THE ITO, WARD-2,, GANDHIDHAM vs. M/S TERAPANTH FOODS LTD.,, GANDHIDHAM

In the result, appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Suchitra Kambleassessment Year: 2005-06

172, no liability arises for payment of tax by the non- resident receiving payment for time charter. Section 195 of the Act as well as Section 40 (a)(i), which speak of sums chargeable under the Income Tax Act, for creating liability for deduction of tax and for making disallowance

BAN LABS PRIVATE LIMITED,RAJKOT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.202/Rjt/2024 ("नधा"रण वष" / Assessment Year: 2018-19) Ban Labs Pvt. Ltd., Vs. Principal Commissioner Of Ban House, Dr. Vikram Sarabhai Income Tax-1, Nagar, Gondal Road (South), Rajkot Rajkot-360004 (Gujarat) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacb8999C (Appellant) (Respondent)

172 taxmann.com 232 (Gujarat), held that where Assessing Officer had made inquiries with regard to disallowance under section 14A read

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

disallowed 15% of Rs.93,22,874/- which comes to Rs.13,98,431/- and added this amount to the total income of the appellant as AOP by order dated 24.03.2025. 5. That the assessee filed the appeals against the assessment order before the Ld.CIT(A). That the Ld.CIT(A) has dismissed the appeals of the assessee with following observation

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

disallowed 15% of Rs.93,22,874/- which comes to Rs.13,98,431/- and added this amount to the total income of the appellant as AOP by order dated 24.03.2025. 5. That the assessee filed the appeals against the assessment order before the Ld.CIT(A). That the Ld.CIT(A) has dismissed the appeals of the assessee with following observation

SMT. KRUSHNABA PRAVINSINH JADEJA,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CIR.-1(1),, RAJKOT-GUJARAT

disallowance of Rs.99,76,000/-, out of\nsundry creditors, under section 68 of the Act.\n7. Succinct facts qua ground Nos. 1 and 2 are that assessee before us is an\nindividual, and filed the return of income, showing income of\nRs.44,99,170/-, on 29.09.2012. The assessee, is engaged in the business of\nfinance and also deals

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. SMT. KRUSHNABA P. JADEJA,, RAJKOT-GUJARAT

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

disallowance of Rs.99,76,000/-, out of sundry creditors, under section 68 of the Act. 7. Succinct facts qua ground Nos. 1 and 2 are that assessee before us is an individual, and filed the return of income, showing income of Rs.44,99,170/-, on 29.09.2012. The assessee, is engaged in the business of finance and also deals

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)

172. Therefore, the difference of Rs. 3,47,91,594/- in the absence of documentary evidences remained unexplained, hence disallowed Rs. 3,47,91,594/-, by the assessing officer, and added to the total taxable income of the assessee for the year under consideration. DCIT Vs. Vasantbhai Muljibhai Kanani ITA No.124 /RJT/2025 and 08/RJT/2025 5 6. Aggrieved by the order

KANATALAW SEVA SAHAKARI MANDALI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

disallowing deductions claimed u/s 80P as ROI was not filed within due date.Asssesee filed appeal against this order with delay of 172 days which was condoned by ADDL/JCIT(A). Further, ADDL/JCIT (A) decided the issue on merit as well and dismissed appeal of assesee vide order dated 15.03.2024. Assesee seems filed current appeal against the order of AddI. CIT/JCIT

KANATALAW SEVA SAHAKARI MANDALI LTD.,RAJKOT (AMRELI) vs. THE ITO WARD - 3 (1) (4) AMRELI, AMRELI

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita Nos.200 & 201/Rjt/2025 "नधा"रण वष"/Assessment Years :2018-19 & 2019-20 Kanatalaw Seva Sahkari Mandli Income Tax Officer Limited Ward 3(1)(4), Amreli बनाम/ Kanatalaw, Savarkundla, Vs Amreli - 364515 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfk8797L (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Written Submission राज"व क" ओर से/Revenue By : Shri Dheeraj Kumr Gupta, Ld. Sr-Dr सुनवाई क" तार"ख /Date Of Hearing : 10/09/2025 घोषणा क" तार"ख /Date Of Pronouncement : 06/11/2025 आदेश/Order Per, Dr. Arjun Lal Saini, A.M

disallowing deductions claimed u/s 80P as ROI was not filed within due date.Asssesee filed appeal against this order with delay of 172 days which was condoned by ADDL/JCIT(A). Further, ADDL/JCIT (A) decided the issue on merit as well and dismissed appeal of assesee vide order dated 15.03.2024. Assesee seems filed current appeal against the order of AddI. CIT/JCIT

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR - 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

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

disallowed by the Page 14 of 16 ITA Nos.793 & 794/Rjt/2025/AYs 2018-19 & 2020-21 Shree Keshav Co-operative Credit Society Limited assessing officer, for the both assessment years by holding that interest earned from fixed deposits made with Rajkot Nagrik Sahakari Bank Ltd. is not allowable as deduction either under

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

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

disallowed by the Page 14 of 16 ITA Nos.793 & 794/Rjt/2025/AYs 2018-19 & 2020-21 Shree Keshav Co-operative Credit Society Limited assessing officer, for the both assessment years by holding that interest earned from fixed deposits made with Rajkot Nagrik Sahakari Bank Ltd. is not allowable as deduction either under

M/S PREMJI VALJI & SONS,,RAJKOT-GUJARAT vs. THE PR. CIT-1, RAJKOT, RAJKOT

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 125/Rjt/2022 िनधा"रण वष"/Asstt. Years: 2017-2018 M/S Premji Valji & Sons, The Principal Commissioner Of “Kuvarjibhai Tower”, Vs. Income Tax, Palace Road, Rajkot-1, Rajkot. Rajkot. Pan: Aacfp7696K

172 to 209, page Nos. 214 to 216 and page Nos. 219 to 249 of the paper book where the reply of the assessee in response to the notice issued under section 142(1) of the Act as mentioned above was placed. Thus, the learned AR contended that there cannot be A.Y. 2017-18 6 said that the assessment order

SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 62/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2018-19) Kamlesh Deoraj Jain Income Tax Officer, Ward-1, Plot No 35-36, Devashish Gandhidham, Income Tax Vs. Sector-5 Gandhidham 370201 Office, Plot No.32, Sector No.3, Near Iffco Colony, Gandhidham-370 201 "ायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowance @ 0.30% of circular trading purchases of Rs. 283,77,87,618. Accordingly, this appeal of the revenue is dismissed.” 19. On the identical and similar facts, our view is fortified by the judgement of jurisdictional High Court of Gujarat in the case of PCIT v. KFC Exports (P.) Ltd. [2025] 172 taxmann.com 157 (Gujarat), wherein, the Hon`ble Court

DHYAN SWAMIBAPA TRUST,SENJALDHAM, TEHSIL : SAVARKUNDLA, DIST: AMRELI vs. THE ITO EXEMPTION, WARD-1, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.244/Rjt/2022 िनधा"रण वष"/Asstt. Year: 2015-16 Dhyan Swamibapa Trust, Ito Senjaldham, Vs. Ward-1(Exemption), Tehsil Saavarkundala Rajkot. Dist. Amreli-364515 C/O. Sanghavi & Company, Prasham, 4Th Floor, Kasturba Road, Nr. Bilkha Plaza, Rajkot-360001. Pan: Aaatd1598E

disallow a claim for deduction allowance or relief in cases where the claim is made on the basis of the decision of any High Court, Appellate Tribunal or other appellate authority even though a contrary view in the matter may have been expressed by another High Court or another Bench of the Tribunal or any other appellate authority. The fact