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

250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) by the Learned Commissioner of Income Tax (Appeals)-11, Ahmedabad, dated 08.09.2025, which, in turn, arises out of an assessment order passed by the Assessing Officer (AO) u/s 143(3) of the Act, dated 27.03.2015. 2. The grounds of appeal raised by the Revenue are as under

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

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

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

section 43(5). It is immaterial whether transaction is carried out at the recognized stock exchange or not. Even the circular of CBDT cited in the assessment order states that once it is established that the assessee has entered in the transaction of the commodity that they deal the other technical details have no material impact. Hence, this reasoning

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

HIMESH R. SHAH,JAMNAGAR. vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3,, JAMNAGAR.

In the result, the appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri T.R.Senthil Kumarassessment Year : 2014-15 Himesh R. Shah Vs. Acit, Cir.3 Parikh & Co. Jamnagar. Ranjit Road Jamnagar 361 001. अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.S. Varia, Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit(Dr)

250(6) of the Income Tax Act, 1961 (“the Act” for short) dated 25.1.2019 pertaining to the Asst.Year 2014-15. 2. The assessee has raised the following grounds: “1. That the learned CIT(Appeals) Jamnagar ought to have deleted the addition of Rs. 6,30,455 made to total income by invoking the provisions of section

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

5. Summarised and concise grounds of appeal in assessee`s appeals are as follows: (1)The ld. CIT(A) erred on facts as also in law, in confirming action of assessing officer in restricting disallowance of deduction under section 80-IC of Rs.1,18,45,693/-, on protective basis, on the alleged ground of inflated profit of Rudrapur unit, being

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

5. Summarised and concise grounds of appeal in assessee`s appeals are as follows: (1)The ld. CIT(A) erred on facts as also in law, in confirming action of assessing officer in restricting disallowance of deduction under section 80-IC of Rs.1,18,45,693/-, on protective basis, on the alleged ground of inflated profit of Rudrapur unit, being

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

disallowed the same and added to total income of the assessee. 6. Aggrieved assessee preferred an appeal before the learned CIT-A. 7. The assessee before the learned CIT(A) submitted that the addition has been solely made on the basis of the statements of the 5 parties out of 8 parties to whom commission was paid through account payee

PARSHWA PRINT PACK PVT. LTD.,,WADHWAN vs. THE ASSISTANT COMMR. INCOME TAX, SURENDRANAGAR CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

disallowed the same and added to total income of the assessee. 6. Aggrieved assessee preferred an appeal before the learned CIT-A. 7. The assessee before the learned CIT(A) submitted that the addition has been solely made on the basis of the statements of the 5 parties out of 8 parties to whom commission was paid through account payee

PARSHWA PRINTPACK PVT. LTD.,,SURENDRANAGAR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE,, SURENDRANAGAR

In the result, the appeal of the assessee is allowed for the statistical purposes

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

disallowed the same and added to total income of the assessee. 6. Aggrieved assessee preferred an appeal before the learned CIT-A. 7. The assessee before the learned CIT(A) submitted that the addition has been solely made on the basis of the statements of the 5 parties out of 8 parties to whom commission was paid through account payee

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ADDI. CIT, RANGE-2, 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. 2. Since, 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 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. 2. Since, 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 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. 2. Since, the issues involved

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

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. 2. Since, the issues involved