INCOME TAX OFFICER, MORBI vs. MAHENDRAKUMAR BHAGVANDAS RANPURA, MORBI

Income Tax Act. That provision of section 68\nto 69D are residuary sections and the same is applied only where the amount was\nnot taxed under any specific chapter. In the present case in hand, the respondent\nassessee company is engaged in the business

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

section 68 of the Income-tax Act, 1961) cash credits/Unsecured\nloans in respect of Jay Khodiyar Dairy Farm received in the F.Y. relevant to\nA.Y.2012-13 and for the new loans pertains to A.Y.2014-15.\n(i). As regard the loan taken from Jay Khodiyar Dairy Farm during the A.Y.2012-13,\nit is submitted that copy of account of the party and bank

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

business, profession or vocation, The AR has made a failed attempt to distinguish income 'accrued or derived' from the term 'received. The AR has very conveniently ignored the fact that the term used in the treaty is 'received or remitted and the term 'remitted' finds no mention in Singapore Income Tax Act (SITA). Appellant talks about taxation of accrual basis

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

business, profession or vocation, The AR has made a failed attempt to distinguish income 'accrued or derived' from the term 'received. The AR has very conveniently ignored the fact that the term used in the treaty is 'received or remitted and the term 'remitted' finds no mention in Singapore Income Tax Act (SITA). Appellant talks about taxation of accrual basis

M/S. DHARTI ESTATE,JUNAGADH vs. THE PR.CIT-3, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

business income” and not as “income from other sources”. The counsel for the assessee further mentioned that the notice under section 263 issued by the PCIT does not make any mention of section 68

ASHVIN DINESHBHAI JADAV,RAJKOT vs. ITO, WARD-1(1)(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

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

Business activity. During the course of assessment proceedings and on perusal of details furnished, by the assessee, particularly return of income and computation of income, it was noticed by the assessing officer that the assessee has shown income from job work and salary. Besides, no other income/loss has been either shown or claimed by the assessee in his uploaded return

ANILBHAI CHUNILAL BHAYANI,,OKHA vs. INCOME TAX OFFICER, WARD-1(4),, DWARKA

In the result, both appeals of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Amarjit Singhआयकर अपील सं./ Ita.No.363/Rjt/2017 "नधा"रण वष"/ Asstt. Year: 2013-14 Anilbhai Chunilal Bhayani Ito, Ward-1(4) C/O. J.C. & Co., Dwarka. Vs Okha Port, Okha – 361 350. Pan : Abvpb 6284 D

business for which assessee receives professional income of Rs. 3,00,0007- Appellant has claimed deduction of Interest expenditure paid on borrowed funds of Rs.6,91,490/- under Section 57 of the I T Act. The appellant has inadvertently claimed interest income and expense of Rs.2,67,939/- and Professional Fees of Rs. 3,00,000/- under the head Income

ASHWINBHAI CHUNILAL BHAYANI,,OKHA vs. INCOME TAX OFFICER, WARD-1(4),, DWARKA

In the result, both appeals of the assessees are allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Amarjit Singhआयकर अपील सं./ Ita.No.363/Rjt/2017 "नधा"रण वष"/ Asstt. Year: 2013-14 Anilbhai Chunilal Bhayani Ito, Ward-1(4) C/O. J.C. & Co., Dwarka. Vs Okha Port, Okha – 361 350. Pan : Abvpb 6284 D

business for which assessee receives professional income of Rs. 3,00,0007- Appellant has claimed deduction of Interest expenditure paid on borrowed funds of Rs.6,91,490/- under Section 57 of the I T Act. The appellant has inadvertently claimed interest income and expense of Rs.2,67,939/- and Professional Fees of Rs. 3,00,000/- under the head Income

SAGAR JEWELLERS,PORBANDAR vs. DCIT, CIRCLE-2(1), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.222/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2019-20) (Hybrid Hearing) Sagar Jewellers Vs. Dcit Zaveri Bazar, Porbandar, Gujarat Circle-2(1), Jamnagar 360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adbfs5410L (Assessee) (Respondent) Assessee By : Shri K. C. Thaker, Ar Respondent By : Shri Sanjay Punglia, Cit.Dr Date Of Hearing : 01/10/2024 Date Of Pronouncement : 01/01/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am: By Way Of This Appeal, The Assessee Has Challenged The Correctness Of The Order Passed By The Learned Principal Commissioner Of Income Tax (In Short ‘The Pcit’), Under Section 263 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), Dated 21.02.2024, For The Assessment Year (In Short ‘A.Y.’) 2019-20. 2. The Grievances Raised By The Assessee Are As Follows:

68 to 69D and treated it as regular business income only so such order can not be said to be erroneous. Also HIGH COURT OF ANDHRA PRADESH in case of Principal Commissioner of Income-tax v. Deccan jewellera (P.) Ltd. AUGUST 2, 2021 held: Section

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

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

business of construction. He would not sit idle waiting for the department to take initiative and prove his guilt. He should have retracted his admission immediately after the search by appraising the higher authorities. In other words, the AO was of the view that disclosure made under section 132(4) is an admissible evidence, it could not be ignored. More

SHRI CHANDUBHAI RAMJIBHAI KAQTHIRIYA,JASDAN, DIST. RAJKOT-364490 vs. THE PR. CIT-1, RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Or At The Time Of Hearing Of Appeal.”

68 r.w.s. 115 BBE of the Act. Therefore, in our view it is not a case where the AO had not made due enquiries and also not the case where the AO had not applied his mind during the course of assessment proceedings on the issue in hand. Regarding the scope of proceedings

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

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.\nA. Generation of bio fertilizer and biogas is not a single day production\nprocess, whereby on one day raw material inputed/inserted/Feeded_and\nsecond day finished goods got ready