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

reassessments. 3. Ensuring Integrity of Financial Reporting: Segregating eligible business profits upholds the integrity of financial statements, reflecting true and fair views of different business segments. Consequences of Non-Compliance 1. Invalid Deduction Claims: Failure to claim the deduction through the profit and loss account may lead to disallowance, increasing the tax liability of the taxpayer. 2. Administrative Burden: Without

MANSUKHBHAI KANJIBHAI SAKARIYA,RAJKOT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, RAJKOT-1, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं/.Ita No.318/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2016-17 Mansukhbhai Kanjibhai Sakariya The Pr.Commissioner Of बनाम At Khajuri Gundala Income Tax-1, Rajkot. Post Station: Vavdi Vs. Amarnagar, Khajuri Gundala. Pan : Aslps 7027 E (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Rajendra Singhal, Ld.Ar राज"वक"ओरसे/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

vi)The Ld. PCIT erred in law and on fact in arriving at a conclusion to the effect that the assessment order passed by the assessing officer was erroneous as well as prejudicial to the interest of the revenue on the ground that interest awarded on enhanced compensation in respect of compulsory acquisition of agricultural land is chargeable

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 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 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 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

GOPAL SNACKS PVT LTD ,RAJKOT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita Nos. 498 & 499/Rjt/2025 "नधा"रणवष"/ Assessment Years: 2015-16 & 2020-21 बनाम Gopal Snacks Pvt. Ltd. Asst. Commissioner Of Plot No.2322-2324, Gidc Metoda, Income Tax Vs. Lodhika, Rajkot, Gujarat-360021 Circle-1(1), Rajkot Pan : Aadcg6113A (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Prakash Jhunjhunwala & Shri K. K. Maloo, Ars. राज"व क" ओर से/Revenue By : Shri Shramdeep Sinha, Cit.Dr & Shri Abhimanyu Singh, Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 19/11/2025 घोषणा क" तार"ख /Date Of Pronouncement : 08/12/2025

VI-A. Accordingly, a notice u/s 143(2) of the Act was issued on 29.06.2021 and was duly served on the assessee. Subsequently, the notices u/s 142(1) of the Income Tax Act, 1961 along with questionnaire was issued and details were called for under e- assessment scheme. The assessee has stated that during the year under consideration

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपीलसं./Ita No.185/Rjt/2023

9. The Ld. PCIT noticed that even though there was no loss of revenue on account of the disallowance of Rs.70,71,531/-, but the disallowances had impact on the losses to be carried forward. No explanation has been offered for under- reporting of income to the extent of Rs.70,71,531/-, which was prima facie not allowable in view

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

9 Page 18 of 25 ITA No. 611 & 612/RJT/2025 Dff Shri Gandhi Maulana Azas Shramjivi Ashra From the above approval document, under section 151 of the Income Tax Act 1961, it is vivid that there is no signature of the concemed authority, therefore, in the absence of signature by the concemed Authority, the above approval document, cannot be enforced

SHRI GANDHI MAULANA AZAD SHRAMJIVI ASHRA,KUTCH vs. INCOME TAX OFFICER, EXEMPTION WARD 1, RAJKOT, RAJKOT

In the result, appeals of the assessee, are allowed

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

9 Page 18 of 25 ITA No. 611 & 612/RJT/2025 Dff Shri Gandhi Maulana Azas Shramjivi Ashra From the above approval document, under section 151 of the Income Tax Act 1961, it is vivid that there is no signature of the concemed authority, therefore, in the absence of signature by the concemed Authority, the above approval document, cannot be enforced

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

ABDULKADAR HAJIAHMED VADIWALA,JAMNAGAR vs. PR. COMMISSIONER OF INCOME TAX, JAMNAGAR

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.103/Rjt/2025 "नधा"रणवष"/ Assessment Year: 2016-17 Abdulkadar Hajiahmed Vadiwala The Pr.Cit बनाम Maniar Street, Lindi Bazar Jamanagar. Jamnagar-361001 Vs. Pan : Aatpv 4729 Q (अपीलाथ"/Assessee) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Chetan Agarwal, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

9 expense incurred i.e. total of Rs. 3,29,04,667/- we have claimed only expense for the plots which were sold during the year which can not be compared with sale made or not. We have carried forwarded expense in relation stock only and not claimed in this year, hence we request your honour to recheck your observation

DCIT, CENTRAL CIRCLE 2, RAJKOT, RAJKOT vs. SHRI MUKESH MANEKCHAND SHETH, RAJKOT

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

9. In response, to the show cause notice of the assessing officer, the assessee submitted a detailed reply before the assessing officer along with documentary evidences. In his reply, the assessee submitted before the assessing officer that reopening of the assessment is itself bad in law, and the provisions of Section 148, 148A, 149 of the Act, have not been

KUMAR RAMESH SAHU,RAJKOT, GUJARAT vs. ACIT, CIRCLE-2(2), RAJKOT, RAJKOT, GUJARAT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.336/Rjt/2023 (िनधा"रण वष" / Assessment Year : 2009-10) Kumar Ramesh Sahu बनाम/ The Acit, Sundaram, 72/3, New Cirtcle-2(3) Vs. College Wadi Rajkot – 60 001 150Ft5. Ring Road Opp. Meera Apartment Rajkot – 360 005 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aesps 5531 C (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri M.N. Manvar, Ld. Ar Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख / Date Of Hearing 13/01/2025 घोषणा की तारीख /Date Of Pronouncement 04/04/2025 आदेश / O R D E R Per Dinesh Mohan Sinha:

vi) unexplained deposit by cheque Rs. 50,000/- Rs. Rs.36,64,251/- u/s. 68 as discussed in para 11.1 Total Income... Rs. 42,04,261/- Rounded off to... Rs. Rs. 42,04,260/- The Assessing Officer assessed the income of Rs. 42, 04,260/- under Section 143(3) r.w.s. 147 of the Act. Further, the A.O. initiated penalty proceedings under