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)

section 40A(2)(b) of the Act. Moreover, there is no justification for the assessing officer to compare the average purchase price for purchases from two group concerns. Even while making disallowance

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)

section 40A(2)(b) of the Act. Moreover, there is no justification for the assessing officer to compare the average purchase price for purchases from two group concerns. Even while making disallowance

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)

section 40A(2)(b) of the Act. Moreover, there is no justification for the assessing officer to compare the average purchase price for purchases from two group concerns. Even while making disallowance

THE DY. COMMR. OF INCOME TAX, JUNAGADH CIRCLE,, JUNAGADH vs. M/S MAHASAGAR TRAVELS LTD.,, JUNAGADH

In the result, the appeal filed by the Revenue is hereby dismissed

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

Section 40A(2)(b) of the Act and disallowed the commission expenditure of Rs. 1,64,77,275/-. The A.O. also

SHRI DIPTEN AHINDRA BHOWMICK,GANDHIDHAM-KUTCH vs. THE ITO, WARD-1, GANDHIDHAM-KUTCH

In the result, the appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri T. R. Senthil Kumar

disallowances on account of cash payment. 10. However the learned CIT (A) confirmed the order of the AO by observing as under: “The reply of the appellant has no force as the payments were a part of the appellant assessee’s ledger as remarked by the AO. It certainly was an expense even if the net effect was taken

KANDLA EXPORT CORPORATION,,GANDHIDHAM vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.-2(3),, AHMEDABAD

In the result, the summaries and concise ground No

Bench: Dr. Arjun Lal Saini, Am.& Dinesh Mohan Sinha, Jm आयकरअपीलसं./It(Ss)A No.135/Ahd/2016 ("नधा"रणवष" / Assessment Year: (2011-12) (Hybrid Hearing) The Deputy Commissioner Of Vs. Kandla Exports Corporation Income – Tax, Central Circle – 2(3), Plot No. 18, Maitri Bhavan, 3Rd Floor, A – 305, Aayakar Bhavan, Sector – 8, Gandhidham, Ahmedabad – 370201 Kutch- 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfk1906F (Assessee) (Respondent) आयकरअपीलसं./It(Ss)A No.136/Ahd/2016 ("नधा"रणवष" / Assessment Year: (2012-13) (Hybrid Hearing) The Deputy Commissioner Of Kandla Exports Corporation Vs Income – Tax, Central Circle – Plot No. 18, Maitri Bhavan, . 2(3), 3Rd Floor, A – 305, Aayakar Sector – 8, Gandhidham, Bhavan, Ahmedabad - 370201 Kutch- 370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfk1906F (Assessee) (Respondent)

Section 40A(2)(b) of Act. As far as Opening Credit Balance of Rs. 1,26,868/-in the Account of M/s. Friends Mercantile Pvt. Ltd., are concern it may be submitted that the assessee-firm maintains two accounts (ie. Bill Account and Loan Account) in their books of M/s. Friends Mercantile Pvt. Ltd., and as per the bill account

KANAIYA FOOD PRODUCTS,JAMKANDORANA vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

In the result, appeal filed by the assessee, is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos. 336/Rjt/2024 (Assessment Year: 2017-18) (Hybrid Hearing) Kanaiya Food Products, Vs. The Principal Commissioner Of A A, Dhoraji Jamkandorana Income Tax-1, Rajkot 2Nd Floor, Aaykar Bhawan, Race Road, Near Gujarat Pani Purvatha Tank, Course Ring Road, Rajkot Jamkandodrana-360405 Rajkot-361006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamfk9437F (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance under clause (a) of sub-section (3) of section 40A shall be made and no payment shall be deemed to be the profits and gains of business or profession under clause (b) of sub-section (3) of section 40A where any payment in a sum exceeding twenty thousand rupees is made otherwise than by an account payee cheque drawn

THE ACIT, CEN. CIR.-2,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK PVT. LTD.,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

40A(2)(b) of the I.T. Act. 5. On the facts and in the circumstances of the case and in law, the CIT(A) ought to have upheld the order of the A.O. 6. It is, therefore, prayed that the order of the CIT(A) be set aside and that of the A.O. be restored to the above extent

THE ACIT, CEN. CIR.-2,, RAJKOT-GUJARAT vs. M/S. CLASSIC NETWORK PVT. LTD.,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

40A(2)(b) of the I.T. Act. 5. On the facts and in the circumstances of the case and in law, the CIT(A) ought to have upheld the order of the A.O. 6. It is, therefore, prayed that the order of the CIT(A) be set aside and that of the A.O. be restored to the above extent

CLASSIC NETWORKS PVT. LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.2,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

40A(2)(b) of the I.T. Act. 5. On the facts and in the circumstances of the case and in law, the CIT(A) ought to have upheld the order of the A.O. 6. It is, therefore, prayed that the order of the CIT(A) be set aside and that of the A.O. be restored to the above extent

CLASSIC NETWORKS PVT. LTD.,,RAJKOT-GUJARAT vs. THE DY. COMMR. OF INCOME TAX, CEN. CIR.2,, RAJKOT-GUJARAT

The appeals of the Revenue are dismissed for assessment years 2005-06 and 2006-07

40A(2)(b) of the I.T. Act. 5. On the facts and in the circumstances of the case and in law, the CIT(A) ought to have upheld the order of the A.O. 6. It is, therefore, prayed that the order of the CIT(A) be set aside and that of the A.O. be restored to the above extent

M/S. GREEN EARTH BIOGAS PVT. LTD.,SURENDRANAGAR vs. THE PR. CIT-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

b) read with section 270(A)(1) of Income Tax Act, 1961,?\n(ii)\nDocumentary evidences of putting depreciable assets to use for the\npurpose of the Business.\n(iii)\nDocumentary evidences w.r.t. to source of cash deposited into the bank.\n3) Certain facts we would like to put for kind consideration as under before we\nsubmit our reply

ANKUL CONSTRUCTION CO.,RAJKOT vs. THE ASSIT. DIRECTOR OF INCOME TAX , CPC BENGLURU/ITO WD-1(2)(1), RAJKOT

In the result, this appeal of the assessee is allowed for statistical purposes, in above terms

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No. 484/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) Anukul Constriction Co. Vs. Asstt. Director Of Income 901, Aalap-B, Opp. Shastri Ground, Tax, Cpc Bangaluru / Ito Limda Chowk, Ward 1(2)(1), Rajkot – 360001 Aayakar Bhavan, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aakfa2385E (Appellant) (Respondent) Appellant By : Shri Jay Kathrani, Ld. A.R. Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 04/02/2025 Date Of Pronouncement : 17/02/2025

B, Opp. Shastri Ground, Tax, CPC Bangaluru / ITO Limda Chowk, Ward 1(2)(1), Rajkot – 360001 Aayakar Bhavan, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./PAN/GIR No.: AAKFA2385E (Appellant) (Respondent) Appellant by : Shri Jay Kathrani, Ld. A.R. Respondent by : Shri Abhimanyu Singh Yadav, Ld. Sr. DR Date of Hearing : 04/02/2025 Date of Pronouncement : 17/02/2025 आदेश / O R D E R PER DINESH MOHAN

SHREEJI CERAMIC INDUSTRIES,MORBI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX-1, RAJKOT

In the result, the appeal filed by the assessee is allowed

Bench: Dr. A.L.Saini, Am & Diesh Mohan Sinha, Jm आयकरअपीलसं./Ita No.266/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2015-16) (Hybrid Hearing) Shreeji Ceramic Industries, The Principal Commissioner Of Vs. 8/A National Highway, Lalpar Income Tax – 1, Morbi - 363642 Rajkot "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs8846B (Appellant) (Respondent) Appellant By : Shri D. M. Rindani, Ld. Ar Respondent By : Shri Sanjay Punglia, Cit (Dr) सुनवाईक"तार"ख/ Date Of Hearing : 17/07/2025 घोषणाक"तार"ख/Date Of Pronouncement : 12/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of Learned Principle Commissioner Of Income Tax, Rajkot – 1 [In Short, “The Ld. Pcit”], Dated 30.03.2021 For The Assessment Year (Ay) 2015-16. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows.

disallowance under section 14A of the Act, read with rule 8D in respect of the exempt income was not one of the issues which was selected for scrutiny. The learned Tribunal in paragraph 2 of its order has set out the three items which have been selected for scrutiny namely, (i) Introduction of capital in NBFC/investment company; (ii) large deduction

AARYALAND ENTERPRISE,RAJKOT vs. THE DY. CIT- CIRCLE-1 (2), RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

B. D. Gupta, Sr. DR सुनवाईक"तार"ख/Date of Hearing : 04/07/2022 घोषणाक"तार"ख/Date of Pronouncement: 14/09/2022 आदेश/O R D E R PER BENCH: The captioned appeal has been filed at the instance of the assessee against the order of the Ld. Commissioner of Income Tax-(Appeals) (in short the Ld. CIT(A)), Jamnagar dated 02/08/2019arising

M/S. SHIVABYAY PROJECT PVT. LTD. ,GANDHIDHAM-KUTCH vs. THE INCOME TAX OFFICER, WARD-2,, GANDHIDHAM-KUTCH

In the result, the appeal of the assessee is allowed

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

2. It is therefore prayed that the addition of Rs. 1,95,92,793/- on account of disallowance of expenses claimed u/s 40(a)(ia) of the Act as held in the assessment order be restored.” 4. The brief facts of the case are that for the impugned year under consideration, the assessee had disclosed gross profit

THE INCOME TAX OFFICER, WARD-2,, GANDHIDHAM-KUTCH vs. M/S. SHIVABYAY PROJECT PVT. LTD. , GANDHIDHAM-KUTCH

In the result, the appeal of the assessee is allowed

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

2. It is therefore prayed that the addition of Rs. 1,95,92,793/- on account of disallowance of expenses claimed u/s 40(a)(ia) of the Act as held in the assessment order be restored.” 4. The brief facts of the case are that for the impugned year under consideration, the assessee had disclosed gross profit

PUNABHAI G. PARDAVA,,DHARI vs. INCOME TAX OFFICER, WARD-3(1)(4),, AMRELI

In the result, the appeal preferred by the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri T. R. Senthil Kumar

B. D. Gupta, Ld. DR Date of Hearing 30/08/2022 Date of Pronouncement 28/09/2022 O R D E R PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER: This is an appeal filed by the assessee against the order dated 08.04.2019 passed by the Commissioner of Income Tax (Appeals)-3, Rajkot (in short “CIT(A)”) arising out of the assessment order dated 23.03.2016 passed