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

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

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJI KHIMJI PATEL,,BHUJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRASL CIRCLE-II,, RAJKOT-GUJARAT

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

SHRI LALJIBHAI KHIMJIBHAI PATEL,,BHUJ vs. THE INCOME TAX OFFICER, WARD-2,, BHUJ

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Shri Rajpal Yadav, Hon’Ble & Shri Waseem Ahmed Hon’Ble

vi. Insofar as pending assessments are concerned, the jurisdiction to make the original assessment and the assessment under Section 153A merges into one. Only one assessment shall be ITA No.712/RJT/2010 & Others Shri Laljibhai Khimjibhai Patel Vs. ITO 5 made separately for each AY on the basis of the findings of the search and any other material existing or brought

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 05/03/2025 घोषणा की तारीख/Date Of Pronouncement : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

vi). Unexplained Investment in Properties and Rent thereof as per KYC documents of Undisclosed Foreign Bank Account Rs.5,93,51,875/- (Rs.5,82,72,750/- + Rs.10,79,125/-). (vii). Deemed Rent of more than one property reflected in Balance sheet Rs.1,80,000/-. (viii). Disallowance of payment of commission to Shri Rajesh Bhatt Rs.3,00,000/-. (ix). Disallowance of interest

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.76 To 80/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2008-09 To 2012-13 & आयकर अपीलसं/.Ita No. 81/Rjt/2022 निर्धारणवर्ष /Assessment Year: 2014-15 Shri Pankaj Chimanlal Lodhiya 3Rd Floor, Parth, Diwanpara Main Road, Rajkot-3600 001 Pan: Aampl 3903 F (अपीलार्थी/Assessee) बनाम Vs. Assistant Commissioner Of Income-Tax, Central Circle-2 Rajkot, 2Nd Floor, Amruta Estate, M.G. Rad, Rajkot-360 001 (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri Mehul Ranpura, Ar राजस्व की ओर से/Revenue By : Shri Sanjay Punglia, Cit-Dr सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 05/03/2025 : 30/04/2025 Order Per Bench, Captioned Six Appeals Filed By The Assessee, Pertaining To The Assessment Years (Ays) 2008-09 To 2012-13 & Ay 2014-15, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), (“Ld.Cit(A)” For Short) Under Section 250 Of The Income Tax Act, 1961 (“The Act" For Short), Which In Turn Arise Out Of Separate Penalty Orders, Passed By The Assessing Officer U/S 271(1)(C) & 271Aab(1)(C) Of The Act.

vi). Unexplained Investment in Properties and Rent thereof as per KYC documents of Undisclosed Foreign Bank Account Rs.5,93,51,875/- (Rs.5,82,72,750/- + Rs.10,79,125/-). (vii). Deemed Rent of more than one property reflected in Balance sheet Rs.1,80,000/-. (viii). Disallowance of payment of commission to Shri Rajesh Bhatt Rs.3,00,000/-. (ix). Disallowance of interest

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

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

vi). Unexplained Investment in Properties and Rent thereof as per KYC documents of Undisclosed Foreign Bank Account Rs.5,93,51,875/- (Rs.5,82,72,750/- + Rs.10,79,125/-). (vii). Deemed Rent of more than one property reflected in Balance sheet Rs.1,80,000/-. (viii). Disallowance of payment of commission to Shri Rajesh Bhatt Rs.3,00,000/-. (ix). Disallowance of interest

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)

24. We have carefully considered the facts of the case, the submission of the Learned Counsel for the assessee and ld DR for the Revenue and evidences on ACIT v. Kutchh Salt Allied (AY 2010-11 & 2013-14) ITA 233 to 236, 366 & Co. 23 to 25 record. We find merit in the submissions of ld. Counsel for the assessee

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)

24. We have carefully considered the facts of the case, the submission of the Learned Counsel for the assessee and ld DR for the Revenue and evidences on ACIT v. Kutchh Salt Allied (AY 2010-11 & 2013-14) ITA 233 to 236, 366 & Co. 23 to 25 record. We find merit in the submissions of ld. Counsel for the assessee

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)

24. We have carefully considered the facts of the case, the submission of the Learned Counsel for the assessee and ld DR for the Revenue and evidences on ACIT v. Kutchh Salt Allied (AY 2010-11 & 2013-14) ITA 233 to 236, 366 & Co. 23 to 25 record. We find merit in the submissions of ld. Counsel for the assessee

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)

24. We have carefully considered the facts of the case, the submission of the Learned Counsel for the assessee and ld DR for the Revenue and evidences on ACIT v. Kutchh Salt Allied (AY 2010-11 & 2013-14) ITA 233 to 236, 366 & Co. 23 to 25 record. We find merit in the submissions of ld. Counsel for the assessee

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)

24. We have carefully considered the facts of the case, the submission of the Learned Counsel for the assessee and ld DR for the Revenue and evidences on ACIT v. Kutchh Salt Allied (AY 2010-11 & 2013-14) ITA 233 to 236, 366 & Co. 23 to 25 record. We find merit in the submissions of ld. Counsel for the assessee