SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

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

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SHREE KESHAV CO OP CREDIT SOCIETY LTD,JUNAGADH vs. THE DCIT/ACIT, CIR - 1(1), RAJKOT, RAJKOT

In the result, both appeals filed by the assessee, are allowed

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

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SULTANPUR JUTH SEVA SAHKARI MANDLI LTD,RAJKOT vs. ASSESSMENT UNIT, NFAC (PRESENT JURIS. ACIT-DICT CIR 1(1) RAJKOT), RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SULTANPUR JUTH SEVA SAHKARI MANDLI LTD,RAJKOT vs. ASSESSMENT UNIT, NFAC (PRESENT JURIS. ACIT-DCIT CIR 1(1),, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SULTANPUR JUTH SEVA SAHAKARI MANDALI LTD.,SULTANPUR, TAL. GONDAL, DIST. RAJKOT vs. THE DCIT, CIRCLE-1 (1), RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.492 & 493 & 697/Rjt/2024 ("नधा"रण वष"/Assessment Year: (2018-19 & 2020-21) Sultanpur Juth Seva Sahkari Assessment Unit, Nfac Mandali Ltd. (Present Juris. Acit-Dcit Vs. Cir-1(1) Sultanpur, At Sultanpur Tal: Gondal, Dist. It Office, New Aayakar Bhavan, Vatiaka, Rajkot – 364470 Rajkot - 360001 "थायी लेखा सं./जीआइआरसं./Pan/Gir No.: Aaabs0194F (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SHRI NIDHI CREDIT CO-OPRATIVE SOCIETY LIMITED,RAJKOT vs. ITO 3(1)(1), RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini, Am. & Shr Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No.936/Rjt/2024 "नधा"रण वष" / Assessment Year: (2014-15)

disallowing the deduction claimed u/s 80P of the Income-tax Act, 1961, both on facts and law by applying incorrect inference drawn from the text of the section and judiciary pronouncements and therefore, the order passed requires to be quashed in toto. (2) The appellant craves leave to add, amend, alter or withdraw all or any ground of appeal

THE MORBI CITIZENS CREDIT CO-OPRATIVE SOCIETY LIMITED,MORVI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.285/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) The Morbi Citizens Credit Co- Vs. The Assessment Unit, Operative Society Ltd., Income Tax Department Above Murlidhar Sales National Faceless Agency, Savsar Plot, Ram Assessment Center Chowk, Morbid - 363641 (Nfac), Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabat2850K (Appellant) (Respondent)

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SHREE JAMNAGAR JILLA SAHAKARI KHARID VECHAN SANGH LIMITED,JAMNAGAR vs. DCIT-CIR-2(1), JAMNAGAR

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.223/Rjt/2025 "नधा"रण वष"/Assessment Year : 2018-19

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

SHRI JIVICO KARMACHARI CO-OPERATIVE CREDIT SOCIETY LIMITED,RAJKOT, GUJARAT vs. INCOME TAX OFFICER, WARD 2(1)(1), RAJKOT, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.48/Rjt/2025 ("नधा"रण वष" /Assessment Year: (2017-18) Shri Jivico Karmachari Co- Income Tax Officer, Operative Credit Society Ltd. Ward-2(1)(1), Rajkot, Aayakar Vs. Bhawan, Race Course Ring Road, Jivan Prakash, Mahila College Rajkot-360 001 Chowk, Tagore Marg, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaoas 6270 K (अपीलाथ" /Appellant) (""यथ" /Respondent) "नधा"रती क" ओर से /Assessee By : Shri Krutarth Desai, Ar राज"व क" ओर से /Revenue By :Shri Abhimanyu Singh Yadav, Sr-Dr सुनवाई क" तार"ख/ Date Of Hearing : 03/07/2025 घोषणा क" तार"ख/Date Of Pronouncement : 21/07/2025 आदेश / O R D E R Per Dr. A.L. Saini, A.M:

disallow the interest and dividend income earned from Co-operative Bank, which, as per ld PCIT, are not eligible for deduction under section 80P(2)(d) of the Act. 25. We note that the assessee’s case was selected for limited scrutiny to examine investments, advances, loans, unsecured loans, deduction from total income under Chapter

KUNAL RAJENDRA MASHRU,MUMBAI vs. ASST COMMISSIONER OF INCOME TAX CIRCLE -1, JUNAGADH

32 of the Judgment)\n6. The Court further held that where the language of an exemption is\nplain. no additional words or classes can be read into the statute\neven if there appears to be a legislative intent.\nApplication to Present Case\n7. In the present case:\n•\nThe definition of \"relative\" under Explanation (e) is clearly limited\nto certain

SHRI RAJKOT VISHASHRIMALI JAIN SAMAJ ,RAJKOT vs. THE ITO, EXEMPTION WARD-1, RAJKOT, RAJKOT

In the result, appeal of the assessee is allowed

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

32,610 The CPC while processing u/s. 143(1) of the Act denied the claim of deduction of the assessee u/s. 11 of the Act on the ground that the assessee failed to furnish form 10B along with the return of income u/s. 139 as required under the Act. During the year under consideration, the return of income for assessment

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

2 Others 27 32. He further drew our attention to the order of the DRP pointing out that the DRP had not even dealt with submissions made by the assessee before it. 33. On the issue of disallowance of bank guarantee commission expenses made under section

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

2 Others 27 32. He further drew our attention to the order of the DRP pointing out that the DRP had not even dealt with submissions made by the assessee before it. 33. On the issue of disallowance of bank guarantee commission expenses made under section

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

2 Others 27 32. He further drew our attention to the order of the DRP pointing out that the DRP had not even dealt with submissions made by the assessee before it. 33. On the issue of disallowance of bank guarantee commission expenses made under section

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.

32. So far as deeming fiction under section 9(1)(i) is concerned, it cannot be invoked in the present case since no part of the operations of the recipient's business, as commission agent, was carried out in India. Even though deeming fiction under section 9(1)(i) is triggered on the facts of this case, on account

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. GANDHI REALITY (INDIA) PRIVATE LIMITED, RAJKOT

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

2) (together known as the Transferor Companies), had been amalgamated with the Assessee vide a scheme of amalgamation (the Scheme) as per the provisions of section 230 to 232 of Companies Act, 2013. The Scheme was approved by the Honourable National Company Law Tribunal (Hon'ble NCLT) vide its order dated 22 October 2018 and amalgamation was effective from

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

THE ASSISTANT COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHINAGAR vs. M/S KUTCH SALT & ALLIED INDUSTRIES LTD.,, GANDHIDHAM

In the result, cross objections filed by the assessee are allowed for statistical purposes

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhait (Ss)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 To 2012-13) (Hybrid Hearing) Asstt. Commissioner Of Income Tax, Vs. M/S. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaact1769L (Appellant) (Respondent)

2)(b) of the Act. The assessee also furnished the bank accounts, as per books, statement of accounts, from the banks and accounts of these concerns, as called for by the assessing officer. The assessee had also supplied detailed statement showing secured loans, interest-free funds advances etc. by letter filed on 20- 11-2014 for all the financial years