BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2, RAJKOT, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

revised the assessment order, therefor Asst. Year 2010-11 cannot be taken as a base to allow the appeal of the assessee. 27. The Ld. CIT-D.R. further submitted that the assessee is not engaged in production of manufacture in Rudrapur unit, as the assessee purchased the semi- finished goods from Rajkot unit and sends it to Rudrapur unit

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

revised the assessment order, therefor Asst. Year 2010-11 cannot be taken as a base to allow the appeal of the assessee. 27. The Ld. CIT-D.R. further submitted that the assessee is not engaged in production of manufacture in Rudrapur unit, as the assessee purchased the semi- finished goods from Rajkot unit and sends it to Rudrapur unit

M/S. SIMERO VITRIFIED P. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

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

revision u/s 263 was passed on 13.09.2016 and AO was directed to re-assess the income of the assessee depicting the following issues:\n(a) Share Capital introduced during the year under consideration;\n(b) Unsecured Loans (squared up or not) raised during the year;\n(c) Sundry Creditors, and\n(d) Sustainability of claim u/s 32AC\n3. Accordingly

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2(1), RAJKOT, RAJKOT

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ADDI. CIT, RANGE-2, RAJKOT, RAJKOT

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee.\n27.\nThe

ASSISTANT COMMISSINER OF IINCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee.\n27.\nThe

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised the assessment order, therefor Asst.\nYear 2010-11 cannot be taken as a base to allow the appeal of the assessee

ASSTT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), , RAJKOT vs. SYMBOSA GRANITO PRIVATE LIMITED, WANKANER

263 r.w.s 144B of\nthe Income Tax Act 1961 for the assessment year(A.Y.) 2016-17 of the\nassessing officer of making addition of Rs. 7,78,97,000/- on account of share\ncapital and Rs. 57,61,000/- on account of unsecured loans u/s 68 of the Act, and\nthis is a second inning before us. Learned

M/S. EMBOZA GRANITO PVT. LTD. ,MORBI vs. THE PR. CIT-3 , RAJKOT

In the result, appeal filed by assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 240/Rjt/2019 िनधा"रण वष"/Asstt. Years: 2016-2017

depreciation of Rs.6.25 crores on plant and machinery installed during the year under consideration and (3) deduction claimed on account of investment allowance u/s.32AC of the Act of Rs.5.11 crores and thereby setting aside the order passed u/s.143(3} of the Act dated 21.12.2018. The order passed u/s 263 of the Act by the learned Pr. CIT is totally unjustified

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

u/s 143(3) of the Act, on 15/04/2021 for the A.Y. 2018-19, is erroneous in so far as it is prejudicial to the interest of the revenue within the meaning of the provisions of section 263 of the Act. Therefore, ld. PCIT directed the assessing officer to examine and investigate and to verify these various expenses, as claimed

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

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

u/s 143(3) of the Act, on 15/04/2021 for the A.Y. 2018-19, is erroneous in so far as it is prejudicial to the interest of the revenue within the meaning of the provisions of section 263 of the Act. Therefore, ld. PCIT directed the assessing officer to examine and investigate and to verify these various expenses, as claimed

GOJIYA BHIKHUBHAI,JAMNAGAR vs. PRINCIPAL COMMISSIONEROF INCOME TAX, JAMNAGAR

u/s 143(3) of the Act, on 15/04/2021 for the A.Y. 2018-19, is erroneous\nin so far as it is prejudicial to the interest of the revenue within the meaning of\nthe provisions of section 263 of the Act. Therefore, ld. PCIT directed the\nassessing officer to examine and investigate and to verify these various\nexpenses, as claimed

SURENDRANAGAR DISTRICT CO OP PRODUCERS UNION LIMITED,SURENDRANAGAR vs. ASSISTANT COMMISSIONER OF INCOME TAX, SURENDRANAGAR CIRCLE

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 429/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2014-15) Surendranagar District Co. Op. Acit, Circle, Producers Union Ltd. Vs. Surendranagar-363035 Plot No.249, Phase 2 Gidc Market Yard Circle, Sursagar Dairy, Wadhwan Road, Surendranagar-363035 (Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaas8375B (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : Heard On 09/10/2025, Refixed For Clarification On 03.11.2025 & Finally Heard On 02.02.2026 : 10/02/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, A.M.:

depreciation, the net income of Rs. 92,40,586/- has been shown. The net business income is claimed as deduction u/s 80P(2)(b) of the Act, in the return filed by the assessee. However, during the course of assessment proceedings, the deduction of interest is disallowed and the net interest income of Rs. 34,79,487/- has been treated

RAJSHANTI METALS PVT. LTD.,,JAMNAGAR vs. THE PR. COMMR. OF INCOME TAX,, JAMNAGAR

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 176/Rjt/2016 िनधा"रण वष"/Asstt. Years: 2011-2012 Rajshanti Metals Pvt. Ltd., The Principal Commissioner Of B-42, Gidc, Vs. Income Tax, Shankar Tekri, Jamnagar. Jamnagar.

263 proceedings are invalid when AO had made enquiries and taken a plausible view in law, with the following observations: “Having heard learned counsel for the parties and having perused the documents on record, we see no reason to interfere with the view of the Tribunal. The question whether the income should be taxed as business income or as arising

SAURASHTRA GRAMIN BANK MANAGER (F & A), RAJKOT,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX-I,, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 37/Rjt/2022 (Assessment Year: 2017-18) (Hybrid Hearing) Saurashtra Gramin Bank Vs. The Pr. Cit-1, Manager (F & A), Rajkot 1St Floor Wing 2, Lic Jeevan Prakash Building, Tagore Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahas2116H (अपीलाथ"/Appellant) (""यथ"/Respondent)

revision u/s 263 of the Income tax Act. 10. In response to the above show cause notice, the assessee has submitted a detailed reply before learned PCIT on 22/12/2021. The assessee submitted about provision of Rs. 20,78,36,400/- on account of Investment Depreciation

KONARK OVERSEAS PRIVATE LIMITED,GANDHIDHAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE, GANDHIDHAM

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

revision order u/s. 263 of the\nAct on 21.03.2017 and set-aside the original assessment order passed u/s. 143(3)\nfor de-novo assessment in respect of few specific issues.\nConsequently, the de-novo assessment order u/s. 143(3) r.w.s. 263 of the\nAct was passed on 12.09.2017 determining total income at Rs.85,55,290/-which\nincluded addition