GODHAVADAR SEVA SAHAKARI MANDALI LTD.,GODHAVADAR, LILIYA MOTA, AMRELI-365535 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

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

section 139(1). The Ld. A.O. CPC Bengaluru processed the return of income u/s. 143(1)(a)(ii) disallowing their

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

section 139(1). The Ld. A.O. CPC Bengaluru processed the return of income u/s. 143(1)(a)(ii) disallowing their

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

section 139(1). The Ld. A.O. CPC Bengaluru processed the return of income u/s. 143(1)(a)(ii) disallowing their

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

section 139(1). The Ld. A.O. CPC Bengaluru processed the return of income u/s. 143(1)(a)(ii) disallowing their

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 only from the Assessment Year 2022-23. I.T.A Nos. 269, 276 & 277/Rjt/2022 A.Y. 2019-20 Page No 4 Aliudepur Seva Sahakari Mandli Ltd. and Ors. vs. ADIT (CPC) 3.1. In support of the same, the assessee relied upon Mumbai

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 only from the Assessment Year 2022-23. I.T.A Nos. 269, 276 & 277/Rjt/2022 A.Y. 2019-20 Page No 4 Aliudepur Seva Sahakari Mandli Ltd. and Ors. vs. ADIT (CPC) 3.1. In support of the same, the assessee relied upon Mumbai

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 only from the Assessment Year 2022-23. I.T.A Nos. 269, 276 & 277/Rjt/2022 A.Y. 2019-20 Page No 4 Aliudepur Seva Sahakari Mandli Ltd. and Ors. vs. ADIT (CPC) 3.1. In support of the same, the assessee relied upon Mumbai

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)

section 143(1)(a)(ii), which specifies the list for disallowance under the said provision and prima facie adjustment for late

MEDI SEVA SAHAKARI MANDALI LTD.,MEDI, DIST. AMRELI vs. THE ADIT (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

143(1 (a) can be made under the clause (ii) of the said section which says" an incorrect claim, if such incorrect claim is apparent from any information in the return." The information of filing the return after the due date is very much apparent from the return and therefore, the disallowance

SHRI TRAMBAKPUR SAHAKARI MANDALI LIMITED,AT TRAMBAKPUR TALUKA DHARI DIST. AMRELI vs. THE DCIT/ACIT (CPC),, BANGALORE

In the result, appeal of the assessee is allowed

section 143(1)(a)(ii) of the Act does not deal with disallowance of deduction for deed filing of return

SHRI NAVA UJALA SEVA SAHAKARI MANDALI LIMITED,AT NAVA UJALA, TALUKA KUNKAVAV, GUIJARAT-365450 vs. THE DCIT/ACIT(CPC),, BANGALORE

In the result, appeal of the assessee is allowed

section 143(1)(a)(ii) of the Act does not deal with disallowance of deduction for deed filing of return

DHAR SEVA SAHAKARI MANDALI LTD.,DHAR, TALUKA: - SAVARKUNDLA, DIST. AMRELI-GUJARAT. vs. THE DCIT(CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

section 143(1)(a)(ii) of the Act does not deal with disallowance of deduction for deed filing of return

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)

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.— Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f. 1

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

143(1) of the Act with respect to the exemption claim by the assessee under Section 11/12 of the Act. Before parting, it is equally significant to note that there is no denial for disallowing claim of the assessee with respect to the expenditures incurred by it against the income. In other words the gross total income cannot be brought

SHRI NAVAVAGHNIYA SEVA SAHKARI MANDALI LIMITED,AMRELI vs. THE DCIT/ACIT (CPC), BANGALORE, BANAGALORE

In the result, appeal of the assessee is allowed

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

disallowance of deduction claimed under any of the provisions of Chapter VI-A under the heading "C.—Deductions in respect of certain incomes" (which includes deduction under section 80P of the Act), can be made if the return is furnished beyond the due date specified under sub-section (1) of section 139. This amendment has been introduced w.e.f. 1

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)

disallowed all the expenses of " 8,22,889/- incurred towards the objects of the Trust, without assigning any specific reason. 4. In the filed appeal by the assessee before Ld. CIT(Appeals), the assessee submitted that the adjustment made u/s 143(1) of the Act does not fall within the ambit of either section 143(1)(a)(i) or (ii

ITO WARD 3(1)(4), RAJKOT-STATION- AMRELI, AMRELI, GUJARAT vs. AVADH AGRI EXPORTS, AMRELI, GUJARAT

In the result, appeal filed by the revenue is dismissed

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

143(2) of the Income tax Act, 1961 was issued on 07.08.2013 which was served upon the assessee on 21.08.2013. Thereafter, notice u/s 142(1) of the Income tax Act, 1961, along with detailed questionnaire was issued on 24.07.2014 which was duly served upon the assessee on 25.07.2014. In response thereto, the assessee attended from time to time and furnished

THE DY. COMMR. OF INCOME TAX, CIR.-3(1), RAJKOT-GUJARAT vs. M/S. SONPAL EXPORTS PVT. LTD., RAJKOT-GUJARAT

In the result, appeal filed by the revenue is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 29/Rjt/2018 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Dcit, Circle – 3(1), Vs. M/S. Sonpal Exports Pvt. Ltd. Rajkot Aayakar Bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1St Floor, Race Course Factory, Amreli Ring Road, Rajkot Pan No.: Aajcs0177N (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 24/06/2025 Date Of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am; By Way Of This Appeal, The Revenue, Has Challenged Correctness Of The Order Dated 16.11.2017, Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The Assessment Year 2012-13. Grievances Raised By The Revenue, Which Are Interconnected & Will Be Taken Up Together, Are As Follows: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 13,96,33,023/- Holding That Provision Of Section 195 Will Not Be Applicable. 2. On The Facts Of The Case & In Law, The Ld. C.I.T. (A) Erred In Ignoring The Facts That The Assessee Has Failed To Prove The Genuineness Of Foreign Commission Expenses Before The A.O. 3. It Is, Therefore, Prayed That The Order Of The C.I.T. (A) May Be Set Aside & That Of The A.O. Be Restored To The Above Extent. Dcit Vs. M/S. Sonpal Export Pvt. Ltd.

143(2) of the Act, was issued to the assessee, on 07-08- 2013, which was duly served upon him on 22-08-2013. A notice u/s 142(1) of the Act, was also issued to the assessee, on 07-10-2014 which was duly served upon him. In response to the said notices, Authorized Representative of the assessee