THE ITO, WARD-3(1)(1),, RAJKOT-GUJARAT vs. SHRI GIRISHKUMAR M. PURUSWANI,, RAJKOT-GUJARAT

In the result, the appeal filed by the Revenue is hereby dismissed

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

section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating I.T.A No. 405 to 407/Rjt/2016 A.Y. 2008-09 to 2010-11 Page No 2 ITO vs. Shri Girishkumar Mohanlal Puraswani to the Assessment Years (A.Ys) 2008-09 to 2010-11. Since common disallowance/additions are involved and common grounds are raised

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

Section 149(1)(b) of I.T. Act, 1961. 3. That, the Ld. AO has wrongly passed the assessment order u/s 147 r.w.s. 144B r.w.s. 144 of the Act. 4. That, the Ld. CIT(A) has wrongly set-aside the denial of exemption u/s 11 and 12 of the Act. 5. That, the Ld. CIT(A) has wrongly set-aside

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

Section 149(1)(b) of I.T. Act, 1961. 3. That, the Ld. AO has wrongly passed the assessment order u/s 147 r.w.s. 144B r.w.s. 144 of the Act. 4. That, the Ld. CIT(A) has wrongly set-aside the denial of exemption u/s 11 and 12 of the Act. 5. That, the Ld. CIT(A) has wrongly set-aside

SPECTRUM JOHNSON TILES PRIVATE LIMITED,RAJKOT vs. THE DCIT/ACIT CIR 1(1),RAJKOT., RAJKOT

Appeal is Allowed for Statistical Purpose

sections": [ "14A", "143(3)", "147", "8D" ], "issues": "Whether disallowance under Section 14A of the Income Tax Act, 1961, is attracted

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued

SHRI JUGALKISHORE NATWARLAL DHOLAKIA,JUNAGADH vs. THE PR. CIT-1, RAJKOT, RAJKOT

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:-

disallowance under Section 14A of the Act out of such interest expenses. It was further found that the assessee received interest income of Rs.80,29,679/- as partner in firm of M/s. CVM & Co., against which the assessee claimed and was allowed bank overdraft interest expenses of Rs.11,40,147

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:-

disallowance under Section 14A of the Act out of such interest expenses. It was further found that the assessee received interest income of Rs.80,29,679/- as partner in firm of M/s. CVM & Co., against which the assessee claimed and was allowed bank overdraft interest expenses of Rs.11,40,147

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

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

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

section 147 of the I.T. Act, 1961." Ground of Appeal No.-4: “Ld. CIT (A), NFAC, Delhi, in his appeal order having DIN & Order No.: ITBA/NFAC/S/250/2023-24/1055595028(1), dtd. 30/08/2023, is silent for Rs. 30,250 being interest amount on unsecured deposit of M/s. Ghewarchand Mohanlal Rs. 10, 30,250 disallowed

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

147 of the Act. Therefore, two parallel proceeding initiated by the assessing officer\nwas procedurally invalid and illegal which vitiates the entire assessment.\"\n7. Learned Counsel for the assessee, submitted that above legal grounds on\ntechnical issue, have been raised by the assessee, before the Tribunal. These\nabove legal grounds were also raised before the learned

BABUBHAI KANJIBHAI SAKARIYA LEGAL HEIR OF LATE SMT. UJIBEN KANJIBHAI SAKARIYA,JETPUR vs. ITO WARD 1(2)(1), RAJKOT, RAJKOT

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

147 of the Act, dated 15.03.2022, should be\nquashed.\n15. We note that assessee had intimated to the Revenue Authorities by way of\nletter dated 24.11.2021, about the death of the assessee, the said letter of the\nassessee is placed in the Paper Book of the assessee. We note that the\nAssessing Officer was aware about the death

SHRI RAJESHKUMAR MAHESHBHAI MANEK,ANJAR KUTCH vs. THE ITO WARD-2, GANDHIDHAM-KUTCH, GANDHIDHAM-KUTCH

In the result, additional legal ground raised by the assessee is allowed

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

disallowed herewith and added back to his total income.” 11. Therefore, it is abundantly clear that reasons were recorded by the assessing officer, under section 147

HARIDAS MULJI RUGHANI,PORBANDAR vs. INCOME TAX OFFICER - WARD 2(3), PORBANDAR

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

147 of the Act.\"\nThe amount of Rs. 9,80,000/- on account of SBNs deposited, the assessee\nis found to be the owner of money about whose source the assessee has\nfailed to offer justification duly supported with evidence about the\nacquisition of such money. Assessee's explanation is not satisfactory and,\nPage 2\ntherefore, this money is deemed

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

SAURASHTRA GRAMIN BANK,RAJKOT vs. ASSISTAT COMMISSIONER OF INCOME TAX NFAC , NATIONAL FACELESS ASSESSMENT CENTRE DELHI

In the result, the appeal of the assessee is allowed

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

147 of the I.T. Act.” 4. Therefore, AO issued notice to the assessee u/s 148 of the Act. In response to the notice, under section 148 of the Act, the assessee filed the return of income. Subsequently, a notice under section 142(1) of the Act was also issued to the assessee on 7th March 2022, calling for various details

MUKESH MANEKCHAND SHETH,RAJKOT vs. THE DCIT-ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

147 of the Act is incurably and defective. In para-3 of SCN, it is\nstated that the provision of Section 149(1)(b) has been followed by taking\napproval from the specified authority. However, as submitted above, there is no\nmention of asset or expenditure represented by the alleged-escaped income and\nhence, the notice issued

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

disallowed the deduction u/s 80JJAA of the Act, to the\ntune of Rs.3,01,93,275/-. However, later on, the assessee's case, was selected\nfor scrutiny under section 143 (3) of the Act and the said deduction u/s.80JJAA\nof the Act, was allowed by the assessing officer, vide order dated 19.09.2022,\npassed by the assessing officer under section