SHRI JAYANTILAL P. SATIKUNVER,,RAJKOT-GUJARAT vs. THE COMMISSIONER OF INCOME TAX-III,, RAJKOT-GUJARAT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./I.T.A. No.469/Rjt/2014 ("नधा"रण वष" / Assessment Year 2010-11)

section 80-IA of the Act. However, the ld. CIT found that 1 There was no separate book of account maintained by the assessee with respect to the windmill business. 2 Against the income of windmill, the assessee has claimed only the direct expenses without claiming any fixed and variable overhead. 3 In the financial year 2007-08, there

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)

section 263 of the Income-tax Act, 1961. 5. The ld.PCIT had noticed the first issue from the assessment records that assessee (M/s Saurashtra Gramin Bank) during the previous year 2016-17 relevant to assessment year (A.Y.) 2017-18, had made provision for an amount of Rs. 20,78,36,400/-, on account of "Investment Depreciation Reserve" as allowable expenditure

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

In the result, ground No.4 raised by the assessee is allowed

58,90,530/-against Returned Book loss of\nRs.28,40,37,610/-.\n2. Grounds of Appeal in relation to computation of book profit u/s 115JB\nHon. CIT(A) erred in law as well as in facts in\n(i). confirming addition made by assessing officer of Rs. 73.99 crores to the book profits\nunder Clause (1) of Explanation

THE ASSISTANT COMMR. OF INCOME TAX, CIRCLE-2(1),, RAJKOT-GUJARAT vs. M/S BHAVANI INDUSTRIES,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 108/Rjt/2016 िनधा"रण वष"/Asstt. Years: 2011-2012 A.C.I.T., M/S Bhavani Industries, Circle-2(1), Vs. C/1-B, 236/3, Gidc, Rajkot. Aji Industrial Estate, Rajkot.

58,98,9242/- thus this ground of appeal is allowed. 6. Aggrieved by the order of the Ld. CIT(A), the Revenue is in appeal before us. 7. The Ld. DR before us vehemently supported the order of the AO by reiterating the findings contained in the Assessment Order. 8. On the other hand the Ld. AR before us filed

THE ACIT, CIRCLE MORBI, MORBI vs. M/S. VITA GRANITO PVT. LTD., MORBI

In the result, the appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2008-09 Acit, Morbi Circle Vs. M/S.Vita Granito P.Ltd. Morbi. B/H. Dariyalal Resort Village-Jambudiya Morbi. Pan : Aaccv 4765 A अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri Mehul Ranpura, Ld.Ar Revenue By : Shri B.D. Gupta, Ld.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2023 घोषणा क" तार"ख /Date Of Pronouncement: 07/07/2023 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Revenue Against Order Passed By The Ld.Commissioner Of Income Tax(Appeals)-3, Rajkot [Hereinafter Referred To As “Ld.Cit(A)Under Section 250(6) Of The Income Tax Act, 1961 ("The Act" For Short) Dated 14.3.2019 Pertaining To The Asst.Year 2008-09. 2. This Is A Recalled Matter. The Appeal Of The Revenue Was Earlier Dismissed On Account Of Low Tax Effect. However, Subsequently, The Department Filed An Ma Pleading That The Appeal Of The Revenue Could Not Be Dismissed On Account Of Low Tax Effect, Because, It Fell Within The Exceptions Provided In Para-8(C) Of The Board’S Instruction Directing Withdrawal Of Appeals On Account Of 2

section 37(1) of the Act had been disallowed treating the same as capital expenditure, holding the assessee as being entitled to depreciation on the same. The order of the AO reveals that reasons for holding so, was that he found that the assessee to have got enduring benefits on account of the said expenditure. The ld.CIT(A), we have

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

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

58 76 989 49 00 203 7 50 40 850 5 55 74 943 Credit of Wind farm on Units Generated 1 05 91 915 1 15 89 169 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

VITARAG EXPORT INDUSTRIES,JUNAGADH ROAD vs. ITO, WARD - 2(1)(1), RAJKOT, AAYAKAR BHAVAN

In the result, ground No.5 raised by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.354/Rjt/2023 ("नधा"रणवष" / Assessment Year: (2012-13) (Physical Hearing) Vitrang Export Industries, Vs. The Ito, Junagadh Road, Near Railway Ward – 2(1)(1), Crossing, Dhoraji, Gujarat - 360140 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfv2407M (Appellant) (Respondent)

58,520/- by way of low production yield of groundnut oil. Vitrang Export Industries 2. The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi failed to appreciate appellant’s ground that when Section 145(3) was not invoked, book result could not have been disturbed by the assessing officer. 3. The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi failed

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,, 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

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

58,137/-, the assessee did not show any Capital Gain in Return of Income part B-TI i.e.(computation of income) as well as schedule CG i.e. Capital Gain and in schedule EI i.e. Exempt Income. The assessee failed to comply in response to notice u/s 142(1) dtd. 01-12-2010 even after the assessee was supplied with

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

depreciation was accounted for in the respective units. All these submissions were made available during the assessment proceedings which can be verified Bhavani Industries India LLP ITA Nos.247 to 250 /RJT/2024 & Ors. (AYs : 2012-13, 2013-14 & Ors.) from the paper book. However the AO has not pointed out any defect in the submission filed by 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

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

depreciation was accounted for in the respective units. All these submissions were made available during the assessment proceedings which can be verified Bhavani Industries India LLP ITA Nos.247 to 250 /RJT/2024 & Ors. (AYs : 2012-13, 2013-14 & Ors.) from the paper book. However the AO has not pointed out any defect in the submission filed by the assessee

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

section 80-IC of Rudrapur Unit for the year\nunder consideration, were submitted before the assessing officer.\n36. The ld.Counsel submitted before us that Rudrapur unit is totally a new and\nindependent unit having separate registration numbers and licenses required\nunder various Act, for manufacturing. It is also submitted that there is no\nforging facility at Rudrapur unit

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

section 80-IC of Rudrapur Unit for the year\nunder consideration, were submitted before the assessing officer.\n36.\nThe ld.Counsel submitted before us that Rudrapur unit is totally a new and\nindependent unit having separate registration numbers and licenses required\nunder various Act, for manufacturing. It is also submitted that there is no\nforging facility at Rudrapur unit