M/S P.M. DIESELS PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSTT. COMMR. INCOME TAX, CIRCLE-2(1),, RAJKOT-GUJARAT

In the result, appeal of the assessee is allowed

section 14A in order to disallow one per cent of interest expenses incurred for earning exempt income. The ITAT Ahmedabad in the case of Zaveri & Co. (P.) Ltd.[2020] 118 taxmann.com 429 (Ahmedabad - ITAT), held that where assessee had Rs. 305 crores in its share capital and reserves against which it had made investment of Rs. 32.73 crores, since I.T.A

M/S. SHAILDEEP ENGINEERING P. LTD., RAJKOT,RAJKOT vs. THE DCIT, CPC, BANGALORE, BANGALORE

In the result, the appeal of the assessee is partly allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2019-20 Shaildeep Engineering P.Ltd. Vs. Adit, Cpc C-1/38, Gidc, Aji Industrial Delhi. Estate, Phase-1, Rajkot Sanosara B.O.,Jaliya Rajkot 360 003. Pan : Aaecs 9245 E अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri Akash Goda, Ld.Ar Revenue By : Shri B.D. Gupta, Ld.Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2023 घोषणा क" तार"ख /Date Of Pronouncement: 07/07/2023 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Passed By The Ld.Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre (Nfac), Delhi Under Section 250(6) Of The Income Tax Act, 1961 ("The Act" For Short) Dated 27.12.201 Pertaining To The Asst.Year 2019-20. 2. As Transpires From Orders Of The Authority Below, The Grievance Of The Assessee Is Vis-À-Vis Adjustment Made To The Income Of The Assessee In The Intimation Made Under Section 143(1) Of The Act By Way Of Disallowance Of Deduction Claimed Under Section 80Jja Of The Act Amounting To Rs.2,02,500/- & Disallowance Of Employees’ 2 Contribution To Esi & Pf In Terms Of Section 36(1)(Va) Amounting To Rs.2,81,444/-. The Reasons For Disallowance Of Deduction Under Section 80Jja Being Non-Filing Of Necessary Audit Report In Form No.10Da Along With Return Of Income & That For Disallowance Of Employees’ Contribution To Esi & Pf Being Late Deposit Of The Same With The Requisite Funds.

178 as per which, even a single day’s delay would attract disallowance as per the provisions of section 36(1)(va) of the Act. Therefore

SHRI CHINTAN KANJIBHAI KATARIYA,ANJAR-KUTCH vs. THE ITO WARD-1, , GANDHIDHAM-KUTCH

In the result, appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance of Rs. 5,87,178/- as per provisions of Section 40(a)(ia) of the Act. Further, the Assessing

THE ITO, WARD-2,, JUNAGADH vs. M/S D. JEWEL,, JUNAGADH

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

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedअपील सं./Ita No.15/Rjt/2017 िनधा"रण वष"/Asstt. Year: 2013-2014 Income Tax Officer, M/S. D. Jewel, Ward-2, Vs. 1-Shishu Mangal Road, Junagadh. Gandhigram, Junagadh.

section 10AA of the Act was disallowed by the AO without issuing any show cause notice which is against the principle of justice. 5.2 The assessee further in support of the claim submitted that it is engaged in the manufacturing activity and eligible to claim the deduction u/s 10AA of the Act based on the following details as given hereunder

SHREEJI CERAMIC INDUSTRIES,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

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

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

178 (Ahmedabad – Trib) 4. Mind Sports League (P.) Ltd. Vs. PCIT [2023] 157 taxmann.com 815 (Kolkata – Trib) Assessment Year.2015-16 Shreeji Ceramic 5. Sanjeev Garg Vs. PCIT [2025] 179 taxmann.com 79 (Chandigarh - Trib) 6. Ranchhodbhai Jerambhai Meghani Vs. The Income Tax Officer – Direct Tax Online 7. CBDT instruction No. 20/2015, dtd. 29.12.2015 13. The appeal pertains

THE INCOME TAX OFFICER, WARD-3(1), JAMNAGAR vs. M/S. PARAS BUILDCON P. LTD., JAMNAGAR

Bench: Shri Waseem Ahmed & Shri T.R Senthil Kumar

disallowed the same. But the same was deleted by the learned CIT(A) for the reasons discussed above. 10.1 Admittedly, it is hard to believe that the assessee will make the payment for the purchase over a period in piecemeal amounting to Rs. 18,000 to 20,000 in the given facts and circumstances. However, the onus lies upon

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

SHRI RAJKOT VISHASHRIMALI JAIN SAMAJ ,RAJKOT vs. THE ITO, EXEMPTION WARD-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

178 of the Income Tax Rules, 1962 provide that said report of audit of the accounts of a trust or institution shall be in Form No. 108 As per the provisions of Section 12A(b) of the Income Tax Act, 1961, and under Rule 17B of the Income Tax Rules, Audit Report in Form 108 has to be filed along

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

In the result, ground No.4 raised by the assessee is allowed

disallowance\nof the deduction u/s 80IA of Rs.30,84,582/-.\n34. Aggrieved by the order of Ld. CIT(A), assessee is in further appeal before\nus.\n35. The Ld. Senior Counsel for the assessee, at the outset submitted that Ld.\nCIT(A) ought not to have confirmed the addition made by the Assessing Officer\nof Rs.30

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