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.

17. As regards the amount of disallowance enhanced by the learned CIT under section 263 of the Act, it was contended by the learned DR that the assessee cannot be given the benefit of the proviso to section 12A of the Act as the year in dispute relates to the assessment year 2009-10 which is much before the amendment

ACIT, CIR-1(1), RAJKOT, RAJKOT vs. SHRI RAJKOT DISTRICT CO OPERATIVE BANK LTD, RAJKOT

The appeal of the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

disallowance, increasing the tax liability of the taxpayer. 2. Administrative Burden: Without separate profit figures, assessing officers must delve into detailed accounts to compute the deduction, leading to administrative inefficiencies. 3. Risk of Penalties: Non-compliance can attract penalties and interest, as it may be perceived as an attempt to evade taxes. Conclusion For taxpayers to legitimately benefit from

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

disallowed than the ratio laid down\nby the various High Courts, regarding not taxing all the receipts would remain in\npapers only. Thus, with a view to strike a proper balance between the factual vis-\nà-vis the legal aspects it is decided to further enhance the average net profit rate\nto 50%. Accordingly, the net unaccounted profit for this

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2, RAJKOT, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

17. Therefore, assessee submitted, before the assessing officer that deduction/relief under Section 80-IC of the Act, would be allowed to the assessee, under consideration, in view of the following: (i). The undertaking has obtained lease hold land for manufacturing from SIDCUL. And paid the development charge to TATA MOTORS LTD for development of the land at assessee`s cost

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

17. Therefore, assessee submitted, before the assessing officer that deduction/relief under Section 80-IC of the Act, would be allowed to the assessee, under consideration, in view of the following: (i). The undertaking has obtained lease hold land for manufacturing from SIDCUL. And paid the development charge to TATA MOTORS LTD for development of the land at assessee`s cost

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

3) of the Act. 17. During the course of hearing before us, the ld.counsel for the assessee drew our attention to the order of the DRP dismissing the assessee’s objections to the proposed disallowance of the impugned expenses from page no.16 to 19 of the order as under: ITA (TP)No.97/RJT/2016 and 2 Others 10 ITA (TP)No.97/RJT/2016

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

3) of the Act. 17. During the course of hearing before us, the ld.counsel for the assessee drew our attention to the order of the DRP dismissing the assessee’s objections to the proposed disallowance of the impugned expenses from page no.16 to 19 of the order as under: ITA (TP)No.97/RJT/2016 and 2 Others 10 ITA (TP)No.97/RJT/2016

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

3) of the Act. 17. During the course of hearing before us, the ld.counsel for the assessee drew our attention to the order of the DRP dismissing the assessee’s objections to the proposed disallowance of the impugned expenses from page no.16 to 19 of the order as under: ITA (TP)No.97/RJT/2016 and 2 Others 10 ITA (TP)No.97/RJT/2016

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 437/Rjt/2018 धििाधरणणवध/Asstt. Year:2014-2015 Ahlstrom Munksjo Vs. D.C.I.T, Fibercomposites(India) Pvt. Ltd., Gandhidham Circle, Mundra Sez Integrated Textile & Gandhidham. Apparel Park (Mitap), Plot No.07, Survey No.141, Mundra, Kutch-370421. Pan: Aagca9137M (Applicant) (Respondent) Assessee By : Shri Tushar Hemani, A.R Revenue By : Shri Shramdeep Sinha, C.I.T Dr सुिणाईकीतारीख/Date Of Hearing : 06/12/2023 घोवणाकीतारीख/Date Of Pronouncement: 20/12/2023 आदेश/O R D E R Per Waseem Ahmed:

section 40(a)(ia) of the Act. The appellant prays that the addition made by the Learned AO in relation to the disallowance of reimbursement of bank guarantee commission be deleted. The appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit. 3

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ADDI. CIT, RANGE-2, RAJKOT, RAJKOT

disallow the claim of deduction under section 80-IC mainly on\nfollowing basis viz: (1) Rudrapur Unit is not an independent Unit, (2) Activity\nat Rudrapur Unit would not fall within the ambit of definition of manufacturing\nand Production and (3) Transfer of products from non-eligible unit at Rajkot to\neligible unit at Rudrapur Unit is not at market

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

disallow the claim of deduction under section 80-IC mainly on\nfollowing basis viz: (1) Rudrapur Unit is not an independent Unit, (2) Activity\nat Rudrapur Unit would not fall within the ambit of definition of manufacturing\nand Production and (3) Transfer of products from non-eligible unit at Rajkot to\neligible unit at Rudrapur Unit is not at market

ASSISTANT COMMISSINER OF IINCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

disallow the claim of deduction under section 80-IC mainly on\nfollowing basis viz: (1) Rudrapur Unit is not an independent Unit, (2) Activity\nat Rudrapur Unit would not fall within the ambit of definition of manufacturing\nand Production and (3) Transfer of products from non-eligible unit at Rajkot to\neligible unit at Rudrapur Unit is not at market

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

disallow the claim of deduction under section 80-IC mainly on\nfollowing basis viz: (1) Rudrapur Unit is not an independent Unit, (2) Activity\nat Rudrapur Unit would not fall within the ambit of definition of manufacturing\nand Production and (3) Transfer of products from non-eligible unit at Rajkot to\neligible unit at Rudrapur Unit is not at market

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

disallow the claim of deduction under section 80-IC mainly on\nfollowing basis viz: (1) Rudrapur Unit is not an independent Unit, (2) Activity\nat Rudrapur Unit would not fall within the ambit of definition of manufacturing\nand Production and (3) Transfer of products from non-eligible unit at Rajkot to\neligible unit at Rudrapur Unit is not at market

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S DML EXIM PVT. LTD.,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

17. The assessment proceeding was finalised upon making disallowance of Rs. 6,02,976/- out of the interest expenses of Rs. 9,90,30,159/- by invoking the provision of Sec. 14 A r.w.r 8D of the Income Tax Act, 1961. This particular disallowance was made on the contemplation that the appellant may receive income not chargeable to tax from

M/S. D.M.L. EXIM PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

17. The assessment proceeding was finalised upon making disallowance of Rs. 6,02,976/- out of the interest expenses of Rs. 9,90,30,159/- by invoking the provision of Sec. 14 A r.w.r 8D of the Income Tax Act, 1961. This particular disallowance was made on the contemplation that the appellant may receive income not chargeable to tax from

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S D.M.L. EXIM PVT. LTD.,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

17. The assessment proceeding was finalised upon making disallowance of Rs. 6,02,976/- out of the interest expenses of Rs. 9,90,30,159/- by invoking the provision of Sec. 14 A r.w.r 8D of the Income Tax Act, 1961. This particular disallowance was made on the contemplation that the appellant may receive income not chargeable to tax from

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