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)

2) of the Act. Further, since the delay in filing appeal has been condoned by CIT(Exemption), no question of invoking section 12A(b) arises. In the alternative, the counsel for the assessee submitted that the provisions of section 143(1) of the Act do not encompass within its scope disallowance of expenditure claimed by the assessee in its computation

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)

2 SCR 762], it was laid down that in showing sufficient cause to condone the delay, it is not necessary that the applicant has to explain whole of the period between the date of the judgment till the date of filing the appeal. It is sufficient that the applicant would explain the delay caused by the period between the last

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)

2 SCR 762], it was laid down that in showing sufficient cause to condone the delay, it is not necessary that the applicant has to explain whole of the period between the date of the judgment till the date of filing the appeal. It is sufficient that the applicant would explain the delay caused by the period between the last

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:

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Learned Commissioner of Income Tax (Appeal) [hereinafter referred to as “CIT(A)”], dated 20.10.2023, which in turn arises out of an intimation order passed by CPC, Bengaluru / Assessing Officer u/s 143(1) of the Act, on 25.06.2019. Khadakala Seva Sahkari Mandali Ltd. vs. ITO Grounds

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)

2. Refusing to condone delay can result in a meritorious matter being thrown out at the very threshold and cause of justice being defeated. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties. 3. "Every day's delay must be explained" does not mean

SHRI SHARDAGRAM ALUMNI EDUCATION AND CHARITABLE TRUST,RAJKOT vs. CIT(EXEMPTION), AHMEDABAD, AHMEDABAD

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

15 per cent. Many other similar\nsituations can be contemplated where it would be absurd and unreasonable to apply\nsection 52(2) according to its strict literal construction. We must, therefore, eschew\nliteralness in the interpretation of section 52(2) and try to arrive at an interpretation which\navoids this absurdity and mischief and makes the provision rational and sensible

KANTABEN RAMNIKLAL NAGDA,JAMNAGAR vs. ITO, WARD 2(6), JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita Nos.39/Rjt/2025 ("नधा"रणवष" / Assessment Years: (2014-15) Kantaben Ramniklal Nagda Vs. Ito, Wd- 2(6), Jamnagar Flat No. 603, K D Tower, Oswal Aayakar Bhavan, Nr. Subhash Bridge, Colony, Jamnagar Rajkot Highway, Jamnagar-361004 Jamnagar - 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agtpn7366D (Assessee) (Respondent)

2. Hon'ble CIT (Appeals) erred in law by confirming addition made by Ld A.O. of Rs. 8,34,694/- u/s. 56(vii)(b)(i) on account of alleged difference between actual purchase price and Jantri Value without establishing that purchase is made by appellant by payment of extra money neither by referring the same to valuation officer for evaluation

JITESHBHAI RAMNIKLAL NAGADA,JAMNAGAR vs. ITO, WARD 2(6), JAMNAGAR, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita Nos.39/Rjt/2025 ("नधा"रणवष" / Assessment Years: (2014-15) Kantaben Ramniklal Nagda Vs. Ito, Wd- 2(6), Jamnagar Flat No. 603, K D Tower, Oswal Aayakar Bhavan, Nr. Subhash Bridge, Colony, Jamnagar Rajkot Highway, Jamnagar-361004 Jamnagar - 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agtpn7366D (Assessee) (Respondent)

2. Hon'ble CIT (Appeals) erred in law by confirming addition made by Ld A.O. of Rs. 8,34,694/- u/s. 56(vii)(b)(i) on account of alleged difference between actual purchase price and Jantri Value without establishing that purchase is made by appellant by payment of extra money neither by referring the same to valuation officer for evaluation

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

Appeals of the assessee are allowed for\nstatistical purposes

15 per\ncent. Many other similar situations can be contemplated where it would be absurd and\nunreasonable to apply section 52(2) according to its strict literal construction. We must,\ntherefore, eschew literalness in the interpretation of section 52(2) and try to arrive at an\ninterpretation which avoids this absurdity and mischief and makes the provision rational\nand sensible

JAMNAGAR TAX CONSULTANTS ASSOCIATION,JAMNAGAR vs. THE COMMISSIONER OF INCOME TAX (EXEMPTION), RAJKOT

In the result, this appeal of the assessee is allowed for statistical purposes, in\nabove terms

Section 2(15) of the Income Tax Act, 1961" ], "issues": "Whether the delay in filing the appeal is condonable and whether

FUSION GRANITO PRIVATE LIMITED,MORBI vs. THE PR. COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

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

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.190/Rjt/2023 (िनधा"रण वष" / Assessment Year: (2018-19) (Physical Hearing) Fusion Granito Pvt. Ltd. बनाम/ Principal Commissioner Of Income Revenue Survey No.555/P1/91, Tax-1, Vs. Nr. Khokhra Hanuman Temple, 2Nd Jetpar Road, Morbi-363641 Rajkot, Floor, “Aayakar Bhawan”, Race Course Ring Road, Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcf 0696 B (अपीलाथ"/Appellant) (""थ" /Respondent) अपीलाथ" ओर से/ Appellant By Shri Bandish Soparkar, Ar ""थ" की ओर से/Respondent By Shri Praveen Verma, Cit Dr सुनवाई की तारीख/Date Of Hearing 24/06/2025 घोषणा की तारीख /Date Of Pronouncement 10/09/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax - 1, Rajkot [In Short ‘Ld. Pcit’], Dated 27.03.2023, Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The ‘Act’] For The Assessment Year (Ay) 2018-19. 2. Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: “1. The Revision Order U/S 263 Of The Act Dated 28.03.2023 Is Bad In Law. 2. The Hon’Ble Pr. Cit-1, Rajkot Has Erred In Law As Well As On Facts In Completing The Revision Proceedings U/S 263 Of The Act Hurriedly In Short Span Of Time Fusion Granito Pvt. Ltd.

condonation is made out for explaining the delay in this hopelessly time-barred appeal. The appeal is, accordingly, liable to be dismissed on the ground of delay. Fusion Granito Pvt. Ltd. 12. Therefore, ld DR stated that since the order passed by the learned PCIT has been merged with the order of the Commissioner of Income tax (appeals), hence, present

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

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

15-11- 2017 u/s. 144C(1) of the Act and duly served on the assessee on 16-11-2017. 3.1. As per Section 144C(2) of the Act, within 30 days of the receipt of the draft assessment order, the assessee is supposed to (a) file his acceptance of the variations to the Assessing Officer, or (b) file his objections

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

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Commissioner of Income-tax (Appeals), dated 15.03.2024 & 13.06.2024, which in turn arise out of intimation orders passed by CPC, Bengaluru / Assessing Officer u/s 143(1) of the Act, on 25.06.2019 & 01.05.2020; respectively. 2. Grounds of appeal raised by the assessee in ITA No.200/Rjt/2025

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

section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Commissioner of Income-tax (Appeals), dated 15.03.2024 & 13.06.2024, which in turn arise out of intimation orders passed by CPC, Bengaluru / Assessing Officer u/s 143(1) of the Act, on 25.06.2019 & 01.05.2020; respectively. 2. Grounds of appeal raised by the assessee in ITA No.200/Rjt/2025

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

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

15, are barred by limitation of 81 days ITA Nos.519 & 521/Rjt/2025 (AY 13-14 & 14-15) Jivanbhai D Sarla (each appeal). In both the appeals, assessee filed respective petitions for condonation of delay, requesting the Bench to condone the relay. In both the petitions, for condonation of delay, the contents and facts are identical and similar, therefore, we shall adjudicate

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

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

15, are barred by limitation of 81 days ITA Nos.519 & 521/Rjt/2025 (AY 13-14 & 14-15) Jivanbhai D Sarla (each appeal). In both the appeals, assessee filed respective petitions for condonation of delay, requesting the Bench to condone the relay. In both the petitions, for condonation of delay, the contents and facts are identical and similar, therefore, we shall adjudicate

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

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

15-08- 2024. Thus, due to ignorant of particular provision of law and absence of concern person it caused delay of 120 days in filling of appeal. Therefore, there is reasonable cause in delay of filling appeal > Due to this order your appellant faces many hardships to run the business. > There are so many judgments in which juridical authorities have

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

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

15-08- 2024. Thus, due to ignorant of particular provision of law and absence of concern person it caused delay of 120 days in filling of appeal. Therefore, there is reasonable cause in delay of filling appeal > Due to this order your appellant faces many hardships to run the business. > There are so many judgments in which juridical authorities have