SHRI SHANTILAL MALTIPORT INFRASTRUCTURE PVT. LTD.,,JAMNAGAR. vs. THE ASST. COMMR. OF INCOME TAX & THE ITO-TDS-CIRCLE-1,, JAMNAGAR

In the result, ITA No.275/Rjt/2018 is allowed for statistical purposes whereas

Bench: Shri Waseem Ahmed & Shri Madhumita Roy)

rectification order dated 13/03/2018 of the JCIT (OSD) Circle-1/Jamnagar wherein, claim of the appellant with regard to allowance of surcharge and education cess has not been considered, Surprisingly no appeal either against the order u/s. 143(1) or against the order u/s. 154 of the Act has been filed by the appellant. The appellant has filed the appeal

DHIRAJLAL GOVINDBHAI PATEL ,RAJKOT vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

The appeal of the assessee is treated as allowed

Bench: Dr. Arjun Lal Saini, Am. & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.299/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Dhirajlal Govindbhai Patel Vs. The Ito, Ward – 1(2)(1), Mayurpankh Industries, K-1/49, Aayakar Bhawan, Race Course Road-D, Phase-I, Aji Gidc, 80Ft Ring Road, Road, Rajkot – 360001 Rajkot – 360003 Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agepp0489N (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 22 /10 /2024 Date Of Pronouncement : 22 /01 /2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee Is Directed Against The Order Passed By The National Faceless Appeal Centre [(In Short “Nfac/Ld.Cit(A)”] Vide Order Dated 08.05.2024, Which In Turn Assessment Order Passed By Assessment Unit, Income Tax Department / Assessing Officer Under Section 154 Of The Income Tax Act, 1961 (In Short “The Act”).

disallowed. Thereafter, the appellant filed rectification request u/s. 154 of the Act before CPC. However, the CPC confirmed the demand

SHREE PIPARDI SEVA SAHAKARI MANDALI LIMITED,SURENDRANAGAR vs. THE ITO WARD-2 (1) (2), RAJKOT

In the result, grounds of appeal raised by the assessee are allowed for statistical purposes only

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 448/Rjt/2024 Assessment Year: (2019-20)

disallowed deduction claimed by the assessee while issuing intimation u/s 143(1) of the Act by stating the reason that “Deductions under Chapter-VIA ITA 448/Rjt/2024 Sh. Pipardi Seva Shakari Mandli Ltd. will not be allowed unless respective schedules are filled properly. The assessee filed rectification request u/s 154

ANKUL CONSTRUCTION CO.,RAJKOT vs. THE ASSIT. DIRECTOR OF INCOME TAX , CPC BENGLURU/ITO WD-1(2)(1), RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 484/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) Anukul Constriction Co. Vs. Asstt. Director Of Income 901, Aalap-B, Opp. Shastri Ground, Tax, Cpc Bangaluru / Ito Limda Chowk, Ward 1(2)(1), Rajkot – 360001 Aayakar Bhavan, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfa2385E (Appellant) (Respondent) Appellant By : Shri Jay Kathrani, Ld. A.R. Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 04/02/2025 Date Of Pronouncement : 17/02/2025

rectification u/s. 154 of the Act, and the application was rejected by the Ld. ADIT/ CPC, Bengaluru. 5. That the assessee filed an appeal against the impugned order dated 22.08.2022 and rectified the order. “In view of the above, I find no infirmity in the disallowance

THE ACIT CIRCLE- 1 (1), RAJKOT vs. M/S. MICRO MELT PVT. LTD. , SHAPAR (VERAVAL), RAJKOT

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

rectification proceedings u/s. 154 of the Act has ever claimed that the business loss of A.Y. 1996-97 which has been claimed as set off against the income for the year under consideration i.e. A.Y. 2005-06 consists unabsorbed depreciation loss of A.Y. 1996-97? 3. The appeal is being filed in view of the fact that the case falls

SORTHIYA AHIR GNATINO UTARO,BHAVNATH, JUNAGADH vs. THE ADIT (CPC), BANGALORE, BANGALORE

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

rectification application u/s 154 made by the Appellant and in making adjustment to the returned income of the Appellant by way of intimation u/s 143(1) of the Act and in denying claim of deduction of Rs. 17,00,000/- u/s 11(2) of the Act to the Appellant, failing to appreciate that this was not a case of prima

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

disallowance of deduction u/s.80JJAA of Rs.3,01,93,275/-, since such deduction had subsequently been allowed by the CPC in rectification order passed u/s 154

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

Rectification order u/s.154, since such adjustments does not comprise of the\nmistake apparent on record.\n(vi)The Ld. CIT(A) erred in confirming the total income as processed by the CPC, on\nignoring the fact that the notice for enhancing the income has not been served to the\nappellant u/s 154(3) of the Act.\n3. The facts

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

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

Disallowance of hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 his income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated 10.07.2017, was issued and served on the assessee. Thereafter, rectification u/s 154

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

Disallowance of hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 ITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya H his income. Accordingly notice u/s 274 r.w.s

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

Disallowance of hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 H ITA No.76 to 81/RJT/2022 (AY 8-09 to 12-13 & 14-15) Pankaj C Lodhiya his income. Accordingly notice u/s 274 r.w.s

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

rectification u/s 154 was carried out, vide order dated\n28.02.2018 wherein addition of Rs.589,63,46,541/-, made on account of\nunexplained credit entries in unallocated gold/silver account of STCSH is\nreduced to Rs.9,01,43,236/-, as there was error in considering gold and silver\nrate and mistake in calculation thereof. Accordingly total income revised at\nRs.61

JASUMATIBEN LALITCHANDRA SHAH,RAJKOT vs. INCOME TAX OFFICER, RAJKOT

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

disallowed the claims of the assessee. 3. During the proceedings before the CPC-AO, the assessee filed a rectification application under section 154 of the Act to rectify the mistake and the assessee has prayed the CPC-AO to allow the carry forward loss and set off of the same in the assessment year under consideration

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara | बनाम Main Road, Rajkot-3600 001 Vs. Pan: Aampl 3903 F Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (अपीलार्थी/Assessee) (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

Disallowance of hedging loss Rs.79,37,455/-. 6. In respect of above additions, penalty u/s 271(1)(c) of the Act, was also initiated for concealment of income by furnishing inaccurate particulars of 3 his income. Accordingly notice u/s 274 r.w.s. 271(1)(c) dated 10.07.2017, was issued and served on the assessee. 7. Thereafter, rectification u/s 154

VIJAYA METTALICA INCORPORATED,RAJKOT vs. THE ADIT, CPC, BANGALOREQ, BANGALORE

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

154 of the Income Tax Act, 1961; in short “the Act”. I.T.A No. 115/Rjt/2021 A.Y. 2019-20 Page No. 2 Vijaya Mettalica Incorporated 2. The assessee has taken the following grounds of appeal:- “1 The learned CIT(Appeals) have erred in confirming the disallowance of employee’s contribution u/s. 36(1)(va) amounting

SHRI LAJAI SEVA SAHKARI MANDALI,LAJAI vs. THE ITO, WARD-3, MORBI

In the result, appeal filed by the Assessee is allowed

disallow the claim of u/s. 80P(2)(d) of the Act on rental income. The assessee claimed statutory deduction u/s. 24 of the Act and accepted the addition of Rs. 1,06,575/- as the rental income. The A.O. initiated penalty proceedings u/s. 271(1)(c) for furnishing inaccurate particulars of income. 2.2. A show cause notice dated 08.02.2018 which

SHREE SAURASTRA KA;AKENDRA CO-OP. HOUSING SOCIETY LTD.,RAJKOT vs. THE ADIT (CPC), BANGALORE, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

disallowed by CPC under Section 143(1) of the Act. In response to the adjustment made by CPC u/s 143(1), the assessee filed three separate rectification applications, which were all rejected by the CPC. Accordingly, the assessee filed appeal against the order passed by CPC under Section 154

ROGI KALYAN SAMITI CHITAL,CHITAL AMRELI vs. ITO EXEMPTION WARD-2 RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.328/Rjt/2023 Assessment Year: (2013-14) (Hybrid Hearing) Rogi Kalyan Samiti Chital, Income Tax Officer C. H. C. Chital, Chital District, Vs. (Exemption), Ward – 2, Rajkot Amreli-365 601 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aactr 0652 F (Appellant) (Respondent)

154 of the I.T. Act, 1961. 2. The Learned CIT(A) has wrongly confirmed disallowance of deduction amounting to Rs.3,99,140/-. 3. That, the Ld. CIT(A) has wrongly confirmed levy of interest u/s 234A, 234B, 234C and 234D of the I.T. Act, 1961. ITA.328/RJT/2023/AY.2013-14 Rogi Kalyan Samiti Chital 4. That, the finding

M/S. J. DODHI & CO.,RAJKOT vs. THE ITO, WARD-3 (1) (2), RAJKOT

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

rectification application u/s 154 before the Assessing Officer. The present appeal is therefore dismissed.” 5. Before us, counsel for the assessee submitted that it is filing its return of income under section 44AD of the Act, and it is not required to maintain the books of accounts. Further, as per the terms of the Partnership Deed, the assessee firm