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

houses, bungalows, shops, flats, offices, tenements workshops, factory buildings, go-downs, warehouses, apartments, buildings, and civil works of all kinds. During the year under consideration, erstwhile Gandhi Realty (India) Private Limited having registered office at "Solitarie", Amin Marg Junction, 150 Ring Road, Nr. Pragati complex, Rajkot-360005 and PAN AACCG5189K (The Transferor Company 1" or "old GRIPL) and Crystal Organisers

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

PANKAJKUMAR CHIMANLAL LODHIYA,RAKJOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet -\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt -\nRs.3

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACTIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

PANKAJKUMAR CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

PANKAJ CHIMANLAL LODHIYA,RAJKOT vs. THE ACIT, CENTRAL CIRCLE-2, RAJKOT, RAJKOT

vi). Unexplained Investment in Properties and Rent thereof as per KYC\ndocuments of Undisclosed Foreign Bank Account Rs.5,93,51,875/-\n(Rs.5,82,72,750/- + Rs.10,79,125/-).\n(vii). Deemed Rent of more than one property reflected in Balance sheet\nRs.1,80,000/-.\n(viii). Disallowance of payment of commission to Shri Rajesh Bhatt\nRs.3

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)

House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit, but voluntarily and on grounds of commercial expediency and in order to indirectly to facilitate the carrying on the business…The expression "commercial expediency" is an expression

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)

House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit, but voluntarily and on grounds of commercial expediency and in order to indirectly to facilitate the carrying on the business…The expression "commercial expediency" is an expression

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)

House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit, but voluntarily and on grounds of commercial expediency and in order to indirectly to facilitate the carrying on the business…The expression "commercial expediency" is an expression

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

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)

House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit, but voluntarily and on grounds of commercial expediency and in order to indirectly to facilitate the carrying on the business…The expression "commercial expediency" is an expression

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)

House of Lords that in order to claim a deduction, it is enough to show that the money is expended, not of necessity and with a view to direct and immediate benefit, but voluntarily and on grounds of commercial expediency and in order to indirectly to facilitate the carrying on the business…The expression "commercial expediency" is an expression

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

housing development. 2. Eligible Business: The deduction applies exclusively to profits derived from the eligible business activities mentioned above. 3. Creation of Special Reserve: The entity must transfer up to 20% of the eligible profits to a special reserve, as reflected in the financial statements. Necessity of Claiming Through Profit and Loss Account 1. Legal Compliance: The Income

SHRI SHAMJIBHAI SADHABHAI KANGAD,GANDHIDHAM-KUTCH vs. THE DCIT CENTRAL CIRCLE-1 , RAJKOT

house agent, renting of godown and\nwarehouse etc. The pioneer and founder of the salt manufacturing business, was\nLate Shri Sadhabhai Ramjibhai Kangad, who has installed the first washery plant\nShri Shamjibhai Shadabhai Kangad & Ors.\nIT(SS)A Nso.11 to 23/RJT/2022 and Ors. (AYs: 2011-12 to 2018-19 & Ors..)\n11\nway back in 1968 in the name of Neelkanth

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

properties as seized in the form of Digital Data like and in the form of Hard Data were also compared and corroborated with the documentary evidences and responses received from the Sub-registrar office and with the data available in public domains on various government portals like 1) anyror.gujarat.gov.in 2) garvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial transactions entered

R K DREAMLAND,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

properties as seized in the form of Digital Data like and in the form of Hard Data were also compared and corroborated with the documentary evidences and responses received from the Sub-registrar office and with the data available in public domains on various government portals like 1) anyror.gujarat.gov.in 2) garvi.gujarat.gov.in and 3) gujrera.gujarat.gov.in. Comparison of the financial transactions entered

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)

vi) On 29th June, 2007, the assessment order was passed. 17. From the aforesaid dates, it is clear that as per the proviso to Explanation to Section 1538, the assessment order could have been passed on or before 3rd July, 2007, ie., period of 60 days after the special audit report was to be submitted to the Assessing Officer

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)

vi) On 29th June, 2007, the assessment order was passed. 17. From the aforesaid dates, it is clear that as per the proviso to Explanation to Section 1538, the assessment order could have been passed on or before 3rd July, 2007, ie., period of 60 days after the special audit report was to be submitted to the Assessing Officer