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

b) On the facts and under the circumstances of the case the penalty levied under section 271(1)(c) of the Act is void as no specific notice u/s 274 has been issued by the AO. c) On the facts and circumstances of the case the penalty order is bad in law as the approval of JCIT dated

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

b) On the facts and under the circumstances of the case the penalty levied under section 271(1)(c) of the Act is void as no specific notice u/s 274 has been issued by the AO. c) On the facts and circumstances of the case the penalty order is bad in law as the approval of JCIT dated

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

b) On the facts and under the circumstances of the case the penalty levied under section 271(1)(c) of the Act is void as no specific notice u/s 274 has been issued by the AO. c) On the facts and circumstances of the case the penalty order is bad in law as the approval of JCIT dated

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

b) On the facts and under the circumstances of the case the penalty levied under section 271(1)(c) of the Act is void as no specific notice u/s 274 has been issued by the AO. c) On the facts and circumstances of the case the penalty order is bad in law as the approval of JCIT dated

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

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

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

271(1)(c) of the Act, then assessee came to know about the passing of the impugned order u/s 250 of the Act, on 20/03/2025. Therefore, ld. Counsel submitted that the delay of 81 days in filing the appeal took place, for which the assessee explained sufficient cause, there were no intentional latches on the part of assessee, hence delay

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

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

271(1)(c) of the Act, then assessee came to know about the passing of the impugned order u/s 250 of the Act, on 20/03/2025. Therefore, ld. Counsel submitted that the delay of 81 days in filing the appeal took place, for which the assessee explained sufficient cause, there were no intentional latches on the part of assessee, hence delay

KISHORBHAI CHHAGANBHAI ANDIPARA,GONDAL vs. ITO, WARD-1(1)(1), RAJKOT, RAJKOT

In the result, both the appeals are dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

271(1)(b) of the Act is totally unjustified on facts as also in law may kindly be deleted. 4. The Ld. CIT (A) ought to have deleted the penalty of Rs.30,000/- levied u/s.271(1)(b) of the Act.” 3. There is a delay in filing the appeal of 281 days which has been explained by the assessee through

KIRANBEN KISHORBHAI ANDIPARA,GONDAL vs. ITO, WARD-1(2)(1), RAJKOT

In the result, both the appeals are dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

271(1)(b) of the Act is totally unjustified on facts as also in law may kindly be deleted. 4. The Ld. CIT (A) ought to have deleted the penalty of Rs.30,000/- levied u/s.271(1)(b) of the Act.” 3. There is a delay in filing the appeal of 281 days which has been explained by the assessee through

SHRI BHAKTINAGAR CO OP HOUSING SOCIETY LTD,RAJKOT vs. COMMISSIONER OF INCOME TAX (APPEALS), DELHI

In the result the appeal of the assessee is dismissed in limine

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

section 80P(2)(a)(i)/80P(2)(d) of the Act. The issue of taxability of interest earned from surplus funds decided by the Hon'ble Supreme Court 283/188 Taxman 282, wherein it was held that the assessee being co-operative society in the case of Totgars' Co-operative Sale Society Ltd. vis. ITO [20101 322 ITR is engaged

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

271(1)(c) for A.Y. 2016-17 dated 29.06.2025 wherein it was mentioned "you had preferred appeal which has been disposed of by the 1st appellate authority, i.e. CIT(A)." On perusal of this notice, the assessee immediately approached the consultant. Therefore, in this process, the delay of 80 days has occurred, which may kindly be condoned. 4. Learned

M/S. VINAYAKA REALTY (G) PVT. LTD.,RAJKOT vs. THE ITO WARD-1 (2) (5), RAJKOT, RAJKOT

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

Bench: Ms. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section I.T.A No. 108/Rjt/2021 A.Y. 2011-12 Page No 2 Vinayaka Realty (G) Pvt. Ltd. vs. ITO 271(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2011-12. 2. The brief facts of the case is that the assessee is a Company engaged in the business of Civil

HETALKUMAR BHUPENDRABHAI JOSHI,RAJKOT vs. ITO, WARD-2(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 861 & 863/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Hetalkumar Bhupendrabhai Joshi. Vs. The Ito, Ward-2(2)(1), Vijay Villa, C/O, Kankrai L Mehta, Rajkot. 5-Mahavir Society Nirmala Road, Rajkot-360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agspj0840P (अपीलाथ"/Appellant) (""यथ"/Respondent)

condoning the delay in filling the appeal. The appeal may kindly be directed to be decided on merits. 4) The Ld. CIT(A) erred on facts as also in law in not deciding grounds of appeal related to validity of notice issued u/s 148 of the Income Tax Act, 1961. That on facts as also in law, proceedings-initiated

HETALKUMAR BHUPENDRABHAI JOSHI,RAJKOT vs. ITO, WARD-2(2)(1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 861 & 863/Rjt/2024 (Assessment Year: 2013-14) (Hybrid Hearing) Hetalkumar Bhupendrabhai Joshi. Vs. The Ito, Ward-2(2)(1), Vijay Villa, C/O, Kankrai L Mehta, Rajkot. 5-Mahavir Society Nirmala Road, Rajkot-360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agspj0840P (अपीलाथ"/Appellant) (""यथ"/Respondent)

condoning the delay in filling the appeal. The appeal may kindly be directed to be decided on merits. 4) The Ld. CIT(A) erred on facts as also in law in not deciding grounds of appeal related to validity of notice issued u/s 148 of the Income Tax Act, 1961. That on facts as also in law, proceedings-initiated

JITENDRABHAI DEVAJIBHAI BODAR,RAJKOT vs. INCOME TAX OFFICER, WARD-2(1)(1), RAJKOT, RAJKOT

In the result, the appeal is dismissed as not admitted”

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

b), 271(1)(c), 271F of the Act” 3. Brief facts of the case are that the assessee filed his return of income for the A.Y. 2013-14 on 25.01.20214 in the prescribed Form, ITR-4 declaring total income of Rs.4,29,650/-, (including income earned from Commission and Interest Income), after deduction under chapter VI of Rs.1

SHRI BHARATKUMAR IASHWARBHAI BHATIYA,RAJKOT vs. THE ACIT, CENTRAL CIRL-1,, RAJKOT

In the result, appeals filed by the Revenue, in ITA No

Bench: Dr. Arjun Lal Saini & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 134 & 135/Rjt/2023 (िनधा"रणवष" / Assessment Years: (2007-08 & 2008-09) Income Tax Officer, Ward- Shri Kherajmal Lekhrajbjai 5Th 1(2)(1), Aaykar Bhavan, Thavrani, 4- Parsana Nagar, Shri Vs. Floor, Room No. 517, Race Vaheguru Grupa, Near Refugee Course Ring Road, Rajkot-360 Colony, Rajkot-360 001 001 "थायी लेखा सं./जी आइ आर सं./Pan/Gir No.: Adrpt 5807 E (Appellant) (Respondent)

271 (1)(c) of the IT Act is initiated for concealing the particulars of income." 3.12.2. Same finding has been given by the A.O. for the other assessment years in all the case of above mentioned appellant. During the appellate proceedings, the appellant filed detailed submission against the additions made. The appellant contended that they are engaged in the business

BALVANTRAI AMRUTBHAI VYAS,RAJKOT vs. THE ITO WARD-2(1)(1), RAJKOT., RAJKOT

Appeal is dismissed as “not pressed

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

B-21, Shantiniketan Aayakar Bhavan, Race Course Residency, Nr. Aalap Greem City, Ring Road, Rajkot – 360001 Raiya Road, Rajkot-360007 स्थायीलेखासं./जीआइआरसं./PAN/GIR No.: ALLPV2034K (Appellant) (Respondent) Appellant by : Shri Ms. Devina Patel, Ld. AR Respondent by : Shri Abhimanyu Singh Yadav, Ld. Sr. DR Date of Hearing : 16/01/2026 Date of Pronouncement : 30/01/2026 आदेश / O R D E R Per, Dinesh

M/S. KALPATARU CREDIT CO-OPRATIVE SOCIETY,RAJKOT vs. THE INCOME TAX OFFICER, WARD-1 (1)(1), RAJKOT, RAJKOT

In the result, the matter is set aside to the file of the assessing officer with the above directions

Bench: The Hearing Of Appeal.

delay in filing the appeal by the assessee is hereby being condoned. 4. On merits, the brief facts of the case are that the AO reopened the case of the assessee under section 147 of the Act on the basis that the Revenue is in possession of information that the assessee purchased cheque/DD in lieu of cash to the tune