THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

1)(iii) of Rs.3,16,82,477/- though the assessee had made interest free advances out of interest bearing funds. This is ground No.3 of revenue`s appeal in ITA No. 233/RJT/2016 for assessment year 2009–10. Similar and identical grounds in other appeals of the revenue are as follows: (a)Ground No.3 in revenue`s, appeal

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

1)(iii) of Rs.3,16,82,477/- though the assessee had made interest free advances out of interest bearing funds. This is ground No.3 of revenue`s appeal in ITA No. 233/RJT/2016 for assessment year 2009–10. Similar and identical grounds in other appeals of the revenue are as follows: (a)Ground No.3 in revenue`s, appeal

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

1)(iii) of Rs.3,16,82,477/- though the assessee had made interest free advances out of interest bearing funds. This is ground No.3 of revenue`s appeal in ITA No. 233/RJT/2016 for assessment year 2009–10. Similar and identical grounds in other appeals of the revenue are as follows: (a)Ground No.3 in revenue`s, appeal

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM-KUTCH

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

1)(iii) of Rs.3,16,82,477/- though the assessee had made interest free advances out of interest bearing funds. This is ground No.3 of revenue`s appeal in ITA No. 233/RJT/2016 for assessment year 2009–10. Similar and identical grounds in other appeals of the revenue are as follows: (a)Ground No.3 in revenue`s, appeal

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

1)(iii) of Rs.3,16,82,477/- though the assessee had made interest free advances out of interest bearing funds. This is ground No.3 of revenue`s appeal in ITA No. 233/RJT/2016 for assessment year 2009–10. Similar and identical grounds in other appeals of the revenue are as follows: (a)Ground No.3 in revenue`s, appeal

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

depreciation i.e. (a) Rs.32,22,897/- and 10% average advances of nRs.3,92,33,51,000/- i.e. (b)_ Rs.39,23,35,100/-, total (a) plus (b) Rs.39,55,57,997/- or (ii) Rs.NIL being provision debited to profit & loss account plus Rs.57,00,750/- being 15% of profit & loss appropriation amount of Rs.3

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)

26-11-2008. 4. Learned PCIT grossly failed to consider the deductions allowable as per the Statute under section 36(1)(viii), 36(1)(v) and 36(1)(viia) amounting to Rs. 46,83,83,284/-. 5. Learned PCIT has failed to consider the fact that your Honour's assessee is a Regional Rural Bank required to furnish details with

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. GANDHI REALITY (INDIA) PRIVATE LIMITED, RAJKOT

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

iii). The said consideration was issued and paid based on the valuation of Transferor Companies and share exchange ratio determined by the valuer. (iv). Subsequently, the amalgamated company, M/s J. B. Realty Pvt Ltd, has changed its name to M/s Gandhi Realty (India) Pvt Ltd, vide Certificate of Incorporation, pursuance to change of name of MCA Gujarat (India), dated

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

depreciation of Rs. 19,15,32,208/-, as per I.T. Act. Further, the company has increased its profit by Rs. 1,87,86,147/- (Rs. 21,03,18,355/- less Rs. 19,15,32,208/-) in income tax return (ITR). In support of this, the assessee has submitted before the assessing officer the copy of computation of income for assessment

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.

section 142(1) of the Act dated 31-01-2014 2. Please furnish N.P./turnover and GP/turnover ratio for the AYs 2009-10, 2010-11 and 2011-12 with reason for decline. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 7. Please furnish complete postal addresses and confirmation of new unsecured loan. XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX 9. Books of accounts alongwith stock registers. Reply dated 15-02-2014: 2. Gross

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

iii) it should not produce the items which is not specified in\nSection 80IC of the Act. The Learned DR for the revenue contended that by\nand large, these conditions were not satisfied by the assessee, under\nconsideration.\n29. The Ld. CIT-D.R. for the Revenue also submitted written submissions\nbefore the Bench, on the terminology and definition

THE ACIT, CIRCLE-1,, JAMNAGAR vs. M/S. SENOR METALS PVT. LTD., JAMNAGAR

In the results the appeal of the revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Suchitra Raghunath Kambleआयकर अपील सं./Ita No. 260/Rjt/2015 िनधा"रण वष"/Asstt. Year:2011-12

Depreciation Related to Mfg. 67 68 087 77 55 982 1 73 60 002 1 93 45 151 (Increase )/Decrease in stock Opening stock By product 1 28 206 2 86 589 Work in process 5 86 46 481 6 63 78 651 Finished goods 1 11 79 254 77 63 967 Total

THE ASSTT. COMMR. INCOME TAX, CEN. CIRCLE-2,, RAJKOT-GUJARAT vs. M/S BACKBONE ENTERPRISES LTD.,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

26 Backbone Enterprise Ltd. vs. DCIT & ACIT vs. Backbone Enterprise Ltd. “11.8 The contract at Sr. No. 9 was between Gujarat State Road Development ion Ltd. and the appellant for construction of additional 2-Lane of Bharuch- Dahej Road to make Bharuch-Dahej (SH-6) as Lane Road. The terms and conditions of the agreement included complete work including

BACKBONE ENTERPRISE LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. INCOME TAX, CEN. CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

26 Backbone Enterprise Ltd. vs. DCIT & ACIT vs. Backbone Enterprise Ltd. “11.8 The contract at Sr. No. 9 was between Gujarat State Road Development ion Ltd. and the appellant for construction of additional 2-Lane of Bharuch- Dahej Road to make Bharuch-Dahej (SH-6) as Lane Road. The terms and conditions of the agreement included complete work including

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

M/S. MADHURAM CONSTRUCTION CO. JUNAGADH,JUNAGADH vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

section 263 of the\nIncome Tax Act, 1961. On perusal of records, it was noticed by the ld.\nPCIT, that during the previous year 2015-16, relevant to assessment year\n(A.Υ.) 2016-17, the assessee had claimed labour expenses of\nRs.8,50,39,942/- (approximately 19 % of contract work income) in the\nprofit and loss account

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

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

26,60,862 (13,00,93,467 + 4,25,67,395) is required to be disallowed u/s 40(a)(ia) of Act and added to your total income. 3.2 Further, on verification of the records, it is noticed that the you have debited P&L account with Rs. 1,36,50,985/- as direct Expenses w.r.t. ROW expenses being

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

26,60,862 (13,00,93,467 + 4,25,67,395) is required to be disallowed u/s 40(a)(ia) of Act and added to your total income. 3.2 Further, on verification of the records, it is noticed that the you have debited P&L account with Rs. 1,36,50,985/- as direct Expenses w.r.t. ROW expenses being

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

iii) it should not produce the items which is not specified in\nSection 80IC of the Act. The Learned DR for the revenue contended that by\nand large, these conditions were not satisfied by the assessee, under\nconsideration.\n29. The Ld. CIT-D.R. for the Revenue also submitted written submissions\nbefore the Bench, on the terminology and definition