ACIT, CIR-1(1), RAJKOT, RAJKOT vs. SHRI RAJKOT DISTRICT CO OPERATIVE BANK LTD, RAJKOT

The appeal of the revenue is dismissed

Bench: Dr. Arjun Lal Saini. & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.188/Rjt/2024 िनधा"रणवष"/ Assessment Year: (2015-16) (Hybrid Hearing) Assistant Commissioner Of Income- Vs. Rajkot District Co-Operative Bank Tax, Circle-1 (1), Rajkot Limited Room No.502, Aayakar Bhawan, Jilla Bankbhavan, Kasturba Road, Race Course Ring Road, Rajkot- Opp: Chaudhary High School, 360001 Rajkot 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaar0564K (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld.Sr.Dr : 09/06 /2025 Date Of Hearing Date Of Pronouncement : 05/08 /2025

disallowance of Rs. 1,87,65,201/- on account of excess claim of deduction u/s 36(1) (viii) of the Act by way of letter/submission during the assessment proceeding. 2. The learned CIT (A) has erred in law on facts in directing to allowed deduction u/s 36(1)(viii) of Rs. 3,75,00,000/- as against

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

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

201 of the Act and no disallowance can be made by invoking the provisions of section 40(a)(ia) of the Act. Therefore, the disallowance made by the assessing officer cannot be sustained. The addition made at Rs.67,84,807/- on account of disallowance of payments made to CHAs u/s. 40(a)(ia) of the IT Act, 1961 stands deleted

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

201 of the Act and no disallowance can be made by invoking the provisions of section 40(a)(ia) of the Act. Therefore, the disallowance made by the assessing officer cannot be sustained. The addition made at Rs.67,84,807/- on account of disallowance of payments made to CHAs u/s. 40(a)(ia) of the IT Act, 1961 stands deleted

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

201 of the Act and no disallowance can be made by invoking the provisions of section 40(a)(ia) of the Act. Therefore, the disallowance made by the assessing officer cannot be sustained. The addition made at Rs.67,84,807/- on account of disallowance of payments made to CHAs u/s. 40(a)(ia) of the IT Act, 1961 stands deleted

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

disallowance under section\n40(a)(ia) of the Act. Thus, the Assessing Officer has imposed penalty on the ground of\nfurnishing inaccurate particulars, whereas the Tribunal has upheld the order of the Assessing\nOfficer on the ground of concealment of particulars. It is by now well settled that while\nissuing a notice under section 271(1

THE DCIT, (INTL. TAXN.), RAJKOT vs. M/S. KOREA SOUTH EAST POWER CO. LTD., MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar(Conducted Through Virtual Court) Assessment Year: 2011-12 The Dcit (Intl. Taxn.) M/S.Korea South East Power Amruta Estate Co.Ltd. Room No.312 Mg Road बनाम/ C/O. P.V. Page & Co., Girnar Cinema 201, Sardar Griha, 198 L.T. Marg Vs. Rajkot Mumbai – 400 002 (Appellant) (Respondent) Pan: Pan : Ahvps 3555Q Assessee By None Revenue By Shri Ashish Kumar Pandey, Sr.Dr Date Of Hearing 25/09/2023 Date Of Pronouncement 15/12/2023

201, Sardar Griha, 198 L.T. Marg Vs. Rajkot Mumbai – 400 002 (Appellant) (Respondent) PAN: PAN : AHVPS 3555Q Assessee by None Revenue by Shri Ashish Kumar Pandey, Sr.DR Date of Hearing 25/09/2023 Date of Pronouncement 15/12/2023 आदेश/ O R D E R PER ANNAPURNA GUPTA, ACCOUNTANT MEMBER : This appeal is filed by the Revenue against the order passed by the Learned

M/S. L. L. ELECTRICALS,RAJKOT vs. THE NEAC, DELHI , DELHI

In the result, ground number 2 of the assessee’s appeal is being set aside to the file of Assessing Officer with the aforesaid directions

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1) of section 201 of the Act., no disallowance could be made u/s 40(a)(ia) of the Act. L. L. Electricals

THE DCIT CENTRAL CIRCLE-1 , RAJKOT vs. SHRI SHAMJIBHAI SADHABHAI KANGAD, GANDHIDHAM-KUTCH

In the result, appeal filed by the Revenue, in IT(SS) No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआ.(खो और ज).सं./It(Ss)A Nos.11 To 20/Rjt/2022 "नधा"रण वष"/ Assessment Years:2011-12 To 2020-21 बनाम/ Shri Shamjibhai Sadhabhai Deputy Commissioner Of Kangad Income Tax, Central Circle-1, Vs. Bbz-S-60, Zanda Chowk, “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Adepk 3471 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.21 To 23/Rjt/2022 "नधा"रण वष"/ Assessment Years:2014-15, 2016-17 &2017-18 बनाम/ Deputy Commissioner Of Income Shri Shamjibhai Sadhabhai Tax, Central Circle-1, “Amruta Kangad Vs. Estate”, 2Nd Floor, M.G. Road, Bbz-S-60, Zanda Chowk, Rajkot-360001 Gandhidham-370 201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aabca 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) आ.(खो और ज).सं./It(Ss)A Nos.15/Rjt/2023 "नधा"रण वष"/ Assessment Year:2019-20 बनाम/ Deputy Commissioner Of Shri Hetab Shamjibhai Kangad Income Tax, Central Circle-1, Bbz-South-60, Zanda Chowk, Vs. “Amruta Estate”, 2Nd Floor, Gandhidham-370 201 M.G. Road, Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Aqtpk 7484 M (अपीलाथ"/Assessee) (""यथ"/Respondent)

201 "थायीलेखासं./जीआइआरसं./PAN/GIR No.:AABCA 8202 E (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee by. : Shri Mehul Ranpura, ld.AR राज"व क" ओर से/Revenue by : Shri Praveen Verma, CIT-DR & Shri Abhimanyu Singh Yadav, Sr-DR सुनवाई क" तार"ख /Date of Hearing : 25/06/2025 घोषणा क" तार"ख /Date of Pronouncement : 31/07/2025 आदेश/Order

THE DCIT, CIRCLE (TDS), RAJKOT, RAJKOT vs. M/S. GOPAL SNACKS P. LTD., RAJKOT, VILLAGE METODA, TAL. LODHIKA, DIST. RAJKOT

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

1) r.w.s. 194C of the Act. The A.O. also levied interest of Rs. 54,64,255/- u/s. 201(1A) of the Act. 3. Aggrieved against the same, the assessee filed an appeal before Ld. CIT(A). The ld. CIT(A) deleted the additions as follows: “During appellate proceedings the assessee has reiterated his earlier contentions made during assessment

SHRI JAYANTILAL P. SATIKUNVAR,,RAJKOT-GUJARAT vs. THE ASSISTANT COMMR. INCOME TAX,CIRCLE-2(3),, RAJKOT-GUJARAT

In the result, ground number 2 of the assessee’s appeal is being set aside to the file of assessing officer with the aforesaid directions

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

1 of the assessee’s appeal is dismissed as not pressed. Ground number 2: disallowance under section 40(a)(ia) of the Act 5. The brief facts in relation to this ground of appeal are that Ld. CIT(Appeals) confirmed the action of the assessing officer in respect of disallowance under section

ASHOKKUMAR PROJECTS INDIA PVT. LTD.,PORBANDAR vs. THE PR. CIT, JAMNAGAR, JAMNAGAR

In the result, appear of the assessee is allowed

Bench: Dr.Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.83/Rjt/2024 (िनधा"रणवष" / Assessment Year: (2018-19) (Physical Hearing) Ashokkumar Projects India P. Vs. The Pr. Commissioner Of Ltd. Income Tax, 4Th Floor, Manek Centre, P.N. Cholera Arcade, M.G. Road Opposite, Bhaveshwar Mahadev Marg, Jamnagar - 361008 Temple, Porbandar – 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamca5891Q (Assessee) (Respondent)

disallowed under section 40(a) (ia) of the Act.Therefore, Ld. PCIT noticed that such failure on the part of assessing officer rendered the assessment order erroneous in so far as it is prejudicial to the interest of the revenue within the meaning of the provisions of section 263 of the Act. 5.Accordingly, a show cause notice, for initiation of proceedings

POLO PLUS CONTAINERS,SURENDRANAGAR vs. DCIT CPC, BANGALORE

In the result, both these appeals filed by the assessee are allowed for statistical purposes, in above terms,

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.436&437/Rjt/2023 "नधा"रणवष" /Assessment Year: 2018-19&2019-20

201(1) of the Act. Submission of additional details/documents in support of such claim cannot be admitted since it is outside the scope of Section 143(1) of the I.T. Act. The assessee has committed default u/s 40(a)(ia) of the Act, the disallowance

POLOPLUS CONTAINERS,SURENDRANAGAR vs. ASSISSTANT DIRECTOR OF I.T. CPC, BANGALORE

In the result, both these appeals filed by the assessee are allowed for statistical purposes, in above terms,

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.436&437/Rjt/2023 "नधा"रणवष" /Assessment Year: 2018-19&2019-20

201(1) of the Act. Submission of additional details/documents in support of such claim cannot be admitted since it is outside the scope of Section 143(1) of the I.T. Act. The assessee has committed default u/s 40(a)(ia) of the Act, the disallowance

ATMAN RAJNIKANT BHESDADIYA L/R. LATE SHRI RAJNIKANT LAVJIBHAI BHEDADIYA,RAJKOT vs. THE DCIT, CENTRAL CIRCLE-1, RAJKOT, RAJKOT

In the result, appeal of the assessee in ITA No

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

201, Rudraksh (Respondent) B-Apartment Vidhya Kunj Main Road, Opp. Shree Colony, Rajkot, Gujarat PAN No: AEOPP1448R (Appellant) Assessee Represented: Shri Mehul Ranpura, A.R. Revenue Represented: Shri Shramdeep Sinha, CIT-DR Date of hearing : 08-11-2023 Date of pronouncement : 20-12-2023 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee as against