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

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H can only take place when the payer has not deducted tax at source on the sum paid and/or credited in the account of her resident but in the instant case the Ld. AO himself has accepted that the impugned payment has been made to the non-resident agents by referring the provision

THE DCIT, CIRCLE 2(1), RAJKOT-GUJARAT vs. SMT MEENABEN H LAKHANI, RAJKOT-GUJARAT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H can only take place when the payer has not deducted tax at source on the sum paid and/or credited in the account of her resident but in the instant case the Ld. AO himself has accepted that the impugned payment has been made to the non-resident agents by referring the provision

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. D.M.L. WORLD TRADE PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H can only take place when the payer has not deducted tax at source on the sum paid and/or credited in the account of her resident but in the instant case the Ld. AO himself has accepted that the impugned payment has been made to the non-resident agents by referring the provision

THE DCIT, CIRCLE-1(2), RAJKOT vs. M/S. DRB COMMODITIES PVT. LTD., RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under Section 40(a)(ia) r.w.s. 194H can only take place when the payer has not deducted tax at source on the sum paid and/or credited in the account of her resident but in the instant case the Ld. AO himself has accepted that the impugned payment has been made to the non-resident agents by referring the provision

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

disallowed in view of provisions of section 36(1) (va) of the Act as pointed out in the reasons for reopening. Ad-hoc business income of Rs. 2,00,000/- has been offered additionally. A copy of reason recorded for reopening has been provided to the assessee-firm Vides letter dated 17/12/2021. Further, the objection raised against initiation of proceedings

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

disallowed in view of provisions of section 36(1) (va) of the Act as pointed out in the reasons for reopening. Ad-hoc business income of Rs. 2,00,000/- has been offered additionally. A copy of reason recorded for reopening has been provided to the assessee-firm Vides letter dated 17/12/2021. Further, the objection raised against initiation of proceedings

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

disallowed in view of provisions of section 36(1) (va) of the Act as pointed out in the reasons for reopening. Ad-hoc business income of Rs. 2,00,000/- has been offered additionally. A copy of reason recorded for reopening has been provided to the assessee-firm Vides letter dated 17/12/2021. Further, the objection raised against initiation of proceedings

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

disallowed in view of provisions of section 36(1) (va) of the Act as pointed out in the reasons for reopening. Ad-hoc business income of Rs. 2,00,000/- has been offered additionally. A copy of reason recorded for reopening has been provided to the assessee-firm Vides letter dated 17/12/2021. Further, the objection raised against initiation of proceedings

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

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

disallowed in view of provisions of section 36(1) (va) of the Act as pointed out in the reasons for reopening. Ad-hoc business income of Rs. 2,00,000/- has been offered additionally. A copy of reason recorded for reopening has been provided to the assessee-firm Vides letter dated 17/12/2021. Further, the objection raised against initiation of proceedings

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

disallowed then the ratio laid down by the Hon'ble High Court with regard to not taxing all the receipts would remain on papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects, it is decided to further enhance the aforementioned average net profit rate from 41% to 45%. Accordingly

BUILDFOLIO REALITIES LLP,RAJKOT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 509 & 510/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2021-22 & 2022-23 (Hybrid Hearing) Buildfolio Realities Llp The Deputy Commissioner Of Vs Income Tax, Central-1 . Shop No. 5Gf, Business Edifice, Canal Road 37, Income Tax Office, Amruta Karanpura Corner, Rajkot Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360005 Rajkot-360001 "ायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aawfb8233C (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowed then the ratio laid down by the Hon'ble High Court with regard to not taxing all the receipts would remain on papers only. Therefore, with a view to strike a proper balance between the factual vis-à-vis the legal aspects, it is decided to further enhance the aforementioned average net profit rate from 35% to 39%. Accordingly

BUILDFOLIO REALITIES LLP,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1,, RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 509 & 510/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2021-22 & 2022-23 (Hybrid Hearing) Buildfolio Realities Llp The Deputy Commissioner Of Vs Income Tax, Central-1 . Shop No. 5Gf, Business Edifice, Canal Road 37, Income Tax Office, Amruta Karanpura Corner, Rajkot Estate Building, Near Girnar Cinema, M G Road, Rajkot Rajkot-360005 Rajkot-360001 "ायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aawfb8233C (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowed then the ratio laid down by the Hon'ble High Court with regard to not taxing all the receipts would remain on papers only. Therefore, with a view to strike a proper balance between the factual vis-à-vis the legal aspects, it is decided to further enhance the aforementioned average net profit rate from 35% to 39%. Accordingly

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

disallowed then the ratio laid down by the Hon'ble High Court with regard to not taxing all the receipts would remain on papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects, it is decided to further enhance the aforementioned average net profit rate from 41% to 45%. Accordingly

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

disallowed then the ratio laid down by the Hon'ble High Court with regard to not taxing all the receipts would remain on papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects, it is decided to further enhance the aforementioned average net profit rate from 41% to 45%. Accordingly

RADHE DEVELOPERS,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL-1, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowed than the ratio laid down by the Hon'ble High Court regarding not taxing all the receipts would remain in papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects it is decided to further enhance the average net profit rate to 50%. Considering complete facts of the case

DCIT, CENTRAL CIRCLE 1, RAJKOT, RAJKOT vs. RADHE DEVELOPERS, RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowed than the ratio laid down by the Hon'ble High Court regarding not taxing all the receipts would remain in papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects it is decided to further enhance the average net profit rate to 50%. Considering complete facts of the case

RADHE DEVELOPERS,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL -1, , RAJKOT

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं/.Ita No. 549 & 550/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2017-18 & 2018-19 (Hybrid Hearing) Radhe Developers Vs The Deputy Commissioner Of Income Tax, Central-1 . Office No. 47, Ankur Commercial Center, Opp. Income Tax Office, Amruta Swaminarayan Gurukul, Estate Building, Near Girnar Gondal Road, Rajkot Cinema, M G Road, Rajkot Rajkot-360001 Rajkot-360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfr3387E (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowed than the ratio laid down by the Hon'ble High Court regarding not taxing all the receipts would remain in papers only. Thus, with a view to strike a proper balance between the factual vis-à-vis the legal aspects it is decided to further enhance the average net profit rate to 50%. Considering complete facts of the case

KRISHNA DEVELOPERS,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL-1, RAJKOT

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

disallowed than the ratio laid down by the Hon'ble High Court regarding not taxing all the receipts would remain in papers only. Thus, with a view to strike a proper balance between Page 10 of 18 ITA Nos. 543 & 544 & 688/Rjt/2024 Krishan Developers the factual vis-à-vis the legal aspects it is decided to further enhance the average