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

Appeals of the assessee are allowed for\nstatistical purposes

147 days (approx.),\nand hence ld CIT(E) rejected application of assessee in Form No.10AB, u/s 80G(5) (iii) of the Act,\nas not maintainable and also cancelled the provisional approval granted in Form No.10AC, under\nclause (iv) of first proviso to sub-section (5) of section 80 G of the Act.\n17.\nTherefore, in this ambiguity situation in circular

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

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

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

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

condone the delay in both appeals and admit these appeals for hearing. 7. In both these appeals, the assessee has raised the grounds pertaining to technical issue, being notice issued under section 148 of the Act, is time barred. When these cases were called for hearing, Ld. Counsel for the assessee submitted that the issue under consideration, in both appeals

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)

delayed by 147 days (approx.), and hence ld CIT(E) rejected application of assessee in Form No.10AB, u/s 80G(5) (iii) of the Act, as not maintainable and also cancelled the provisional approval granted in Form No.10AC, under clause (iv) of first proviso to sub-section (5) of section 80 G of the Act. 17. Therefore, in this ambiguity situation

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

147 days. In case of both the appeals, the assessee has not filed the petition for condonation of delay. Therefore, in the absence of petition for condonation of delay, respective delay should not be condoned in both these appeals. 7. Therefore, I find that in these two appeals, no justification has been submitted for condonation for delay in filing appeals

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

147 days. In case of both the appeals, the assessee has not filed the petition for condonation of delay. Therefore, in the absence of petition for condonation of delay, respective delay should not be condoned in both these appeals. 7. Therefore, I find that in these two appeals, no justification has been submitted for condonation for delay in filing appeals

SURENDRABA RAGHUVIRSINH CHUDASAMA,RAJKOT vs. THE INCOME TAX OFFICER, WARD-3(1)(1), RAJKOT

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

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

section 143(3) r.w.s 147 of the Income tax Act, therefore, it cannot be said that assessee was not effectively pursuing the appeal. Therefore, ld.Counsel for the assessee contended that delay may condoned

VIPUL ARJANBHAI PARMAR,MANGROL vs. INCOME TAX OFFICER, WARD -1, JUNAGADH

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.217/Rjt/2025 िनधा"रण वष"/Assessment Year : 2010-11 बनाम/ Vipul Arjanbhai Parmar Income Tax Officer Vs C/O. Sarda & Sarda (Ca), Sakar, Ward – 1, Junagadh 1St Floor, Dr. Radha-Krishnan Road, Opp. Rajkumar College, Rajkot, Gujarat - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ditpp9286B (अपीलाथ"/Assessee) (""थ"/Respondent)

condone the delay. 8. The grounds of appeal raised by the assessee, on merit, are as follows: “1. The assessment order u/s. 143(3) r.w.s. 147 of the Act is bad in law. 2. The learned Assessing Officer has erred in law as well as on facts for making the addition of Rs. 5,00,000/-on account of unexplained

NILESH ASHANAND THACKER,BHUJ vs. ITO WARD 4, GANDHIDHAM (BHUJ)

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.377/Rjt/2025 (िनधा"रण वष" /Assessment Year: (2012-13) (Physical Hearing) Nilesh Ashanand Thacker, बनाम Income-Tax Officer, Ward-4, / Near-Laxmi Vekari Mahakali Gandhidham (Bhuj-2)-370 201 Vs. Shopping Mall, Jublee Circle, Bhuj, Kutch-300 001(Gujarat) "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adhpt 8610R (अपीलाथ"/ Appellant) (""थ"/Respondent)

section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 08.01.2024, by the National Faceless Appeal Centre (NFAC), Delhi/ Commissioner of Income Tax (Appeals) [in short ‘Ld.CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘AO’) u/s 143(3) r.w.s. 147 of the Act, dated

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

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

delay is condoned in filing the\nappeal.\nPage 3 of 21\nITA No.185/RJT/2025\nBabubhai Kanjibhai Sakariya L/h of Late Smt. Ujiben Kanjibhai Sakariya\n6. Brief facts, as discernible from the orders of lower authorities are that the\nassessee Ujiben Kanjibhai Sakariya (PAN-GDQPS7714N) being an\nindividual filed its return of income for the assessment year (A.Y.) 2016-17,\ndeclaring total

SHRI BECHARBHAI DHARAMSHIBHAI VASOYA,RAJKOT vs. THE ITO WARD 1 (1) (1), RAJKOT, RAJKOT

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

condoned the delay of 508 days, citing the principles of substantial justice and the need for a liberal approach in such matters, as established by various judicial precedents. The appeal was restored to the file of the CIT(A) for a fresh decision on merits.", "result": "Allowed", "sections": [ "250", "143(3)", "147

BHISTI EXPORTS ,VERAVAL vs. INCOME TAX OFFICER WARD-4, VERAVAL

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

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

section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short, ‘the Act’) dated 15.11.2017 and 09.11.2018 respectively. 2. These two appeals filed by the assessee are barred by limitation by 225 days. The assessee moved two separate petitions for condonations of delay

BHISTI EXPORTS ,VERAVAL vs. INCOME TAX OFFICER WARD-4, VERAVAL

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

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

section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short, ‘the Act’) dated 15.11.2017 and 09.11.2018 respectively. 2. These two appeals filed by the assessee are barred by limitation by 225 days. The assessee moved two separate petitions for condonations of delay

SHYAMJIKRUSHNA VARMA TOWNSHIP,RAJKOT vs. THE ITO WARD 2 (1) (1) RAJKOT, RAJKOT

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

147", "Section 144B", "Section 69A", "Section 57"], "issues": "Whether the delay in filing the appeal should be condoned and whether

KRANTI ELECTRIC ENGINEERING PVT. LTD.,RAJKOT vs. THE ITO WARD 2 (1) (4) RAJKOT, RAJKOT

In the result, the appeal of the assessee(ITA No

condoned the delay in filing the appeals, stating that the reason provided by the assessee was convincing. The tribunal noted that the CIT(A)'s order was ex-parte and not speaking, thus not commenting on the merits of the grounds. The matter was remitted back to the assessing officer for fresh adjudication.", "result": "Allowed", "sections": [ "147

RAJENDRASINH RANJITSINH JADEJA,KHAKHADABELA,PADDHARI vs. ITO WD 2(1)(4), RKT, RAJKOT

In the result, appeal filed by the assessee, is allowed, to the extent indicated above

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.459/Rjt/2025 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) Rajendrasinh Ranjitsinh Jadeja Vs. Ito Ward 2 (1) (4), Khakhadabela, Paddhari, Aayakar Bhawan, Race Course Rajkot - 360110 Ring Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agvpj2529E (Appellant) (Respondent) Appellant By : Shri Gaurang Khakhar, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am ; Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2012-13, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income-Tax (Appeals), Dated 26/07/2024, Which In Turn Arises Out Of An Order Passed By The Assessing Officer Dated 25/11/2009 U/S 144 R.W.S 147 Of The Income Tax Act, 1961. 2. Grounds Of Appeal Raised By The Assessee Are As Follows: “1. That The Reasons Recorded U/S 147 Of The I.T. Act, 1961 By The Ld. A.O. Were Merely Based On The Suspicion & Without Any Tangible Material So As To Suggest Any Escapement Of Income. Hence The Reassessment Proceedings Are Liable To Be Quashed Rajendrasinh Ranjitsinh Jadeja

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income-tax (Appeals), dated 26/07/2024, which in turn arises out of an order passed by the Assessing Officer dated 25/11/2009 u/s 144 r.w.s 147 of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

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

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

147 rws 144 and also against the aforesaid penalty order u/s. 270A/271AAC(1) of the Act, before the CIT(A). The ld.CIT(A) has restored the quantum appeal of the assessee, for assessment year 2019– 20, to the file of the assessing officer for fresh adjudication. 9. I have also gone through the petition for condonation of delay

MITHAPUR NUTAN BAL SHIKSHAN SANGH,MITHAPUR vs. INCOME TAX OFFICER - WARD (1), DWARKA, DWARKA

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

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita Nos. 783 To 786/Rjt/2025 (Assessment Year: 2018-19 & 2019-20) (Hybrid Hearing) Mithapur Nutan Bal Shikshan Vs. The Ito, Ward-1, Sangh. Dwarka Sangh Bal Mandir Zanda Chowk, Mithapur-361345 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam0815C (अपीलाथ"/Assessee) (""यथ"/Respondent)

147 rws 144 and also against the aforesaid penalty order u/s. 270A/271AAC(1) of the Act, before the CIT(A). The ld.CIT(A) has restored the quantum appeal of the assessee, for assessment year 2019– 20, to the file of the assessing officer for fresh adjudication. 9. I have also gone through the petition for condonation of delay