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 (3) of the Act and the said deduction u/s.80JJAA of the Act, was allowed by the assessing officer, vide order dated 19.09.2022, passed by the assessing officer under section

SHRI NAGICHANA MAHILA DOODH UTPADAK SAHAKARI MANDALI LTD.,AT. NAGICHANA, TAL. MANGROL, DIST. JUNAGADH vs. THE ITO WARD-1, JUNAGADH

In the result, the appeal of the assessee is allowed

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

section 144Bof the Act dated 21.03.2023. Shri Nagichana Mahila DoodhUtpadakSahakariMandali Ltd. 2 2. The Grounds of appeal, raised by the assessee, are as follows: “1.The order passed u/s 147 r.w.s. 144B of the Act and the notice u/s 148 of the Act is bad in law. 2.The Learned Commissioner (Appeals), NFAC, Delhi erred in sustaining the disallowance

CHANGELA MOHANBHAI R HUF,NEAR BUS STAND vs. PRINCIPAL COMMISSIONER OF INCOME TAX, AAYKAR BHAVAN

In the result, the appeal of the assessee is allowed

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

144B of the Income-tax Act, 1961, on 08.09.2022, accepting returned income. 3. Later on, the Learned Principal Commissioner of Income-tax (in short “Ld PCIT”) exercised his jurisdiction under section 263 of the Income-tax Act, 1961. The ld.PCIT noted that during the course of assessment proceedings, the assessing officer verified the issues under reference and after considering

SOLO STEEL TECH,RAJKOT vs. THE PCIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is dismissed

disallowance in the assessment\nproceedings; Hence, such ‘illegal cash payment transactions” is added and\nabetted by the assessee and his associates whereby the purchaser deposits the\ndifferential cash amount in the bank a/c of the assessee. The assessee is contacted\nby the seller about the said deposit or informed by the purchaser about it. The\nassessee verifies the deposits

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 (3) of the Act and\nthe said deduction u/s.80JJAA of the Act, was allowed by the assessing officer,\nvide order dated 19.09.2022, passed by the assessing officer under section\n143

KANAIYA FOOD PRODUCTS,JAMKANDORANA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 336/Rjt/2024 (Assessment Year: 2017-18) (Hybrid Hearing) Kanaiya Food Products, Vs. The Principal Commissioner Of A A, Dhoraji Jamkandorana Income Tax-1, Rajkot 2Nd Floor, Aaykar Bhawan, Race Road, Near Gujarat Pani Purvatha Tank, Course Ring Road, Rajkot Jamkandodrana-360405 Rajkot-361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfk9437F (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 40A(3)/40A(3A) of the Income-Tax Act. The AO has failed to make disallowance of Rs. 42,92,475/- u/s. 40A(3A) of the IT Act. Therefore, assessment order passed was 147 r.w.s. 144B

SHREE BANTVA SAYUKTA SEVA SAHKARI MANDALI LIMITED,BANTVA vs. INCOME-TAX OFFICER, JUNAGADH

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

Bench: Dr. Arjun Lal Saini

144B of the Income Tax Act, 1961. 2. When this appeal was called out for hearing, learned Counsel for the assessee, submitted before me a statement showing trading account and profit and loss account, claiming various deductions under section 80P of the Act. The Learner Counsel submitted that assessing officer had disallowed

YASMEEN WASEEM PARMAR ,JAMNAGAR vs. THE PR. CIT , JAMNAGAR

Bench: Dr. A. L. Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.194/Rjt/2024 Assessment Year: (2013-14) (Physical Hearing) Yasmeen Waseem Parmar, Vs. Principal Commissioner Of Bawa No Delo, Opp. Old Post Income Tax, Office, Nagarpara Main Road, Jamnagar O/S. Khambhaliya Gate, Jamnagar, Gujarat-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aijph3607F (Assessee) (Respondent)

disallowed 5.Therefore, the order passed by the assessing oficer is prima facie erroneous and prejudicial to the interest of the revenue within the meaning of the provisions of section 263 of the Act, 1961 on this issues as discussed above. Therefore, I intend to revise the order passed by the assessing oficer u/s 147 rws 144B

KETAN GORI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(10), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.42/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Ketan Gori The Pr.Cit बनाम Plot No.3009 Jamnagar. Gidc Phase-Iii Vs. Dared. Pan : Ahppg 5892 A (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sagar Shah, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

disallowed merely based on allegations of the suppliers being bogus. 7.However, ld. Pr. CIT rejected the above submissions of the assessee and observed that in case of some of the suppliers, the GST registrations were cancelled therefore, this leads to conclusion that the genuineness of transactions with supplier is not proved. The ld. PCIT held that the assessment order passed

PRAVINBHAI MOHANBHAI VADI,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR, JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.102/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2021-22 Pravinbhai Mohanbhai Vadi The Pr. Commissioner Of बनाम Flat No.1, Prabhudeep Apartment Income Tax, Jamanagar. Air Force-2 Road Vs. Jamnagar. Pan : Agzpv6946P (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

144B of the Income-tax Act, 1961 (for short ‘the Act’) vide order dated 26/12/2022 determining the total accessed income at Rs. 5,14,18,190/-. 3. Later on, Learned Principal Commissioner of Income-tax (in short “Ld PCIT”), has exercised his jurisdiction under section 263 of the Income-tax Act, 1961. On perusal of the assessment records

DEPUTY COMMIOSSIONER OF INCOMETAX, JAMNAGAR vs. VASANTBHAI MULJIBHAI KANANI, JAMNAGAR

In the result, appeal filed by the revenue is dismissed, whereas appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.124/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Dy. Cit, Cir-1 Vasantbhai Muljibhai Kanani बनाम Jamnagar. Plot No.7, Ambica Enterprise Vs. Sardar Patel Ind. Estte-4 Indira Road Opp: Jakat Naka, Jamnagar-361004 (Guj) Pan : Aitpk 8038 P आयकर अपील सं /.Ita No.08/Rjt/2025 िनधा"रणवष"/ Assessment Year: 2022-23 Vasantbhai Muljibhai Kanani Dy. Cit, Cir-1 बनाम Plot No.7, Ambica Enterprise Jamnagar. Sardar Patel Ind. Estte-4 Vs. Indira Road Opp: Jakat Naka, Jamnagar- 361004 (Guj) Pan : Aitpk 8038 P (अपीलाथ"/Assessee) : (""यथ"/Respondent)

144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'), vide order dated 26.03.2024. 2. The grounds of appeals raised by the Revenue are follows: “1. The Ld. CIT(A) has erred on the facts and in law in deleting the addition of Rs.3,47,91,594/-, made by the assessing officer resorting to the provisions

BHARTIBEN GAUTAMKUMAR BARAI,DWARKA vs. ITO WD-1, DWARKA, DWARKA, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकर अपील सं./Ita No.242/Rjt/2025 "नधा"रण वष" / Assessment Year: (2015-16) (Hybrid Hearing) Bhartiben Gautamkumar Vs Ito, Wd – 1, Barai, Dwarka – 361335 . Nr. Brahm Kund, Dwarka - 361335 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amnpb9005B (Appellant) (Respondent)

section 144B of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee are as follows: 1.The ld. CIT(A) erred in law as well on fact in upholding disallowance

HARDIKKUMAR MAGANBHAI THUMAR,RAJKOT vs. THE INCOME TAX OFFICER WARD 1(1)(1), RAJKOT

In the result, the assessee appeal is allowed for statical purpose

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 625/Rjt/2025 "नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Hardikkumar Maganbhai Thumar Vs. The Income Tax Officer, Ward Jetalsar, Jetalsar Post, Jetpur Rajkot- 1(1)(1),/Rkt. 360360.Gujarat It Office, New Aaykar Bhavan, Vatiaka, Rajkot. Gujarat 360360 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Axupt8837F (Appellant) (Respondent) Appellant By : Shri Kishor Gheewala, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 23 / 12 /2025 Date Of Pronouncement : 05 / 01 /2026

144B of the I.T. Act, on dated 12/09/2022. Hardikbhai Maganbhai Thumar The Grounds of appeal raised by the assessee are as follows: - 1. Addition of Rs. 7,40,673/- u/s 40(a)(ia) & Variation u/s 143(1)(a) of Rs. 12,508/- The registry has informed that the present appeal has been filed after a delay of 25 days

AMRELI JILLA MADHYASTH SAHAKARI BANK LTD.,AMRELI vs. THE DCIT-ACIT-2(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.548/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Amreli Jilla Madhyasth Sahakari The Dcit/Acit-2(1) बनाम Bank Ltd. Rajkot. Bhojalram Bhavan Vs. Rajmahel Road Amreli 365 601. Pan : Aaata 2737 J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M.Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

section 144 and 144B of the Act dated 31.3.2022. ITA No.548 /RJT/2024 (AY : 2014-15) Jasumatiben Lalitchandra Shah 2. The grounds raised by the assessee in the appeal read as under: 1.The order passed u/s 147 r.w.s. 144r.w.s. 144B of the Act and the notice u/s 148 is bad in law. 2.The Learned Commissioner of Income-tax (Appeals), Income

HANSA JITENDRA HARIA,JAMNAGAR vs. PRINCIPAL COMMISSIONER OF INCOME TAX, JAMNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.104/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2013-14) (Hybrid Hearing) Hansa Jitendra Haria Vs. Principal Commissioner Of 2, Oswal Colony, Near Rajendra Income Tax Balkrindagan, Jamnagar, Gujarat Jamnagar 361005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahph4309L (Assessee) (Respondent)

disallowing the issue as discussed above. In view of the above, the ld PCIT held that the assessment order passed by the Assessing Officer u/s 147 rws 144B of the Act dated 30/03/2022 in the case of the above mentioned assessee for the AY 2013- 14 is erroneous in so far as it is prejudicial to the interest of revenue

SHRI PRAKASH BHIKHABHAI THAKKAR,RAJKOT vs. THE ITO, NFAC DELHI, DELHI

In the result, appeal filed by the assessee, is partly allowed, to the extent indicated above

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.412/Rjt/2025 "नधा"रणवष" / Assessment Year: (2019-20) (Hybrid Hearing) Prakash Bhikhabhai Thakkar Vs. Income Tax Department, C/O. "Krushna House", 3Rd National Faceless Floor, Assessment B/H. Alishan Flats, Centre, Near Raiya Telephone Delhi 110001 Exchange, Rajkot 360005 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afjpt6621C (Appellant) (Respondent)

section 144B of the Income Tax Act, 1961. Prakash Bhikhabhai Thakkar, 2. Grounds of appeal raised by the assessee are as follows: “(1) Assessment Order passed u/s. 143(3) r.w.s. 144B of the 1. T. Act, 1961 is bad in law. (2) The Learned AO has erred in law as well as fact in disallowing

ACIT, CIRCLE, GANDHIDHAM, GANDHIDHAM vs. KUTCH DISTRICT CO-OPERATIVE MILK PRODUCERS UNION LIMITED, ANJAR

In the result, appeal find by the revenue is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.212/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2017-18 The Acit, Circle, Kutch District Co-Operative बनाम Gandhidham Milk Producers Union Ltd. Vs. C.O. Apmc Premises, Versamedi Naka, Near Railway Crossing Anjar, Gujarat-37010 Pan : Aaaak9845N (अपीलाथ"/Appellant) (""यथ"/Respondent) : "नधा"रती क" ओर से/Assessee By : Shri Akshay Modi, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr

section 144B of the I.T. Act dated 27.03.2023 when departmental appeal against the order of the Hon'ble ITAT, Rajkot in ITA No. 176/RJT/2022 dated 29.01.2024 is pending with Hon'ble High Court of Gujarat. 2. It is therefore prayed that the order of the Ld.CIT(A) be set aside and that of the AO be restored to the above

PARAS RAMESHCHANDRA DOSHI,RAJKOT vs. THE PCIT - 1, RAJKOT , RAJKOT

section 263 of the Act shall tantamount to change\nof opinion which would not be covered under the revisionary powers of Sec.\n263. Reliance is placed upon following judicial pronouncements in support\nof contentions of the Assessee that when due inquiries are made u/s 263\ncannot be invoked:\na. In the case of Pr. CIT vs M/s Shreeji Prints

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. GANDHI REALITY (INDIA) PRIVATE LIMITED, RAJKOT

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

144B of the Income Tax Act was passed on 20.04.2021, assessing the total income at Rs. 5,44,09,708/-, against the returned Loss of Rs. 16,34,80,379/-. The variation of Rs. 21,78,90,087/-, between returned Loss and assessed Income was attributable to the addition of Rs. 20,18,52,087/-, made on account of disallowance