GODHAVADAR SEVA SAHAKARI MANDALI LTD.,GODHAVADAR, LILIYA MOTA, AMRELI-365535 vs. THE ADIT (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

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

section 250 of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has taken the following grounds of appeal:- I.T.A No. 315/Rjt/2022 A.Y. 2019-20 Page No 2 Godhavadar Seva Sahakari Mandali Ltd. vs. ADIT (CPC) Grounds of Appeal Tax effect relating to each Ground of appeal 1. The learned Commissioner (Appeals), National 2,01,930/- Faceless

BATAVA DEVLI SEVA SAHAKARI MANDALI LTD.,BATAVA DEVLI, TAL. KUNLAVA, DIST. AMRELI. vs. THE ADIT, (CPC), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

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

section 250 of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has taken the following grounds of appeal: I.T.A No. 314/Rjt/2022 A.Y. 2019-20 Page No 2 Batava Devli Seva Sahakari Mandali Ltd. vs. ADIT (CPC) Grounds of Appeal Tax effect relating to each Ground of appeal 1. The learned Commissioner (Appeals), National

CHAKARGADH SEVA SAHAKARI MANDALI LTD.,CHAKARGADH SEVA, DIST. AMRELI vs. THE DCIT(CPC),, BENGALURU

In the result, appeal of the assessee is allowed

Bench: Shri Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

section 250 of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has taken the following grounds of appeal:- I.T.A No. 187/Rjt/2022 A.Y. 2019-20 Page No 2 Chakargadh Seva Sahakari Mandali Ltd. vs. DCIT (CPC) Grounds of Appeal Tax effect relating to each Ground of appeal 1. The learned Commissioner (Appeals), National Faceless Appeal Centre, Delhi

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.

section 143(1) of the Income-tax Act, 1961, as the returned income of Rs. 1,64,75,250/- without any modifications. Later on, the assessee`s case was selected for scrutiny through CASS and a notice u/s 143(2) of the Act, was issued to the assessee, on 07-08- 2013, which was duly served upon

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2, RAJKOT, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

disallowance of said amount made by the assessing officer on account of late payment of PF and ESI. The assessing officer may be directed to allow deduction under section 80-IC of the Act for the amount of addition sustained. [This is ground Nos. 3 and 4 of assessee appeal in ITA No. 256/RJT/ 2024, for assessment year

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

disallowance of said amount made by the assessing officer on account of late payment of PF and ESI. The assessing officer may be directed to allow deduction under section 80-IC of the Act for the amount of addition sustained. [This is ground Nos. 3 and 4 of assessee appeal in ITA No. 256/RJT/ 2024, for assessment year

SMT. NIRMALABEN V. PATEL,JAMNAGAR vs. THE ACIT, CIRCLE-1 , JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Ms. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

section 250 of the Income Tax Act, 1961; in short “the Act”. 2. The assessee has taken the following grounds of appeal:- I.T.A No. 256/Rjt/2019 A.Y. 2016-17 Page No 2 Smt. Nirmalaben V. Patel vs. ACIT “1. Ld. CIT Appeal Jamnagar Erred on law as well as on fact to Partially confirm the Order of ld AO to retain

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2(1), RAJKOT, RAJKOT

250 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') passed by the National Faceless Appeal Centre, Delhi [in short ‘Ld.CIT(A)/NFAC'], which in turns arise out of separate assessment orders passed by the Assessing Officer, under section 143(3)/143(3A) r.w.s. 143(3B) r.w.s.263 of the Act.\n2. Since, the issues involved

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ADDI. CIT, RANGE-2, RAJKOT, RAJKOT

250 of the Income-tax Act, 1961 (hereinafter\nreferred to as 'the Act') passed by the National Faceless Appeal Centre, Delhi\n[in short ‘Ld.CIT(A)/NFAC'], which in turns arise out of separate assessment\norders passed by the Assessing Officer, under section 143(3)/143(3A) r.w.s.\n143(3B) r.w.s.263 of the Act.\n2.\nSince, the issues involved

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

250 of the Income-tax Act, 1961 (hereinafter\nreferred to as 'the Act') passed by the National Faceless Appeal Centre, Delhi\n[in short ‘Ld.CIT(A)/NFAC'], which in turns arise out of separate assessment\norders passed by the Assessing Officer, under section 143(3)/143(3A) r.w.s.\n143(3B) r.w.s.263 of the Act.\n2.\nSince, the issues involved

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

4.\nDespite of the same, if your good- self calculate proportionate remuneration to partners for\nindustrial undertaking at Rudrapur, it will be exempted in the hands of partners. For the said\nour clarifications are as under:\n(a) Prior to 01.04.93.\n(1) Section 40(b): As per above section in case of the firm, any payment of Interest, Salary

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

4.\nDespite of the same, if your good- self calculate proportionate remuneration to partners for\nindustrial undertaking at Rudrapur, it will be exempted in the hands of partners. For the said\nour clarifications are as under:\n(a) Prior to 01.04.93.\n(1) Section 40(b): As per above section in case of the firm, any payment of Interest, Salary

ASSISTANT COMMISSINER OF IINCOME TAX CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

4.\nDespite of the same, if your good- self calculate proportionate remuneration to partners for\nindustrial undertaking at Rudrapur, it will be exempted in the hands of partners. For the said\nour clarifications are as under:\n(a) Prior to 01.04.93.\n(1) Section 40(b): As per above section in case of the firm, any payment of Interest, Salary

SHRI NAGICHANA MAHILA DOODH UTPADAK SAHAKARI MANDALI LTD.,AT. NAGICHANA, TAL. MANGROL, DIST. JUNAGADH vs. THE ITO WARD-1, JUNAGADH

In the result, the appeal of the assessee is allowed

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

250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 16.08.2024, which in turn arise out of an assessment order passed by the Assessing Officer u/s. 147read with section 144Bof the Act dated 21.03.2023. Shri Nagichana Mahila DoodhUtpadakSahakariMandali Ltd. 2 2. The Grounds of appeal, raised by the assessee, are as follows: “1.The order passed

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

4) /\n23(2) of the Indian Income tax Act, 1922 or under section 142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order

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.

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

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

4) /\n23(2) of the Indian Income tax Act, 1922 or under section 142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order

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

4) /\n23(2) of the Indian Income tax Act, 1922 or under section 142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order

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

4) /\n23(2) of the Indian Income tax Act, 1922 or under section 142(1) / 143(2) of the\nIncome tax Act, 1961.\nNO.\ndated\nhave concealed the particulars of your income by furnishing inaccurate particulars\nof such income.\nYou are hereby requested to appear before me on 20/07/2017 at 10.30 A.M. and\nshow cause as to why an order