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)

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 1,23,470/- Faceless

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

SHREE MANGROL VANIK DASHA SHRIMALI GNATI SHAPUR DARWAJA,MANGROAL-362225 vs. THE ITO (EXMPTION) WARD-2, RAJKOT, RAJKOT

In the result, the order passed by Ld

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

250 of the Income Tax Act, 1961; in short “the Act”. I.T.A No. 56/Rjt/2023 A.Y. 2011-12 Page No 2 Shree Mangrol Vanik Dasha Shrimali Gnati Shapur Darwaja vs. ITO (Exemption) 2. The assessee has raised the following grounds of appeal:- “1. That the learned A.O. has grievously erred in assessing the returned income of Rs. Nil at a taxable

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)

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 addition

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

MANOJBHAI C. KAMDAR,RAJKOT vs. INCOME TAX OFFICER , INCOME TAX OFFICE

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.572/Rjt/2025 िनधा"रणवष" / Assessment Year: (2024-25) Manojbhai C. Kamdar, Vs. Ito, Ward-1(1)(1), A-47, Aalap Green City, Raiya Aayakar Bhavan, Race Course Ring Road, Rajkot (Gujarat) - 360007 Road, Rajkot (Gujarat) – 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adgpk8679J (Appellant) (Respondent) Appellant By : Shri R. D. Lalchandani, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr

250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by National Faceless Appeal Centre (NFAC), Delhi, Commissioner of Income Tax (Appeals), dated 21/07/2025, which in turn arises out of an order passed by the Assessing Officer dated 24/09/2024 u/s 143(1) of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee

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

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)

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 erred

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

BHIMJI KARSAN GHEEWALA,PORBANDAR vs. THE ITO WARD-2 (3) , PORBANDAR

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.467/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2017-18 Bhimji Karsan Gheewala Ito, Ward-2(3)(4) बनाम Kedareshwar Road Porbandar. Porbandar Vs. Pan : Aacfb 3513 F (अपीलाथ"/Appellant) (""यथ"/Respondent) :

250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’), dated 10.05.2024,which in turn arises out of an assessment order passed by the Assessing Officer u/s 143(3) of the Income tax Act, 1961, vide order dated 21.12.2019. BhimjiKarsanGheewala 2 2. The solitary grievance of the assessee in this appeal is that ld. CIT(A) upheld

THE INCOME TAX OFFICER-WARD-2, , GANDHIDHAM - KUTCH vs. M/S. RIDDHI SIDDHI JEWELLERS, GANDHIDHAM - KUTCH

In the result, appeal of the Revenue isdismissed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Royassessment Year :2014-15 Ito, Ward-2 Vs. M/S.Riddhi Siddhi Jewellers Gandhidham. Shop No.1, Plot No.68 Bba (Sough) Gandhidham-Kutch. 0 अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri D.M. Rindani, Ar Revenue By : Shri B.D. Gupta, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 11/04/2023 घोषणा क" तार"ख /Date Of Pronouncement: 05/07/2023

250(6) of the Income Tax Act, 1961 ("the Act" for short) dated 16.3.2018 pertaining to the Asst.Year 2014-15. 2. The grounds raised are as under: “1. The ld.CIT(A) has erred on facts and law in deleting the addition made by AO u/s.69A of the Act of Rs.1,93,69,473/- 2. The ld.CIT(A) has erred

DCIT, CENTRAL CIRCLE-1, RAJKOT vs. M/S GARDEN ENTERPRISE, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved

DCIT, RAJKOT vs. M/S GARDEN ENTERPRISE, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved

DCIT, CENTRAL CIRCLE-1, RAJKOT vs. M/S GARDEN ENTERPRISE, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved

DCIT, RAJKOT vs. M/S GARDEN ENTERPRISE, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved

DCIT, CENTRAL CIRCLE-1, RAJKOT vs. M/S GARDEN ENTERPRISE, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved

M/S. GARDEN ENTERPRISE,RAJKOT vs. THE DCIT CENTRAL CIRCLE-1,, RAJKOT

In the result, all appeals of assessee and revenue are allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shree Dinesh Mohan Sinhaआयकर अपील सं/Ita No.121-122/Rjt/2023 (Assessment Years: (2013-14 & 2014-15) Dcit, Central Circle – 1, Rajkot Vs. M/S. Garden Enterprise, Sadhu Amruta Estate, 2Nd Floor, Mg Road, Vasvani Road, Opp. Shilpan Rajkot – 360001 Tower, Rajkot – 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfg5887C (Appellant) (Respondent)

250 of the Income Tax Act, 1961 (herein referred as to “Act”) by the Learned Commissioner of Income-tax (Appeals)-Ahmedabad-11, all dated Page 2 of 41 ITA No. 86 to 89 & 121 to 125/RJT/2023 M/s. Garden Enterpris 28.02.2023, which in turn arose out of separate assessment orders passed by the Assessing Officer. 2. Since, the issues involved