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6 results for “disallowance”+ Section 2(24)(viia)clear

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Key Topics

Section 26312Section 143(3)10Deduction4Section 10(38)3Depreciation3Addition to Income3Disallowance3Section 139(4)2Section 682Section 36

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

ITA 123/RJT/2016[2011-12]Status: DisposedITAT Rajkot15 Feb 2023AY 2011-12

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

For Appellant: Shri S.N. Soparkar, ld.ARFor Respondent: Shri Shramdeep Sinha, ld.CIT-DR
Section 143(3)Section 263Section 36

disallowed as deduction. Such orders cannot be held to be erroneous 3. The learned Principal CIT is not permitted in law to pre-judge taxability of Rs. 25.00 Crore transferred from Provision for Bad and Doubtful Debt to Statutory Reserve and propose the same to be taxed which effectively serves as directions to AO to make specified addition

2
Exemption2

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

The appeal is dismissed

ITA 196/RJT/2024[2011-12]Status: DisposedITAT Rajkot04 Nov 2025AY 2011-12

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:

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT(DR)
Section 143(3)Section 144C(1)Section 263Section 271(1)(c)Section 36(1)Section 36(1)(viia)

disallowance of provision Rs. 60 Lakh made for standard assets attendance fund. Since, this ground not pressed during the course of argument. Hence, we do not adjudicate Ground No. 1 the Ground No. 1 has dismissed. (ii) Ground No 2 deal with an amount of Rs. 25,00,00,000/- transferred from bad and doubtful debts provision for rural Page

THE DHARANGADHRA PEOPLE'S CO. OP. BANK LTD.,,DHRANGADHRA vs. THE DY. COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed

ITA 130/RJT/2017[2012-13]Status: DisposedITAT Rajkot18 Dec 2019AY 2012-13

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./I.T.A. Nos.130-131/Rjt/2017 ("नधा"रण वष" / Assessment Years: 2012-13 & 2013-14) बनाम/ The Dharangadhra People’S D.C.I.T, Co-Op. Bank Ltd., Surendranagar Circle, Vs. Kalpvarksh, Mandvi Chowk, Surendranagar. Dhrangadhara, Surendranagar Circle, Surendranagar. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaaat1192R (अपीलाथ" /Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से / Appellant By : Shri D.M. Rindani, A.R ""यथ" क" ओर से/Respondent By : Shri Anil Kumar, Sr. D.R सुनवाई क" तार"ख / Date Of Hearing 20/09/2019 घोषणा क" तार"ख /Date Of Pronouncement 18/12/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Appeal Has Been Filed At The Instance Of The Assessee Against The Separate Order Of The Learned Commissioner Of Income Tax (Appeals)-7, Ahmedabad [Ld. Cit(A) In Short] Of Even Dated 01/02/2017, Arising In The Matter Of Assessment Order Passed Under S. 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 16/02/2015 & 27/11/2015 Relevant To Assessment Years (A.Y.S) 2012-13 & 2013-14 Respectively.

For Appellant: Shri D.M. Rindani, A.RFor Respondent: Shri Anil Kumar, Sr. D.R
Section 139(3)Section 139(4)Section 80

24,29000.00 sourced from the bad and doubtful debt fund has already been allowed as deduction under section 36 (1)(viia) of the Act at the rate of 7.50% of the total income irrespective of the fact whether there was any actual claim or not. As such the amount sourced from the bad and doubtful debt fund shows that

SAURASHTRA GRAMIN BANK MANAGER (F & A), RAJKOT,RAJKOT vs. THE PR. COMMISSIONER OF INCOME TAX-I,, RAJKOT

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

ITA 37/RJT/2022[2017-18]Status: DisposedITAT Rajkot30 Sept 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 37/Rjt/2022 (Assessment Year: 2017-18) (Hybrid Hearing) Saurashtra Gramin Bank Vs. The Pr. Cit-1, Manager (F & A), Rajkot 1St Floor Wing 2, Lic Jeevan Prakash Building, Tagore Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahas2116H (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Ms. A.D. Vyas, ARFor Respondent: Shri Sanjay Punglia, CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(viii)Section 37(1)

disallowance under section 14A of the Act, the assessee submitted that assessee is in banking business and had made investment in liquid mutual funds. The amount of investment made in liquid mutual funds as on 01-04-2016 for Rs. 70 crore and as on 31- 03-2017, it was Rs. 22 crores. The assessee submitted that investments are made

NISHANT PAREKH- LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD-1(3), JAMNAGAR

In the result, the appeal of the assessee is allowed

ITA 215/RJT/2025[2015-16]Status: DisposedITAT Rajkot14 Oct 2025AY 2015-16

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.215/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-2016) Nishant Parekh – Legal Heir Of Vs. Income Tax Officer Mina Parekh Aaykar Bhavan 322 Madhav Square, Opp 361001, Gujrat Avantika Complex, Limda Lane Road, Gujrat-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (Appellant) (Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 115BSection 147Section 250Section 68

disallowed and accordingly total sale proceeds of Rs.3,28,81,890/- from the sale of scrips of 'PS IT Infrastructure &Services Ltd (Formerly known as Parag Shilpa Investments Ltd) was assessed as unexplained cash credit u/s 68 of the I.T. Act and to be taxable at the rate of 30% as provided u/s 115BBE of the Act. Nishant Parekh – Legal

THE ASSTT. COMMR. OF INCOME TAX, CIRCLE-1(2),, RAJKOT-GUJARAT vs. SHRI RAJKOT DISTT. CO. OP. BANK LTD.,, RAJKOT-GUJARAT

ITA 385/RJT/2016[2010-11]Status: DisposedITAT Rajkot29 Jun 2022AY 2010-11

Bench: Us.

For Appellant: Shri Ajay Atri, CIT/DRFor Respondent: Shri Deepak Rindani, A.R
Section 143(3)Section 250(6)Section 6(1)(a)

disallowance could be made on account of the assessee having followed a different method for valuing its stock in trade for Income Tax return purposes. I.T.A No. 385/Rjt/2016 A.Y. 2010-11 Page No 5 ACIT vs. The Rajkot District Co.Op. Bank Ltd. 7. It was also pointed out that Courts had on several occasions held that the assessee was entitled