THE ACIT, CIRCLE-2,, JAMNAGAR vs. M/S HIRAVATI MARINE PRODUCTS (P) LTD.,, PORBANDAR

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

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed"नधा"रण वष"/Asstt. Year:2007-2008 Addl. Commissioner Of Hiravati Marine Products Pvt. Income Tax, Vs Ltd. Range-2, Porbandar, Jamnagar. Pan No: Aabch2110C "नधा"रण वष"/Asstt. Year:2008-2009

2) of the Act. However, it is established law that the advances given in the course of the business are eligible for deduction under section 37(1)/ 28 of the Act. This fact has already been elaborated in detail in the preceding paragraphs. Thus we are of the view claim of the assessee cannot be just rejected merely

HIRAVATI MARINE PRODUCTS PVT. LTD.,,PORBANDAR vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, RANGE-2,, JAMNAGAR

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

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed"नधा"रण वष"/Asstt. Year:2007-2008 Addl. Commissioner Of Hiravati Marine Products Pvt. Income Tax, Vs Ltd. Range-2, Porbandar, Jamnagar. Pan No: Aabch2110C "नधा"रण वष"/Asstt. Year:2008-2009

2) of the Act. However, it is established law that the advances given in the course of the business are eligible for deduction under section 37(1)/ 28 of the Act. This fact has already been elaborated in detail in the preceding paragraphs. Thus we are of the view claim of the assessee cannot be just rejected merely

THE MORBI CITIZENS CREDIT CO-OPRATIVE SOCIETY LIMITED,MORVI vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.285/Rjt/2024 Assessment Year: (2020-21) (Hybrid Hearing) The Morbi Citizens Credit Co- Vs. The Assessment Unit, Operative Society Ltd., Income Tax Department Above Murlidhar Sales National Faceless Agency, Savsar Plot, Ram Assessment Center Chowk, Morbid - 363641 (Nfac), Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabat2850K (Appellant) (Respondent)

19) of the Income Tax Act, 1961 does not make any exclusion about co-operative bank. We note that in order to become a co-operative bank, the first condition is that it should be a co-operative society. Therefore, a co-operative society, later on decides to take license from the Reserve Bank of India to do banking business

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

2) Notwithstanding anything contained in this Act, no deduction in respect of any\nexpenditure or allowance [or set off of any loss] shall be allowed to the respondent\nassessee under any provision of this Act in computing his income referred to in clause\n(a) of sub-section (1).]\"\nAfter the amendment total income includes additional income as voluntarily

ANIL DHANSUKHLAL,RAJKOT vs. INCOME TAX OFFICER (INT. TAXATION) GANDHIDHAM, GANDHIDHAM

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiand Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.68/Rjt/2024 "नधा"रणवष"/ Assessment Year: (2018-19) Anil Dhansukhlal Income Tax Officer बनाम Vakhat Niwas 10, Divan Para (Int.Txn), Gandhidham, Vs. Rajkot -360 001 Amruta Estate Building, Jheelwas, Sadar, Rajkot- 360 001 Pan/Gir No.Ajypd6405F "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रतीक"ओरसे/Assessee By : Shri Bharat Kumar, Ar राज"वक"ओरसे/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

2,24,76,000/- (PB-81-159) (8). Return of Income filed with Inland Revenue Department for the period 2020-21 of Anil Dhansuklal (PB-160) (9). Return of Income filed with Inland Revenue Department for the period 2017-18 of Chetna Chandrakant Mehta (PB-161) (10). Incorporation of Company in Hongkong Kilman Trading Limited and invoice

SHRI GIRISHBHAI NANJIBHAI SOLANKI,RAJKOT vs. THE ITO, WARD-1 (1) (2), RAJKOT

In the result the appeal filed by the assessee is allowed partly for the statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

19. On the other hand, the learned DR contended that the assessment was framed under section 143(3) of the Act and the proceedings initiated under section 148 of the Act were subsequently dropped. Therefore, it cannot be said that there were 2 simultaneous proceedings for the same assessment year. 20. We have heard the rival contentions

AMRUTPUR SEVA SAHKARI MANDALI LTD.,VILLAGE: - AMRUTPUR TALUKA DHARI, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

19 - Whether provisions of section 80AC(ii) make it dear that any deduction that Is claimed under Part C of Chapter VIA would be admissible only if return of income in that case were filed within ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 6 of 10 prescribed due date - Held, yes - Whether thus

SHREE SANALIYA SEVA SAHKARI MANDLI LTD.,LITAL MOTALILIYA SANALIYA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

19 - Whether provisions of section 80AC(ii) make it dear that any deduction that Is claimed under Part C of Chapter VIA would be admissible only if return of income in that case were filed within ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 6 of 10 prescribed due date - Held, yes - Whether thus

DHARESHWAR SEVA SAHAKARI MANDALI LTD. ,VILLAGE: - DHARESHWAR, TALUKA: - RAJULA, DIST. AMRELI vs. THE DCIT (CPC), BANGALORE, BANGALORE

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

19 - Whether provisions of section 80AC(ii) make it dear that any deduction that Is claimed under Part C of Chapter VIA would be admissible only if return of income in that case were filed within ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 6 of 10 prescribed due date - Held, yes - Whether thus

AMBARADI SEVA SAHKARI MANDALI LTD.,AMBARADI , DIST. AMRELI vs. THE DCIT(CPC), BANGALURU, BENGALURU

In the result, all the 4 appeals are allowed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2019-20

19 - Whether provisions of section 80AC(ii) make it dear that any deduction that Is claimed under Part C of Chapter VIA would be admissible only if return of income in that case were filed within ITA Nos.186, 197, 204 & 203/RJT/2022 Assessment Years: 2019-20 (for all) Page 6 of 10 prescribed due date - Held, yes - Whether thus

KATARIA SNACK PELLETS PRIVATE LIMITED,RAJKOT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), RAJKOT

In the result, appeal of the assessee is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं /.Ita No.468/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2015-16 Kataria Snack Pellets Pvt. Ltd. The Acit, Circle-1(1) बनाम 510, Gidc, Metoda Kalawad Road Rajkot Rajkot-360021, Gujarat Vs. Pan : Aafck2028L (अपीलाथ"/Appellant) (""यथ"/Respondent) :

68 on the other hand, as substituted with the provisos, treats any credit in the books of accounts, even by way of allotment of shares; for which no satisfactory explanation is offered. to be liable to income-tax. Clause (viib) of Section 56(2) is triggered at the stage of computation of income itself when the share application money

SHRI VINODKUMAR HIRALAL RAJA,,RAJKOT vs. THE INCOME TAX OFFICER, INTL. TAXN., RAJKOT

In the result, Ground No. 1 of the assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Section 68 of the Act) is similar to Ground No. 1 of the assessee’s appeal. In view of our observations made in Ground No. 1 of the assessee’s appeal, Ground No. 3 of the assessee’s appeal is also allowed. ITA Nos.50&51/Rjt/2018 Shri Vinodkumar Hiralal Raja vs. ITO & 01 other Asst.Year –2006-07 Smt. Pratimaben Vinodkumar

SMT. PRATIMABEN V. RAJA,,RAJKOT vs. THE INCOME TAX OFFICER, INTL. TAXN., RAJKOT

In the result, Ground No. 1 of the assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Section 68 of the Act) is similar to Ground No. 1 of the assessee’s appeal. In view of our observations made in Ground No. 1 of the assessee’s appeal, Ground No. 3 of the assessee’s appeal is also allowed. ITA Nos.50&51/Rjt/2018 Shri Vinodkumar Hiralal Raja vs. ITO & 01 other Asst.Year –2006-07 Smt. Pratimaben Vinodkumar

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

68 of the Income tax Act 1961 (Para 3 of submission). The\nassessee has further stated that there no iota of deficiencies of any kind found with\nregard to the documentation (Para 4 of submission). At para 1.5 of the submission, the\nassessee has emphasized that every transaction has been accounted, documented and\nsupported. The payments are made through banking

THE ACIT, CIRCLE- 1,, RAJKOT-GUJARAT vs. SMT. MANISHABEN N. MASHRU,, RAJKOT-GUJARAT

In the result, appeal of the Revenue in ITA No

Bench: Shri Pramod Kumar & Shri Rajpal Yadavsr.No.

2 lakhs was appeared against the name of Shri Suryakant Maganlal. But this amount was carried from balance of earlier years. As observed by us, section 68 of the Act contemplates where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source

SHRI KAMLESH DEORAJ JAIN,GANDHIDHAM KUTCHH vs. THE ITO WARD 1 , GANDHIDHAM

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 62/Rjt/2025 ("नधा"रण वष"/Assessment Year: (2018-19) Kamlesh Deoraj Jain Income Tax Officer, Ward-1, Plot No 35-36, Devashish Gandhidham, Income Tax Vs. Sector-5 Gandhidham 370201 Office, Plot No.32, Sector No.3, Near Iffco Colony, Gandhidham-370 201 "ायी लेखा सं./जीआइआरसं./Pan/Gir No.: Adopj1769Q (अपीलाथ"/Appellant) (""थ"/Respondent)

2. The Learned CIT (A) erred in law and facts in upholding the action of the Learned assessing officer in making addition u/s 68 as Bogus Purchase despite transactions with Ankur Chemfood Ltd were termed as Circular Transactions by Ld assessing officer himself and upholding the decision of assessing officer despite direct decision of Ahmedabad ITAT on circular transactions

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

68,000 Corporation Limited, 21 Collyer Peesport Quay, # 02-00 HSBC Building, 6 MT Maersk 3 26,96,32,792 Singapore. Princess 7 MT Maersk Kiera 1 4,03,04,065 8 MT Maersk 2 19,15,34,687 I.T.A Nos. 429 & 430/Rjt/2018 A.Y. 2017-18 Page No 3 ISS Shipping India Pvt. Ltd. vs. Dy. CIT Progress

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

68,000 Corporation Limited, 21 Collyer Peesport Quay, # 02-00 HSBC Building, 6 MT Maersk 3 26,96,32,792 Singapore. Princess 7 MT Maersk Kiera 1 4,03,04,065 8 MT Maersk 2 19,15,34,687 I.T.A Nos. 429 & 430/Rjt/2018 A.Y. 2017-18 Page No 3 ISS Shipping India Pvt. Ltd. vs. Dy. CIT Progress