BATAVA DEVLI SEVA SAHAKARI MANDALI LTD.,BATAVA DEVLI, TAL. KUNLAVA, DIST. AMRELI. vs. THE ADIT, (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

disallowed in view of the express language of section 143(1)(ii), which provides for disallowance of incorrect claim which

SHRI JAIN SWETAMBER MURTIPUJAK TAPGACHCHH SANGHA,DHORAJI, DIST. RAJKOT vs. THE NFAC (APPEALS) DELHI, DELHI

In the result the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowed. 4. The assessee in the present case is a Trust and filed its return of income declaring an income of Rs. NIL after claiming exemption under Section 11(1)(a) of the Act. However, the CPC while processing the return under Section 143

SHREE ANTALIYA KHETI VIKAS KARYAKARI SEVA SAHAKARI MANDALI LIMITED,LILIYA MOTA, DIST. AMRELI vs. THE ADIT (CPC), BANGALURU, BENGALURU

In the result, appeal of the assessee is allowed

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

section 143(1)(a)(v) in the Finance Act, 2021 w.e.f. 01.04.2021 such disallowances is possible under the 143(1) proceedings

DAHIDA SEVA SAHAKARI MANDALI LIMITED ,VILLAGE: - DAHIDA, DIST.:- AMRELI vs. THE ADIT (CPC), BENGALURU, BENGALURU

In the result, appeal of the assessee is allowed

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

section 143(1)(a)(v) in the Finance Act, 2021 w.e.f. 01.04.2021 such disallowances is possible under the 143(1) proceedings

ALIUDEPUR SEVA SAHAKARI MANDALI LIMITED,ALIUDEPUR VILLAGE, TALUKA LATHI, DIST.: - AMRELI-365430 vs. THE ADIT (CPC), BENGALURU, BENGALURU

In the result, appeal of the assessee is allowed

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

section 143(1)(a)(v) in the Finance Act, 2021 w.e.f. 01.04.2021 such disallowances is possible under the 143(1) proceedings

AMBARADI SEVA SAHKARI MANDALI LTD.,AMBARADI , DIST. AMRELI vs. THE DCIT(CPC), BANGALURU, BENGALURU

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

disallowance of deduction claimed u/s. 10AA or under any provisions of Chapter VIA w.e.f. 1st April 2021, if the return is furnished beyond the due date specified under sub-section 1 of section 139. This shows the legislative intent while amending sub-section (v) of section 143

SHREE SANALIYA SEVA SAHKARI MANDLI LTD.,LITAL MOTALILIYA SANALIYA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

disallowance of deduction claimed u/s. 10AA or under any provisions of Chapter VIA w.e.f. 1st April 2021, if the return is furnished beyond the due date specified under sub-section 1 of section 139. This shows the legislative intent while amending sub-section (v) of section 143

DHARESHWAR SEVA SAHAKARI MANDALI LTD. ,VILLAGE: - DHARESHWAR, TALUKA: - RAJULA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

disallowance of deduction claimed u/s. 10AA or under any provisions of Chapter VIA w.e.f. 1st April 2021, if the return is furnished beyond the due date specified under sub-section 1 of section 139. This shows the legislative intent while amending sub-section (v) of section 143

AMRUTPUR SEVA SAHKARI MANDALI LTD.,VILLAGE: - AMRUTPUR TALUKA DHARI, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

disallowance of deduction claimed u/s. 10AA or under any provisions of Chapter VIA w.e.f. 1st April 2021, if the return is furnished beyond the due date specified under sub-section 1 of section 139. This shows the legislative intent while amending sub-section (v) of section 143

M/S CHOKSHI VACHHRAJ MAKANJI & CO.,JUNAGADH vs. THE ASST. COMMISSIONER OF INCOME TAX- CIRCLE - 1 (1), RAJKOT - GUJARAT

In the result, the appeal of the assessee is dismissed

Bench: Hri Waseem Ahmed & Shri Siddhartha Nautiyal

section 143(1)(a) of the Act. The ITAT held that disallowance under section 143(1)(a) was valid in view

SHREE MANGROL VANIK DASHA SHRIMALI GNATI SHAPUR DARWAJA,MANGROAL-362225 vs. THE ITO (EXMPTION) WARD-2, RAJKOT, RAJKOT

In the result, the order passed by Ld

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

disallowance was within the scope of section 143(1) adjustments, by treating the assessee as an AOP and thereby disallowing

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

disallowed the deduction u/s 80JJAA of the Act, to the tune of Rs.3,01,93,275/-. However, later on, the assessee`s case, was selected for scrutiny under section 143

M/S NIHAL PROJECTS,KACHCHH vs. ITO WARD 2 , GANDHIDHAM

In the result, the appeal is allowed in the terms indicated above

section 143(3 of the Act, and\nsuch a legal ground can be raised by the assessee at any stage. Therefore,\nlearned Counsel prayed the Bench to admit the above additional ground on\nlegal issue and adjudicate the same first, as it goes to the root of the matter.\n5. On the other hand, learned DR for the revenue opposed

CHAKARGADH SEVA SAHAKARI MANDALI LTD.,CHAKARGADH SEVA, DIST. AMRELI vs. THE DCIT(CPC),, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

disallowance of deduction claimed under section 80P during relevant years 2018-19 and 2019-20 on grounds of late filing of return was unjustified. In the case of Lunidhar Seva SahkariMandali Ltd.149 taxmann.com 28 (Rajkot - Trib.) the ITAT held that denial of claim under section 80P would not come within purview of prima facie adjustment under section 143

ADHYAKSHYA LOK MELA AMLIKARAN SAMMITTEE,RAJKOT vs. INCOME TAX OFFICER, WARD-1(2),, RAJKOT

Appeal of the assessee is partly allowed for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy, आयकर अपील सं./Ita Nos. 424 & 425/Rjt/2018 वष"/Asstt. Years: 2009-2010 & 2010-2011 िनधा"रण वष" िनधा"रण िनधा"रण िनधा"रण वष" वष" Adhyakshya Lok Mela Amlikaran Ito Sammittee Vs. Ward-1(2), A.D. Vyas & Co., Kotecha Nagar Rajkot Main Road, Opp. Kotecha Girls High School, Rajkot-360001 Pan: Aabaa0922F Assessee By : Shri D. M. Rindani, A.R Revenue By : Shri Shramdeep Sinha, D.R सुनवाई क" तारीख/Date Of Hearing : 24/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 17/05/2023 आदेश/O R D E R आदेश आदेश आदेश Per Waseem Ahmed: The Captioned Appeals Have Been Filed At The Instance Of The Assessee Against The Common Orders Passed Under Section 263 Of The Act By The Learned Commissioner Of Income Tax Rajkot Dated 24/03/2014 Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Here-In- After Referred To As "The Act") Relevant To The Assessment Years 2009-10 & 2010- 11. First, We Take Up Ita 424/Rjt/2018, An Appeal By The Assessee For The Ay 2009-10 2. The Assessee Has Raised The Following Grounds Of Appeal: “Ground No 1 Order Of The Learned Cit 1 Rajkot Reopening The Assessment U/S 263 Is Totally Bad On Facts As Well On Law. Learned Cit Ought To Have Considered The Fact That The Assessee Is Already Assessed U/S 143(3) By Ito 1(2) Rajkot.

143(3) by ITO 1(2) Rajkot. ITA Nos.424&425/Rjt/2018 A.Ys. 2009-10 &2010-11 2 Ground No 2 The learned CIT 1 Rajkot has grievously erred in disallowing the expenses of Rs 155800/- without considering the proviso to section

ADHYAKSHYA LOK MELA AMLIKARAN SAMMITTEE,RAJKOT vs. INCOME TAX OFFICER, WARD-1(2),, RAJKOT

Appeal of the assessee is partly allowed for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy, आयकर अपील सं./Ita Nos. 424 & 425/Rjt/2018 वष"/Asstt. Years: 2009-2010 & 2010-2011 िनधा"रण वष" िनधा"रण िनधा"रण िनधा"रण वष" वष" Adhyakshya Lok Mela Amlikaran Ito Sammittee Vs. Ward-1(2), A.D. Vyas & Co., Kotecha Nagar Rajkot Main Road, Opp. Kotecha Girls High School, Rajkot-360001 Pan: Aabaa0922F Assessee By : Shri D. M. Rindani, A.R Revenue By : Shri Shramdeep Sinha, D.R सुनवाई क" तारीख/Date Of Hearing : 24/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 17/05/2023 आदेश/O R D E R आदेश आदेश आदेश Per Waseem Ahmed: The Captioned Appeals Have Been Filed At The Instance Of The Assessee Against The Common Orders Passed Under Section 263 Of The Act By The Learned Commissioner Of Income Tax Rajkot Dated 24/03/2014 Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Here-In- After Referred To As "The Act") Relevant To The Assessment Years 2009-10 & 2010- 11. First, We Take Up Ita 424/Rjt/2018, An Appeal By The Assessee For The Ay 2009-10 2. The Assessee Has Raised The Following Grounds Of Appeal: “Ground No 1 Order Of The Learned Cit 1 Rajkot Reopening The Assessment U/S 263 Is Totally Bad On Facts As Well On Law. Learned Cit Ought To Have Considered The Fact That The Assessee Is Already Assessed U/S 143(3) By Ito 1(2) Rajkot.

143(3) by ITO 1(2) Rajkot. ITA Nos.424&425/Rjt/2018 A.Ys. 2009-10 &2010-11 2 Ground No 2 The learned CIT 1 Rajkot has grievously erred in disallowing the expenses of Rs 155800/- without considering the proviso to section

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

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

disallowed the deduction u/s\n80JJAA of the Act, to the tune of Rs.3,01,93,275/-. However, later on, the\nassessee`s case, was selected for scrutiny under section 143

SHREE LUNIDHAR SEVA SAHKARI MANDALI LTD.,LUNIDHAR, TALUKA KUNKAVAV, DIST. AMRELI. vs. ASSESSING OFFICER (CPC), , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

section 143(1) providing for disallowance of deduction under section 80P due to late filing of return having been introduced