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

148 of the Act is in violation of Section 151A of the Act. c) The approval accorded by the designated authority is mechanical and without independent application of mind d) The approval u/s 151 of the Act is issued without complying with the provisions of section 282A(1) of the Act. e) The assessment is wrongly re-opened

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

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 section 143(1)(a)(ii) of the Act, especially in the fact that the scope of sub- clause (ii) has been specifically defined in section 143(1). As observed earlier, in our view, the scope of sub- clause (ii) of section 143(1)(a) does not cover delay in filing of return of income beyond the due prescribed

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

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

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 section 143(1)(a)(ii) of the Act, especially in the fact that the scope of sub- clause (ii) has been specifically defined in section 143(1). As observed earlier, in our view, the scope of sub- clause (ii) of section 143(1)(a) does not cover delay in filing of return of income beyond the due prescribed

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

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated

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

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated

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

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated

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

148/-, under Section 80P(2)(a)(iv) – Rs.3,76,152/-, under Section 80P(2)(d) – Rs.3,51,076/- and under Section 80P(2)(e) – Rs.70,900/-. ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 3 of 10 Thereafter, the assessee was in receipt of communication under Section 143(1)(a) of the Act from CPC dated

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

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

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

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

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

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

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

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

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

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

sections 147r.w.s. 143(3) of the Income Tax Act, 1961, ( hereinafter referred to as "the Act"). 2. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order. For the sake of convenience, the grounds as well as the facts narrated

THE DCIT, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. KISHORE PROJECTS PVT. LTD.,, RAJKOT-GUJARAT

In the result, both the appeals filed by the Revenue are dismissed

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kamble

disallowance and claimed deduction under Section 80IA(4) and addition under Section 40(A)(ia) of the Act was made vide order under Section 143(3) read with Section 148

THE DCIT, CIRCLE-1,, RAJKOT-GUJARAT vs. M/S. KISHORE PROJECTS PVT. LTD.,, RAJKOT-GUJARAT

In the result, both the appeals filed by the Revenue are dismissed

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kamble

disallowance and claimed deduction under Section 80IA(4) and addition under Section 40(A)(ia) of the Act was made vide order under Section 143(3) read with Section 148

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)

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

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)

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