THE ASSTT. COMMR. INCOME TAX, CEN. CIRCLE-2,, RAJKOT-GUJARAT vs. M/S BACKBONE ENTERPRISES LTD.,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 9,06,190/- u/s 80IA(4) in respect of following infrastructure projects undertaken by the appellant: Sr. No. of Name of Project Amt. of deduction claimed Project u/s 80IA (in Rs.) referred by CIT (Appeals) 1 Bhavnagar Irrigation 707,354 I.T.A Nos. 129 & 150/Rjt/2015 A.Y. 2011-12 Page No 3 Backbone Enterprise

BACKBONE ENTERPRISE LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. INCOME TAX, CEN. CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 9,06,190/- u/s 80IA(4) in respect of following infrastructure projects undertaken by the appellant: Sr. No. of Name of Project Amt. of deduction claimed Project u/s 80IA (in Rs.) referred by CIT (Appeals) 1 Bhavnagar Irrigation 707,354 I.T.A Nos. 129 & 150/Rjt/2015 A.Y. 2011-12 Page No 3 Backbone Enterprise

THE ASSTT. COMMR. INCOME TAX, CEN. CIRCLE-2,, RAJKOT-GUJARAT vs. M/S BACKBONE ENTERPRISES LTD.,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 3,70,61,909/- u/s 80IA(4) in I.T.A Nos. 126 & 147/Rjt/2015 A.Y. 2008-09 Page No 3 Backbone Enterprise Ltd. vs. DCIT & ACIT vs. Backbone Enterprise Ltd. respect of following infrastructure projects undertaken by the appellant: Sr. No. of Name of the Project Amt. of deduction Project referred claimed u/s 80IA

BACKBONE ENTERPRISE LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. INCOME TAX, CEN. CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 3,70,61,909/- u/s 80IA(4) in I.T.A Nos. 126 & 147/Rjt/2015 A.Y. 2008-09 Page No 3 Backbone Enterprise Ltd. vs. DCIT & ACIT vs. Backbone Enterprise Ltd. respect of following infrastructure projects undertaken by the appellant: Sr. No. of Name of the Project Amt. of deduction Project referred claimed u/s 80IA

BACKBONE ENTERPRISE LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. INCOME TAX, CEN. CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 22,03,940/- u/s 80IA(4) in respect of following infrastructure projects undertaken by the appellant: Sr. No. of Project Name of Project Amt. of referred by CIT deduction (Appeals) claimed u/s 80IA (in Rs.) 1 Bhachau Ramvav Rapar Adesar 1,584,910 2 Bhavnagar Irrigation 619,030 Total 22,03,940 I.T.A

THE ASSTT. COMMR. INCOME TAX, CEN. CIRCLE-2,, RAJKOT-GUJARAT vs. M/S BACKBONE ENTERPRISES LTD.,, RAJKOT-GUJARAT

In the result, appeal of the assessee is dismissed

disallowing the claim of deduction of Rs. 22,03,940/- u/s 80IA(4) in respect of following infrastructure projects undertaken by the appellant: Sr. No. of Project Name of Project Amt. of referred by CIT deduction (Appeals) claimed u/s 80IA (in Rs.) 1 Bhachau Ramvav Rapar Adesar 1,584,910 2 Bhavnagar Irrigation 619,030 Total 22,03,940 I.T.A

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

4,04,77,490 55,03,173 B Copper 31-Aug-10 255 388.80 7,91,69,191 8,57,65,028 (65,95,837) c Copper 30-Nov-10 195 239.19 6,72,73,511 7,43,67,554 (70,94,043) D Copper

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

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

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

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

disallowance can be made in relation to that assessment year in exercise of powers under section 1534 of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur v. Assistant Commissioner of Income

ASSTT. COMMR. OF INCOME TAX, CEN. CIR-1,, RAJKOT vs. RAJESHKUMAR GOVINDBHAI PATEL,, RAJKOT

In the result both the appeals filed by the Revenue and the Cross Objections filed by the assessee are hereby dismissed

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

disallowance can be made in relation to that assessment year in exercise of powers under section 1534 of the Act and the earlier assessment shall have to be reiterated. In this regard, this court is in complete agreement with the view adopted by the Rajasthan High Court in the case of Jai Steel (India), Jodhpur v. Assistant Commissioner of Income

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

4. Claim of deduction disallowed and treated as excess 75,15,201/- THE ACIT CIR.1(1) RAJKOT by the A.O.[(1)-(3)] 5. Claim allowed by CIT(A) 3,75,00,000/- Method of allocation of profit to the various business segments followed by the Bank and has a basis/logic which was elaborately explained; A.O.'s method is general

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

The appeal is dismissed

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:

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

GALAXY INTERNATIONAL OVERSEAS,DHUVA, WANKANER vs. INCOME TAX OFFICER, WARD-1, MORBI

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 54/Rjt/2024 "नधा"रणवष" / Assessment Year: (2014-15) (Hybrid Hearing) Galaxy International Overseas Income Tax Officer, Vs. C/O. Sarda & Sarda, Cas, Ward – 1, 1St Floor, “Sakar”, Shakti Chambers, Nh27, Anand Dr. Radhakrishnan Road, Nagar, Opp. Rajkumar College, Morbi - 363642 Rajkot – 360001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfg6749C (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Cit(Dr) Date Of Hearing : 17/12/2024 Date Of Pronouncement : 07/03/2025

section 36(1)(iii) of the Act for making any disallowance. (ii)We note that the appellant had interest-free fund in the form of Partners' capital to the tune of Rs. 49,49,096/- which were much higher and sufficient to cover-up the interest-free advances of Rs. 20,48,777/- (iii) We notethat the ratio

THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

disallowance of interest u/s. 36(1)(iii) of the Act. [This is common ground no.5 in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 6 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 7 in ITA No. 48/RJT/2019 for AY 2012-13, ground no. 7 ITA No. 49/RJT/2019 for AY 2013-14 and ground

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

255 where it was held as under:\n\"...We do not feel to provide second inning to the revenue because the entire facts\nwere before the Assessing Officer and the Assessing Officer made an addition on\nwrong grounds.”\n9.17 We also note that the Ld. DR has not brought any defect in the finding of ld. CIT-\nA. Thus

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

Appeals are dismissed, Assessee's appeals are partly allowed

255 where it was held as under:\n"...We do not feel to provide second inning to the revenue because the entire facts\nwere before the Assessing Officer and the Assessing Officer made an addition on\nwrong grounds.”\n9.17 We also note that the Ld. DR has not brought any defect in the finding of ld. CIT-\nA. Thus

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

disallowance of interest u/s. 36(1)(iii) of the Act. [This is common ground no.5 in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 6 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 7 in ITA No. 48/RJT/2019 for AY 2012-13, ground no. 7 ITA No. 49/RJT/2019 for AY 2013-14 and ground

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, RAJKOT vs. SHRI PANKAJ CHIMANLAL LODHIYA, RAJKOT

In the result, assessee's ground No

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

disallowance of interest u/s. 36(1)(iii) of the Act. [This is common ground no.5 in ITA No. 46/RJT/2019 for AY 2010-11, ground no. 6 in ITA No. 47/RJT/2019 for AY 2011-12, ground no. 7 in ITA No. 48/RJT/2019 for AY 2012-13, ground no. 7 ITA No. 49/RJT/2019 for AY 2013-14 and ground