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

u/s 143(3) r.w.s. 263 of the Act, in which disallowance was made by the Assessing Officer. Since the Asst. Year 2011-12, was decided based on Asst. Year 2010-11, however in Asst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263 of the Act, in which disallowance was made by the Assessing Officer. Since the Asst. Year 2011-12, was decided based on Asst. Year 2010-11, however in Asst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

In the result, summarised and concise ground No

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

u/s 143(3) r.w.s. 263\nof the Act, in which disallowance was made by the Assessing Officer. Since the\nAsst. Year 2011-12, was decided based on Asst. Year 2010-11, however in\nAsst. Year 2010-11, the PCIT has revised

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

revision\norder under section 263 of the Act, wherein ld. PCIT raised the issue\nabout construction labour expenses. In this respect, the findings of the\nassessing officer, which is mentioned in the assessment order, itself, is\nreproduced below:\n“6. During the course of assessment proceedings, in response to notice u/s 142(1)\nof the Act dated

SHREEJI CERAMIC INDUSTRIES,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

revision of Assessment Year.2015-16 Shreeji Ceramic assessment u/s. 263 by L d. PCIT is totally on wrong basis. On the other hand Ld. DR has relied upon the order of Ld. PCIT. 10. We have perused order of Ld. PCIT as well as Ld. AO. On going through both the orders it has come to our notice that Ld. PCIT

FUSION GRANITO PRIVATE LIMITED,MORBI vs. THE PR. COMMISSIONER OF INCOME TAX - 1, RAJKOT, RAJKOT

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

Bench: Dr. A. L. Saini, Am & Shri Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.190/Rjt/2023 (िनधा"रण वष" / Assessment Year: (2018-19) (Physical Hearing) Fusion Granito Pvt. Ltd. बनाम/ Principal Commissioner Of Income Revenue Survey No.555/P1/91, Tax-1, Vs. Nr. Khokhra Hanuman Temple, 2Nd Jetpar Road, Morbi-363641 Rajkot, Floor, “Aayakar Bhawan”, Race Course Ring Road, Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcf 0696 B (अपीलाथ"/Appellant) (""थ" /Respondent) अपीलाथ" ओर से/ Appellant By Shri Bandish Soparkar, Ar ""थ" की ओर से/Respondent By Shri Praveen Verma, Cit Dr सुनवाई की तारीख/Date Of Hearing 24/06/2025 घोषणा की तारीख /Date Of Pronouncement 10/09/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax - 1, Rajkot [In Short ‘Ld. Pcit’], Dated 27.03.2023, Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As The ‘Act’] For The Assessment Year (Ay) 2018-19. 2. Grievances Raised By The Assessee, Which, Being Interconnected, Will Be Taken Up Together, Are As Follows: “1. The Revision Order U/S 263 Of The Act Dated 28.03.2023 Is Bad In Law. 2. The Hon’Ble Pr. Cit-1, Rajkot Has Erred In Law As Well As On Facts In Completing The Revision Proceedings U/S 263 Of The Act Hurriedly In Short Span Of Time Fusion Granito Pvt. Ltd.

revision order under section 263 of the Act. 6. In response to the notice issued by Ld.PCIT, u/s 263 of the Act, the assessee submitted its reply stating that during the assessment proceedings asssessee submitted reply party-wise, and assessing officer examined the issue. Therefore, order passed by the assessing officer is neither erroneous nor prejudicial to the interest

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

In the result, appeal filed by the assessee is dismissed

revision order u/s 263 of I.T.Act, 1961 are taken\ninto consideration,\nThe para 4.2.1 of the Show Cause notice is as follows:\nYour submissions with corresponding annexures etc have been perused with due care. On\nperusal of the documents and your submissions furnished during set-aside assessment\nproceeding u/s. 263 pending before the Assessing Officer as well as during

MANSUKHLAL KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

disallowed, therefore, action u/s. 263 of the Act is justified. The ld.PCIT also relied on may judgements which are mentioned in the revision

JAYESH KHIMJI KHIMASIYA HUF,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

disallowed, therefore, action u/s. 263 of the Act is justified. The ld.PCIT also relied on may judgements which are mentioned in the revision

MANSUKHLAL KHIMJI KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

disallowed, therefore, action u/s. 263 of the Act is justified. The ld.PCIT also relied on may judgements which are mentioned in the revision

BHANUBEN MANSUKHLAL KHIMASIYA,JAMNAGAR vs. OFFICE OF PRINCIPAL COMMISSIONER OF INCOME-TAX, JAMNAGAR, JAMNAGAR

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

disallowed, therefore, action u/s. 263 of the Act is justified. The ld.PCIT also relied on may judgements which are mentioned in the revision

BAN LABS PRIVATE LIMITED,RAJKOT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.202/Rjt/2024 ("नधा"रण वष" / Assessment Year: 2018-19) Ban Labs Pvt. Ltd., Vs. Principal Commissioner Of Ban House, Dr. Vikram Sarabhai Income Tax-1, Nagar, Gondal Road (South), Rajkot Rajkot-360004 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacb8999C (Appellant) (Respondent)

disallowance for same, revision order passed by Pr. Commissioner under section 263 of the Act, holding that assessment order was erroneous and prejudicial to interest of revenue was liable to be quashed and set-aside. 16. Therefore, according to us, the present order of assessing officer passed u/s

M/S. SARJU VITRIFIED PVT. LTD.,MORBI-363641 vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

disallowed u/s 68 r.w.s. 115BBE of the Act and added to the total income\nof the assessee while finalizing the assessment proceedings u/s. 143(3) of the\nI.T. Act which has not been done, by the assessing officer.The above facts are\nsufficient to reach to a conclusion that the A.O, has passed the assessment order\nwithout making proper enquiry

SHRI GIRISHKUMAR VACHHRAJ DHOLAKIA,,JUNAGADH vs. THE PR. COMMISSIONER OF INCOME TAX-1, RAJKOT-GUJARAT

In the result, both the appeals filed by the assessee(s) are dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./ Ita No. 14/Rjt/2021 Assessment Year : 2015-2016 Shri Jugalkishore Natwarlal Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abqpd 2710 D आयकर अपील सं./ Ita No. 15/Rjt/2021 Assessment Year : 2015-2016 Shri Girishkumar Vachhraj Pr. Commissioner Of Dholakia, Vs Income-Tax, C/O. Chokshi Vachhraj Makanji & Pcit-1, Rajkot Co., Shishumangal Road, Gandhigram, Junagadh-362001 Pan : Abupd 6245 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Samir Jani, Ar Revenue By : Shri Vijay Kumar Jaiswal, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01/05/2023 घोषणा क" तारीख /Date Of Pronouncement: 02/05/2023 आदेश/O R D E R Per Ms. Madhumita Roy:-

revised as it is erroneous and prejudicial to the interests of Revenue. In the event of non-compliance, it shall be presumed that you do not have any objection to the proposed proceedings u/s 263 of the Income Tax Act. NIRAJ KUMAR PCIT 3, RAJKOT” 6. The learned PCIT was of the opinion that the disallowance