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

147, as the case may be, with\nrespect to the cases referred to in sub-section (2), shall be made in a faceless manner\nas per the following procedure, namely:\n(xvi) the National Faceless Assessment Centre shall examine the draft assessment\norder in accordance with the risk management strategy specified by the Board,\naccording to which, in case

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

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 18.06.2025 & 17.06.2025, which in turn arise out of separate orders passed by the Assessing Officer u/s 147 r.w.s. ITA Nos. 498 & 499/Rjt/2025 Gopal Snacks Pvt. Ltd. vs. ACIT 2 144B

PALLAV,JAMNAGAR vs. DCIT, CIRCLE 2, JAMNAGAR

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

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

depreciation etc. In such a case, the provisions of Section 147 of the Act, would be applicable and the assessment

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

section 250 of the Income Tax Act, 1961 (hereinafter referred\nto as \"the Act\") by National Faceless Appeal Centre (NFAC), Delhi /\nCommissioner of Income-tax (Appeals), dated 18.06.2025 & 17.06.2025, which in\nturn arise out of separate orders passed by the Assessing Officer u/s 147 r.w.s.\n144B of the Act, on 29.03.2022 and u/s. 143(3) r.w.s. 144B

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating\ninto order u/s 147

ALPHA HI-TECH FUEL LTD.,,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, SNR CIRCLE,, SURENDRANAGAR

In the result the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकरअपीलसं./I.T.A. No.68/Rjt/2009 (धििाधरणणवध/ Assessment Year 2005-06) Alpha Hi-Tech Fuel Limited, बिाम/ D.C.I.T, Station Road, Surendranagar Vs. Lakhtar, Dist. Surendranagar, Gujarat-382775 स्ायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaaca4258P (अपीला््/Appellant) (प्य््/ Respondent) अपीला््थरसे/ Appellant By : Shri Kalpesh Doshi, A.R Shri B.D Gupta, Sr. D.R. प्य््करथरसे/Respondent By: सुिणाईकरतारीख/ Date Of Hearing 08/06/2023 घोवणाकरतारीख/Date Of Pronouncement 05/09/2023 आदेश/ O R D E R Per Waseem Ahmed:

depreciation claimed by the assessee in different year as well as the deductions claimed under section 80I and 80JJA the of the Act in the earlier assessment years. Thus, the period of 10 years for claiming the benefit of deduction under section 80-IA(4) of the Act has already expired from the initial assessment year. 5.1 The AO also

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT., RAJKOT

depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n\"1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating\ninto order u/s 147

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE -2, RAJKOT, RAJKOT

depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating\ninto order u/s 147

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating\ninto order u/s 147

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

depreciation.\n[This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19]\n4. Now we shall take above, summarised and concise ground of appeals, of\nassessee and revenue, as follows.\n5. The summarised and concise ground No.1, is reproduced below for ready\nreference.\n“1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating\ninto order u/s 147

RAJKOT DISTRICT CO-OP. BANKS EMPLOYEES M P CREDIT CO-OP. LTD.,RAJKOT vs. THE DCIT/ACIT CIR 1(1), RAJKOT

In the result, appeal of the assessee is allowed

Depreciation Fund Exp.\n4,11,045.00\nMember's Gift Exp.\n2,25,020.00\nDepreciation\n4,23,927.00\nLess:\nIncome from Other Head\n(-)18,93,786.00\nInterest Income\n18,41,436.00\nDividend Income\n52,350.00\nB\nSection 80P(2)(d) - Interest or dividend from its investment with any\nother co-operative society\nInterest Income from other Co-operative\nBank

AMRELI JILLA MADHYASTH SAHAKARI BANK LTD.,AMRELI vs. THE DCIT-ACIT-2(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.548/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Amreli Jilla Madhyasth Sahakari The Dcit/Acit-2(1) बनाम Bank Ltd. Rajkot. Bhojalram Bhavan Vs. Rajmahel Road Amreli 365 601. Pan : Aaata 2737 J (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

147 r.w.s. 144r.w.s. 144B of the Act and the notice u/s 148 is bad in law. 2.The Learned Commissioner of Income-tax (Appeals), Income Tax Department NFAC, Delhi erred in sustaining the disallowance of claim of deduction of Rs.57,00,750/- made by the Appellant u/s 36(l)(viia) of the Act in the return of income filed

SAMANVYA EDUCATION & CHARITABLE TRUST,DHORAJI, DIST. RAJKOT vs. THE INCOME TAX OFFICER(EXEMPTION)-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकरअपीलसं./Ita No. 16/Rjt/2021 धििाधरणणवध/Asstt. Year:2015-2016 Samanvya Education & Charitable Vs. The Income Tax Officer, Trust, (Exemption)-1, Nr. Bhola Darshan Apt., Ward-1, Station Road, Rajkot. Junagadh Road, Dhoraji-360410. Pan: Aajts8062M (Applicant) (Respondent) Assessee By : Shri Samir Divetia, A.R Revenue By : Shri Shramdeep Sinha, Cit. Dr सुिणाईकीतारीख/Date Of Hearing : 13/12/2023 घोवणाकीतारीख/Date Of Pronouncement: 20/12/2023 आदेश/O R D E R Per Waseem Ahmed:

Section 263 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2015-16. A.Y. 2015-16 2 2. The only issue raised by the assessee is that the Ld. PCIT erred in holding assessment framed u/s 143(3) of the Act as erroneous in so far prejudicial to the interest

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

SHRI KANJIBHAI B. RANGANI,,RAJKOT-GUJARAT vs. THE INCOME TAX OFFICER, WARD-5(1), RAJKOT-GUJARAT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

147 of the Act and a notice u/s 148 was issued on 17-02- 2010. An addition of Rs. 36,34,125/- being Capital Gain on sale of land was added to the total income of the assessee and the assessment was finalized on 24-12-2010 at assessed income of Rs. 37,55,020/-. The then

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

147, the reply becomes null and void.\n5. Show cause notice was issued to the assessee on 11-09-2021 and the date of compliance has been fixed as 16-09-2021. In compliance of the above, the assessee filed his reply on 16-09-2021. The assessee has submitted his reply of more than 600 pages. Earlier, the assessee

SALIM ABDULLAH RATHOD,MUNDRA vs. DY COMMISSIONER OF INCOME TAX, GANDHIDHAM CIRCLE

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

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 277/Rjt/2023 ("नधा"रणवष"/Assessment Year: (2012-13) Salim Abdullah Rathod, Dy Commissioner Of Income Tax, 6316, Swami Vivekanand Nagar New Vs. Gandhidham Kutch, Gujarat Swaminarayan Temple Road Bhutda 370465 Wadi, Gujarat, 370465 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Adnpp3110E (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section-250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Learned Commissioner of Income-tax (Appeal), (in short ‘Ld. CIT(A)’), dated 16.05.2023, which in turn arises out of assessment order passed by Assessing Officer u/s. 147 r.w.s. 144 of the Act on 27.02.2015. Salim Abdullah Rathod v. DCIT 2. The grounds of appeal

AMARDEEP EXPORTS,JAMNAGAR vs. INCOME TAX OFFICERWARD 1(3), JNR, JAMNAGAR

In the result, the appeal is dismissed

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

147 r.w.s. 144 and 144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), vide order dated 19.03.2022. 2. Grounds of appeal raised by the assesse, are as follows: “1.On the facts and in the circumstances of the case and in law the learned CIT(A)- NFAC has erred in confirming the addition