P of the Act, stating that the assessee not filed Return within

MITESHKUMAR DAYALJIBHAI PABARI,BHATIYA vs. ASSISTANT COMMISSIONER/ DEPUTY COMMISSIONER , RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 420 /Rjt/2025 (िनधा"रण वष"/Assessment Year: (2020-21) Miteshkumar Dayaljibhai Pabari Assistant Commissioner/Deputy Commissioner, International C/O Dayaljibhai Pabari, Shreeji Catlery Vs. Taxation Rajkot, Stores, Main Bajar, Bhatiya, Devbhoomi Dwarka, Room No. 312, Income Tax Office, Amruta Estate Building, Near Girnar Dwarka-361315(Gujarat) Cinema, M.G. Road, Rajkot – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bctpp7290M (अपीलाथ"/Appellant) (""यथ"/Respondent)

delay and non- submission of form, even the not taxable income and even provided the explanations with necessary details, explanation and supporting documents. The passed order is erroneous, against the principle of nature of justice and against the provision of law, liable to quash and set aside. (2) Learned A.O. erred in law as well facts by initiating proceeding

CHIMANLAL BHUTALAL SAGAR,MUMBAI vs. DEPUTY COMMISIONER OF INCOME TAX (INTERNATIONAL TAXATION)-1, RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 126/Rjt/2025 ("नधा"रणवष" / Assessment Year: (208-19) (Hybrid Hearing) Chimanlal Bhutalal Sagar Vs. Deputy Commissioner Of Income C/.O Ca Himansu Gandhi, 10Th Floor, D Tax (International Taxation)-1, Wing, Trade World Building, Kamala Room N.312, Ito, Amruta Mills Compaund, Lower Parle – 400013 Building, Nr. Girnar Cinema, M. G. Road, Gujarat – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Fdmps3665D (Appellant) (Respondent) Appellant By : Shri Himansu Gandhi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/05/2025 Date Of Pronouncement : 30/06/2025

section 271AAC(1) of Income Tax Act, 1961. 10. Appellant craves leave to add further grounds or to amend or hearing. alter the existing grounds of appeal on or before the date of hearing. 11. Whether there is any delay in filing of appeal (if yes please attach application seeking condonation of delay) 3. At the outset, that the appeal

SORTHIYA AHIR GNATINO UTARO,BHAVNATH, JUNAGADH vs. THE ADIT (CPC), BANGALORE, BANGALORE

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

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

section 13(9) of the Act exemption u/s. 11(2) is allowed only if Form 10 is e-filed before the I.T.A No. 104/Rjt/2023 A.Y. 2019-20 Page No 3 Sorthiya Ahir Gnatino Utaro vs. ADIT(CPC) due date specified u/s. 139(1) of the Act. As the assessee filed Form 10 after the due date, but along with

SHRI SWAMI VIVEKANAND TRUST,ADIPUR vs. THE ITO (EXEMPTION), WARD(1), RAJKOT, RAJKOT

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.902/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Shri Swami Vivekanand Trust The Ito (Exemption) बनाम Plot No.1, Dc-2 Ward-1 Rambaug Road Rajkot. Vs. Ward-6A, Adipur. Pan : Aabts 1102 L (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 सुनवाई क" तार"ख /Date Of Hearing : 28/01/2025 घोषणा क" तार"ख /Date Of Pronouncement : 28/03/2025 Order Per Dr. Arjun Lal Saini: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Chennai[In Short ‘Ld.Cit(A)/Nfac’], Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 02.05.2024, Which In Turn Arises Out Of An Intimation Order Passed By The Assessing Officer (Cpc) U/S 143(1) Of The Act, Dated 31.10.2015. Shri Swami Vivekanand Trust 2 2. Grievances Raised By The Assessee In This Appeal Are As Under:

condonation of delay in filing the audit report for the assessment year (AY) 2015-16. The ld CIT(A) noted that the assessee failed to fulfil, the fundamental requirement of timely audit report submission therefore, the adjustment made by the assessing officer(CPC), concerning the denial of exemption under section 11 of the Act, was confirmed