M/S. SURENDRANAGAR DISTRICT CO-OP. MILK PRODUCERS UNION LTD. ,SURENDRANAGAR vs. THE DCIT, SURENDRANAGR CIRCLE,, SURENDRANAGAR

Appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./I.T.A. No.262-263/Rjt/2018 ("नधा"रण वष" / Assessment Years: 2012-13 & 2013-14) बनाम/ M/S.Surendranagar District D.C.I.T, Co-Op. Milk Producers Surendranagar Circle, Vs. Union Ltd. Surendranagar. Wadhwan City, Surendranagar "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaas8375B (अपीलाथ" /Appellant) .. (""यथ" / Respondent) अपीलाथ" ओर से / Appellant By : Shri Kalpesh Doshi, A.R ""यथ" क" ओर से/Respondent By : Shri Jitender Kumar, Dr सुनवाई क" तार"ख / Date Of Hearing 17/09/2019 घोषणा क" तार"ख /Date Of Pronouncement 20/09/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Appeals Have Been Filed At The Instance Of The Assessee Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals)-7, Ahmedabad [Ld. Cit(A) In Short] Of Even Dated 12/01/2018, Arising In The Matter Of Assessment Order Passed Under 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 26/03/2015 Relevant To Assessment Years (A.Ys) 20012-13 & 2013-14. Ita Nos.262-263/Rjt/2018 A.Y.S 2012-13 To 2013-14 First, We Take Up Ita No. 262/Rjt/2018 For A.Y. 2013-14

6,13,744.00 only. Accordingly the AO disallowed the same and added to the total income of the assessee. Aggrieved assessee preferred an appeal to the learned CIT (A). ITA Nos.262-263/RJT/2018 A.Y.s 2012-13 to 2013-14 9. The assessee before the learned CIT (A) submitted that the impugned cash payment represents the expenses incurred in the routine manner

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

b) to section 43(6)(c) cannot be invoked. 27. The ld. CIT(A) further noticed that the judgement of the Hon'ble Supreme Court in the case of CIT v. Mansukh Dyeing and Printing Mills [(2022) 145 taxmann.com 151] is not applicable to the facts of the assessee`s case since the said decision is pertaining to reconstitution

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 6

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)

section 195, as no sum in the hands of the recipients, is chargeable under the Act. The Ld. Counsel submitted that the decisions of AAR are applicable only to the petitioner before AAR and there is express bar against the applicability of AAR's decision, as a precedent in other cases and therefore, the assessing officer has grossly erred

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)

section 195, as no sum in the hands of the recipients, is chargeable under the Act. The Ld. Counsel submitted that the decisions of AAR are applicable only to the petitioner before AAR and there is express bar against the applicability of AAR's decision, as a precedent in other cases and therefore, the assessing officer has grossly erred

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)

section 195, as no sum in the hands of the recipients, is chargeable under the Act. The Ld. Counsel submitted that the decisions of AAR are applicable only to the petitioner before AAR and there is express bar against the applicability of AAR's decision, as a precedent in other cases and therefore, the assessing officer has grossly erred

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)

section 195, as no sum in the hands of the recipients, is chargeable under the Act. The Ld. Counsel submitted that the decisions of AAR are applicable only to the petitioner before AAR and there is express bar against the applicability of AAR's decision, as a precedent in other cases and therefore, the assessing officer has grossly erred

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)

section 195, as no sum in the hands of the recipients, is chargeable under the Act. The Ld. Counsel submitted that the decisions of AAR are applicable only to the petitioner before AAR and there is express bar against the applicability of AAR's decision, as a precedent in other cases and therefore, the assessing officer has grossly erred

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

6 crores only. Furthermore, it was also explained that none of the partner was taking active participation in the affairs of eligible unit. Moreover, there was no loss to the revenue for the reason that the amount of remuneration received by the partners is taxable in their hands subject to the provisions of section 40(b

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

6 crores only. Furthermore, it was also explained that none of the partner was taking active participation in the affairs of eligible unit. Moreover, there was no loss to the revenue for the reason that the amount of remuneration received by the partners is taxable in their hands subject to the provisions of section 40(b

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.185/Rjt/2023

43(1) of the Act. The dropping of penalty in respect of amortization expenses has resulted into loss to the revenue as the amount of penalty would have positive revenue impact as per the provisions of Section 270A(10b) of the Act, which states that where the total income determined under clause (a) of sub-section (1) of section

THE DY. COMMR. OF INCOME TAX, CIRCLE-1,, JAMNAGAR vs. M/S. DEEP RECYCLING IND.,, JAMNAGAR

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

6. The ld DR before us vehemently supported the order of AO. 7. On the other hand, the ld AR before us filed a paper book which is running from pages 1-67 and reiterated the submissions as made before the ld CIT(A). 8. We have heard the rival contentions and perused the materials available on record

THE ACIT, CIRCLE-2,, JAMNAGAR vs. M/S. DEEP RECYCLOING INDUSTRIES,, JAMNAGAR

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

6. The ld DR before us vehemently supported the order of AO. 7. On the other hand, the ld AR before us filed a paper book which is running from pages 1-67 and reiterated the submissions as made before the ld CIT(A). 8. We have heard the rival contentions and perused the materials available on record

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

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

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

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

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

depreciation. [This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19] 4. Now we shall take above, summarised and concise ground of appeals, of assessee and revenue, as follows. 5. The summarised and concise ground No.1, is reproduced below for ready reference. “1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating into order

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

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

depreciation. [This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19] 4. Now we shall take above, summarised and concise ground of appeals, of assessee and revenue, as follows. 5. The summarised and concise ground No.1, is reproduced below for ready reference. “1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating into order

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

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

depreciation. [This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19] 4. Now we shall take above, summarised and concise ground of appeals, of assessee and revenue, as follows. 5. The summarised and concise ground No.1, is reproduced below for ready reference. "1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating into order

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

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

depreciation. [This is ground No.6 in ITA N0.546/Rjt/2024 A.Y.2018-19] 4. Now we shall take above, summarised and concise ground of appeals, of assessee and revenue, as follows. 5. The summarised and concise ground No.1, is reproduced below for ready reference. “1.Ground No.1. The Ld.CIT(A) erred in holding that proceedings u/s 148 culminating into order