AALIDHARA TEXTOOL ENGINEERS PVT. LTD,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.94/Srt/2020 ("नधा"रणवष" / Assessment Years: (2014-15) (Virtual Court Hearing) Alidhara Textool Engineers Pvt. Ltd., Vs. The Pcit-1, Surat. Plot No.168, Udhyog Nagar Road, Udhna, Surat -394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacd8469M (Assessee) (Respondent)

3) of the Act, dated 29.12.2017, for assessment year 2014-15, carried the matter in appeal before the ld CIT(A), then ld CIT(A) deleted the disallowance under section 14A r.w.r.8D of the Rules, therefore principle of doctrine of merger has applied in the assessee’s case, and ld. PCIT need not to exercise the jurisdiction under section

SHRI ANANDKUMAR RAWATRAM JOSHI,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(2),, SURAT

In the result, the appeal of the assessee for the

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No. 2112/Ahd/2014 िनधा"रण वष"/A.Y.:2007-08 & & I.T.A. No. 2135 /Ahd/2014 A.Y. 2008-09 Shri Anand Kumar Joshi Vs. Income Tax Officer, 407 Manoj Market Ring Road Ward- 2(2) Surat Surat 395002 Pan: Aelpj2447K अपीलाथ" Appellant ""यथ"/Respondent

disallowance of Rs. 58,29,830 under section 40A(3)(a) of the Act as not covered by Rule 6DD(k). 11

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. DY. COMMISSIONER OF INCOME TAX,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

3) of the Act was completed on 22.12.2018. In the computation of income the assessee claimed deduction under section 80IA of Rs.2.04 crore, the AO while passing the assessment order restricted the deduction to the extent of Rs.1.72 crore, thereby disallwaning part deduction under section 80IA. The AO in (A.Y s 06-07 & 07-08) Bharuch Enviro Infrastructure Ltd. & Enviro

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

3) of the Act was completed on 22.12.2018. In the computation of income the assessee claimed deduction under section 80IA of Rs.2.04 crore, the AO while passing the assessment order restricted the deduction to the extent of Rs.1.72 crore, thereby disallwaning part deduction under section 80IA. The AO in (A.Y s 06-07 & 07-08) Bharuch Enviro Infrastructure Ltd. & Enviro

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

3) of the Act was completed on 22.12.2018. In the computation of income the assessee claimed deduction under section 80IA of Rs.2.04 crore, the AO while passing the assessment order restricted the deduction to the extent of Rs.1.72 crore, thereby disallwaning part deduction under section 80IA. The AO in (A.Y s 06-07 & 07-08) Bharuch Enviro Infrastructure Ltd. & Enviro

INCOME TAX OFFICER, SURAT vs. SATYAM EDUCATIONAL TRUST, SILVASA

In the result, ground of appeal raised by the revenue in this appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

disallowed only under Section 13(3) as Section 13(3) is not applicable as there was no direct or indirect benefit availed by related party. The assessee trust is registered under Section 12A of the Act and is eligible for application of income under Section 11

INCOME TAX OFFICER, SURAT vs. SATYAM EDUCATIONAL TRUST, SILVASA

In the result, ground of appeal raised by the revenue in this appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

disallowed only under Section 13(3) as Section 13(3) is not applicable as there was no direct or indirect benefit availed by related party. The assessee trust is registered under Section 12A of the Act and is eligible for application of income under Section 11

GREEN MUMBAY LIONS EDUCATION TRUST,NA vs. ARIVS.EXEMPTION WARD, SURAT, INCOME-TAX OFFICE SURAT

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

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.547/Srt/2025 Assessment Year: (2023-24) (Hybrid Hearing) Green Mumbay Lions Education Vs. Ito, Trust, Exemption Ward, Opp – Ratnakar Society, C/O Sgm Surat Shiroya English School, Chhapra Road, Navsari - 396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aatg8361Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Bhupendra Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/11/2025 Date Of Pronouncement 23/12/2025

disallowance of Rs.43,79,990/- as deemed income u/s 11(3) or Explanation – 4 of section 10(23C) of the Act. In the appellate

SHREE VIMALJIN RELIGIOUS CHARITABLE TRUST,VAPI vs. ASSTT. DIRECTOR OF INCOME TAX, CPC, BENGALURU

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 239/Srt/2021 "नधा"रण वष"/Assessment Year: (2016-17) (Physical Court Hearing) Shree Vimaljin Religious Charitable Trust, Vs. The Acit, Cpc, 102, Shantinath Apartment, Nehru Street, Bangaluru. Vapi-396191. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalts6046F

disallowed the claim of expenditure by taking view that the assessee failed to produce the registration certificate under section 12AA of the Act. The ld.CIT(A) also held that the assessee would have obtained the copy of registration from the office of Commissioner(Exemption) or to apply it again, which the assessee has not done. 11. Before us, the ld.AR

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. ASSTT. COMMISSIONER OF INCOME TAX., BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. ASSTT. COMMISSIONER OF INCOME TAX,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

3) was completed on 30.12.2011. As per the same, deduction claimed under section 80IA was disallowed and assessee did not fulfil the perquisite the claiming of deduction under section 80IA in this year also and the assessee has claimed deduction of Rs.1.01 crores which was not allowable. On receipt of reasons recorded, the assessee filed objection dated 18.12.2012 against

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. DY. COMMISSIONER OF INCOME TAX,, BHARUCH

In the result, this appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

11. On the facts and in circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in levying interest under section 234D of the Act without appreciating the fact that interest under the said section cannot be levied pursuant to the assessment made under section 147 of the Act if the regular