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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

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

house property, it is to submit that during\nthe course of assessment proceedings, I had suo-moto offered deemed rental income\nof Rs. 72.000/-p.a. looking to the locality and standardized rent in the area. However,\nwhile finalizing the assessment for the year under consideration, an addition of Rs.\n1,80,000/- was made without bringing any credible evidence

SEABIRD MARINE SERVICES PRIVATE LIMITED,JAMNAGAR vs. ACIT, CIRCLE - 1, JAMNAGAR, JAMANGAR

In the result, ground No.4 raised by the assessee is allowed

house Property instead of business income and considering\nthe same as not eligible for computing deduction u/s 801A though the Rent Income has\ndirect nexus with the 80IA eligible business activity of the assessee, being income\nderived from the business and further issue is covered in favour of assessee by the\ndecision of Rajkot bench in assessee's case

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

THE DY. COMMR. OF INCOME TAX, CIR.-1(1), RAJKOT-GUJARAT vs. M/S ARYAN ARCADE PVT. LTD.,, RAJKOT-GUJARAT

In the result, appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarasstt.Year :2012-13 Dcit, Cir.1(1) M/S.Aryan Arcade P.Ltd. Rajkot. Vs C/O. Milestone Property Mg Basement Grant Central Mall Rajkot.

23(2) and not to other house properties. Therefore, the assessee’s claim had been rightly disallowed by the AO, he contended. 8. The ld.counsel for the assessee, on the other hand, countered by pointing out that this issue has already been dealt in a number of decisions by courts, wherein it has been categorically held that section

SHRI BHAKTINAGAR CO.-OP. HO.SOC. LTD.,RAJKOT vs. THE PR.CIT-3, RAJKOT

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2014-15 Shri Bhaktinagar Co-Operative Vs. Pr.Cit-Iii Housing Society Ltd. Aaykar Bhavan Meghani Rang Bhavan Rajkot. Rajkot. Pan : Aaaas 2363 M अपीलाथ"/ (Appellant) "" यथ"/(Respondent) Assessee By : Shri Gautam Achary, Ld.Ar Revenue By : Shri Shramdeep Sinha, Ld.Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 10/08/2023 घोषणा क" तार"ख /Date Of Pronouncement: 08/11/2023 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Passed By The Ld.Pr.Commissioner Of Income Tax-Iii, Rajkot [Hereinafter Referred To As “Ld.Pr.Cit By Exercising His Power Under Section 263 Of The Income Tax Act, 1961 ("The Act" For Short) Dated 18.2.2019 Pertaining To The Asst.Year2014-15. 2. The Grounds Raised In The Appeal Read As Under:

1) On the facts and in the circumstances of the case, the order passed by the learned Pr.C.I.T. u/s. 263 of the l.T. Act is ab initio void being bad in law. 2) On the facts and in the circumstances of the case, the learned Pr.C.I.T. erred in setting aside the assessment order dated 26th December, 2016 and directing

MISS PARI ANIL GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

23 of the Act, if a person\nhold more than one house property then only one house property can be\nclaimed as self-occupied at his/her option and for remaining properties the\nannual value of the house or houses, other than the self-occupied one shall\nbe determined under sub-section (1), as if such house or houses had been

LATE SMT. PRITI A. GANDHI L/R. SHRI ANILBHAI A. GANDHI, RAJKOT,RAJKOT vs. THE PR. CIT-1, RAJKOT, RAJKOT

23 of the Act, if a person\nhold more than one house property then only one house property can be\nclaimed as self-occupied at his/her option and for remaining properties the\nannual value of the house or houses, other than the self-occupied one shall\nbe determined under sub-section (1), as if such house or houses had been

PRAMUKH ARANYA DEVELOPERS,JUNAGADH vs. PR. CIT, RAJKOT-1, RAJKOT, RAJKOT

House Property\" u/s.22 r.w.s.23 of the Act, which\nhas resulted into under assessment,as per learned PCIT, to the tune of\nRs.84,86,212/-.\n11.About the first issue, regarding unsecured loan, without charging interest\ngiven to family members and associated concerns, wherein the PCIT has\nworked out the interest to the tune of Rs.1,09,21,304/-. The Ld.Counsel\nsubmitted

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)

C. Thacker, vehemently argued that assessee, has huge funds of Rs.28,34,76,940/-, available, as on 31-03-2011, on which no interest is payable, as against interest-free advances given to parties of Rs.4,35,00,000/-. This included Rs.2,15,00,000/- given to Maharaja Salt Works, as advance for purchase of salt. The said party failed

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)

C. Thacker, vehemently argued that assessee, has huge funds of Rs.28,34,76,940/-, available, as on 31-03-2011, on which no interest is payable, as against interest-free advances given to parties of Rs.4,35,00,000/-. This included Rs.2,15,00,000/- given to Maharaja Salt Works, as advance for purchase of salt. The said party failed

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)

C. Thacker, vehemently argued that assessee, has huge funds of Rs.28,34,76,940/-, available, as on 31-03-2011, on which no interest is payable, as against interest-free advances given to parties of Rs.4,35,00,000/-. This included Rs.2,15,00,000/- given to Maharaja Salt Works, as advance for purchase of salt. The said party failed

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)

C. Thacker, vehemently argued that assessee, has huge funds of Rs.28,34,76,940/-, available, as on 31-03-2011, on which no interest is payable, as against interest-free advances given to parties of Rs.4,35,00,000/-. This included Rs.2,15,00,000/- given to Maharaja Salt Works, as advance for purchase of salt. The said party failed

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)

C. Thacker, vehemently argued that assessee, has huge funds of Rs.28,34,76,940/-, available, as on 31-03-2011, on which no interest is payable, as against interest-free advances given to parties of Rs.4,35,00,000/-. This included Rs.2,15,00,000/- given to Maharaja Salt Works, as advance for purchase of salt. The said party failed

M/S. D.M.L. EXIM PVT. LTD.,,RAJKOT-GUJARAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

property in India or control and management vested in India, are not satisfied in the present case. The commission expenses paid on export sales to a non-resident admittedly for services rendered outside India is not coming under the purview of Sec. 40(a)(ia) of the Act. It is relevant to mention that the ‘commission’ simpliciter is not fees

THE DY. COMMR. OF INCOME TAX, CIR.-1(2), RAJKOT-GUJARAT vs. M/S DML EXIM PVT. LTD.,, RAJKOT-GUJARAT

Appeal is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

property in India or control and management vested in India, are not satisfied in the present case. The commission expenses paid on export sales to a non-resident admittedly for services rendered outside India is not coming under the purview of Sec. 40(a)(ia) of the Act. It is relevant to mention that the ‘commission’ simpliciter is not fees