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

E’ Bench in the case of Glaxo Smithkline Consumer Healthcare Ltd. vs. ITO 12 SOT 221 (Delhi) · Hon’ble Bombay High Court in the case of CIT vs. Jivanlal Lalloobhai& Co. 206 ITR 548 (Bom) · Hon’ble ITAT, Mumbai “B” Bench in the case of ACIT vs. Merchant Shipping Services (P) Ltd. 129 ITD 109 (Mumbai) · Hon’ble ITAT Mumabi

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

E’ Bench in the case of Glaxo Smithkline Consumer Healthcare Ltd. vs. ITO 12 SOT 221 (Delhi) · Hon’ble Bombay High Court in the case of CIT vs. Jivanlal Lalloobhai& Co. 206 ITR 548 (Bom) · Hon’ble ITAT, Mumbai “B” Bench in the case of ACIT vs. Merchant Shipping Services (P) Ltd. 129 ITD 109 (Mumbai) · Hon’ble ITAT Mumabi

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

E’ Bench in the case of Glaxo Smithkline Consumer Healthcare Ltd. vs. ITO 12 SOT 221 (Delhi) · Hon’ble Bombay High Court in the case of CIT vs. Jivanlal Lalloobhai& Co. 206 ITR 548 (Bom) · Hon’ble ITAT, Mumbai “B” Bench in the case of ACIT vs. Merchant Shipping Services (P) Ltd. 129 ITD 109 (Mumbai) · Hon’ble ITAT Mumabi

KUNAL RAJENDRA MASHRU,MUMBAI vs. ASST COMMISSIONER OF INCOME TAX CIRCLE -1, JUNAGADH

22, 23, 29 & 32 of the Judgment)\n6. The Court further held that where the language of an exemption is\nplain. no additional words or classes can be read into the statute\neven if there appears to be a legislative intent.\nApplication to Present Case\n7. In the present case:\n•\nThe definition of \"relative\" under Explanation (e) is clearly

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

22,148/-, 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

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

22,148/-, 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

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

22,148/-, 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

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

22,148/-, 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

SHRI RAJKOT DISTRICT COOPERATIVE BANK LTD.,,RAJKOT-GUJARAT vs. THE PR. COMMR. OF INCOME TAX-1,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2011-12 Shri Rajkot District Cooperative Vs. Pr.Cit, Rajkot-1 Bank Ltd. Rajkot. ‘Jilla Bank Bhavan’, Kasturba Road Opp: Chaudhari High School Rajkot. Pan : Aaaar 0564 K 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assesseeby : Shri S.N. Soparkar, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 17/11/2022 घोषणा क" तार"ख /Date Of Pronouncement: 15/02/2023

E R PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER Present appeal has been filed by the assessee against order of the ld.Pr.Commissioner of Income-tax, Rajkot-1[hereinafter referred to as “the ld.Pr.CIT”] dated 21.3.2016 passed by invoking provisions of 263 of the Income Tax Act, 1961 [hereinafter referred to as "the Act" for short] for the Asst.Year2011-12. 2. The grounds raised

THE DY. COMMR. OF INCOME TAX, CIR.-3(1), RAJKOT-GUJARAT vs. M/S. SONPAL EXPORTS PVT. LTD., RAJKOT-GUJARAT

In the result, appeal filed by the revenue is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 29/Rjt/2018 "नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Dcit, Circle – 3(1), Vs. M/S. Sonpal Exports Pvt. Ltd. Rajkot Aayakar Bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1St Floor, Race Course Factory, Amreli Ring Road, Rajkot Pan No.: Aajcs0177N (Assessee) (Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Praveen Verma, Ld. Cit(Dr) Date Of Hearing : 24/06/2025 Date Of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, Am; By Way Of This Appeal, The Revenue, Has Challenged Correctness Of The Order Dated 16.11.2017, Passed By The Learned Cit(A), In The Matter Of Assessment Under Section 143(3) Of The Income Tax Act 1961, For The Assessment Year 2012-13. Grievances Raised By The Revenue, Which Are Interconnected & Will Be Taken Up Together, Are As Follows: “1. On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 13,96,33,023/- Holding That Provision Of Section 195 Will Not Be Applicable. 2. On The Facts Of The Case & In Law, The Ld. C.I.T. (A) Erred In Ignoring The Facts That The Assessee Has Failed To Prove The Genuineness Of Foreign Commission Expenses Before The A.O. 3. It Is, Therefore, Prayed That The Order Of The C.I.T. (A) May Be Set Aside & That Of The A.O. Be Restored To The Above Extent. Dcit Vs. M/S. Sonpal Export Pvt. Ltd.

E R Per, Dr. Arjun Lal Saini, AM; By way of this appeal, the Revenue, has challenged correctness of the order dated 16.11.2017, passed by the learned CIT(A), in the matter of assessment under section 143(3) of the Income Tax Act 1961, for the assessment year 2012-13. Grievances raised by the Revenue, which are interconnected and will

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

section 37(1) of the Act. 20. With regard to his contention on the nature of services received by virtue of these expenses being established to the AO, he drew our attention to the facts noted by the DRP inits order as reproduced above vis-à-vis these expenses, and pointed out that the payment for management

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

section 37(1) of the Act. 20. With regard to his contention on the nature of services received by virtue of these expenses being established to the AO, he drew our attention to the facts noted by the DRP inits order as reproduced above vis-à-vis these expenses, and pointed out that the payment for management

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

section 37(1) of the Act. 20. With regard to his contention on the nature of services received by virtue of these expenses being established to the AO, he drew our attention to the facts noted by the DRP inits order as reproduced above vis-à-vis these expenses, and pointed out that the payment for management

THE ACIT, CIRCLE-1,, JAMNAGAR vs. M/S. SENOR METALS PVT. LTD., JAMNAGAR

In the results the appeal of the revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Suchitra Raghunath Kambleआयकर अपील सं./Ita No. 260/Rjt/2015 िनधा"रण वष"/Asstt. Year:2011-12

E Zinc 30-Jun-11 5 25.47 21,54,750 22,93,250 (1,38,500) TOTAL 26,96,36,291 28,43,83,211 (1,52,46,920) 3.2 During the assessment proceeding the main point of arguments of the assessee were as under: a) The loss is incurred on account of the derivative transaction entered into to safeguard

ITO WARD 3(1)(4), RAJKOT-STATION- AMRELI, AMRELI, GUJARAT vs. AVADH AGRI EXPORTS, AMRELI, GUJARAT

In the result, appeal filed by the revenue is dismissed

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

e-filed its return of income on 30.09.2012, declaring total income of Rs. 4,69,490/-. Thereafter, the assessee’s case was selected for scrutiny through CASS. Accordingly, first statutory notice u/s 143(2) of the Income tax Act, 1961 was issued on 07.08.2013 which was served upon the assessee on 21.08.2013. Thereafter, notice u/s 142(1) of the Income

SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

The appeal is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.196/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2011-12) Shri Rajkot District Co-Operative Vs. The Deputy Commissioner Of Bank Ltd., Income-Tax, Circle-1(1), Jilla Bank Bhavan, Kasturba Road, Aayakar Bhavan, Race Course Ring Opp. Chaudhary High School, Road, Rajkot-360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Commissioner Of Income Tax Office [(In Short “Ld.Cit(A)”] Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(1) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 30.03.2023 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

E R Per, Dinesh Mohan Sinha, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY)-2018-19, is directed against the order passed by the Commissioner of Income Tax Office [(in short “Ld.CIT(A)”] vide order dated 29.12.2023, which in turn assessment order passed by Income Tax Department / Assessing Officer under section 144C(1) of the Income

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

E R PER Ms. MADHUMITA ROY - JM: The bunch of appeals filed by the Revenue is directed against the order all dated 04.05.2017 passed by the Commissioner of Income Tax (Appeals)-1, Rajkot arising out of the separate orders dated 28.11.2016, 08.08.2016, 17.11.2016, 16.11.2016 & 17.11.2016 respectively passed by the ACIT, Circle – 1(2), Rajkot & DCIT, Circle-1(2), Rajkot under

THE DCIT, CIRCLE-1 (2), RAJKOT vs. SHRI NARENDRA NANJIBHAI DAVDA, RAJKOT

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

E R PER Ms. MADHUMITA ROY - JM: The bunch of appeals filed by the Revenue is directed against the order all dated 04.05.2017 passed by the Commissioner of Income Tax (Appeals)-1, Rajkot arising out of the separate orders dated 28.11.2016, 08.08.2016, 17.11.2016, 16.11.2016 & 17.11.2016 respectively passed by the ACIT, Circle – 1(2), Rajkot & DCIT, Circle-1(2), Rajkot under