ASST. COMMISSIONER OF INCOME TAX, CC-2, SURAT vs. AALIDHAARA TEXTOOL ENGINEERS PVT. LTD, SURAT

In the result, the grounds of appeal raised by Revenue are partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of appeal are partly allowed. 20. Ground No.3 relates to disallowance under section 80G. The Assessing Officer disallowed Rs.39,75,000/- for the want of registration certificate under section 80G. We find that ld. CIT(A) while granting relief of Rs.6,75,000/- out of disallowance of donation to Shri Saurashtra Patel Kelwani Mandal and Shri Leuva Patel Pragati

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, SURAT vs. M/S AALIDHAR TEXTOOL ENGINEERS PVT. LTD., SURAT

In the result, the grounds of appeal raised by Revenue are partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of appeal are partly allowed. 20. Ground No.3 relates to disallowance under section 80G. The Assessing Officer disallowed Rs.39,75,000/- for the want of registration certificate under section 80G. We find that ld. CIT(A) while granting relief of Rs.6,75,000/- out of disallowance of donation to Shri Saurashtra Patel Kelwani Mandal and Shri Leuva Patel Pragati

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

23. The case of the assessee was re-opened under section 147 on 28.03.2012. Notice under section 148 was served upon assessee on 30.03.2012. The case of assessee was re-opened by Assessing Officer while finalizing assessment for AY 2010-11 by taking view that assessee is not eligible for deduction under section 80IA as it was not having agreement

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

23. The case of the assessee was re-opened under section 147 on 28.03.2012. Notice under section 148 was served upon assessee on 30.03.2012. The case of assessee was re-opened by Assessing Officer while finalizing assessment for AY 2010-11 by taking view that assessee is not eligible for deduction under section 80IA as it was not having agreement

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

23. The case of the assessee was re-opened under section 147 on 28.03.2012. Notice under section 148 was served upon assessee on 30.03.2012. The case of assessee was re-opened by Assessing Officer while finalizing assessment for AY 2010-11 by taking view that assessee is not eligible for deduction under section 80IA as it was not having agreement

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT

In the result, Revenue’s appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

disallowed interest expense against the loan taken from nineteen parties. The Ld. CIT(A) by referring the relevant portion of decision of Hon'ble jurisdictional High Court in the case of Saumya Construction Pvt. Ltd. (supra) and decision of Delhi High Court in the case of Kabul Chawla (supra) and other decisions held that impugned addition are not based

SHRI NEHRUNAGAR CO. OP HOUSING SOCIETY,SURAT vs. INCOME TAX OFFICER, WARD-1(3)(5), SURAT

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Dr. A. L. Sainiआयकर अपील सं./Ita No.478/Srt/2023 Assessment Year: (2017-18) (Physical Hearing) Shri Nehrunagar Co.Op. Housing Vs. The Ito, Society, Ward – 1(3)(5), Umang Hall, Nehrunagar Society, Surat Ichchanath Road, Surat – 395007. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabas2271H (Appellant) (Respondent)

23-9-2019. The case was selected for scrutiny for examination of deduction of Chapter-VIA. We find that during the assessment order the assessing officer issued specific show cause notice for examination of deduction under Chapter VIA. The assessee filed its reply and explained the admissibility of deduction under section 80P, specifically about the deduction of Rs. 2.01 Crore

SIDDHI VINAYAK KNOTS & PRINTS PRIVATE LIMITED,SURAT vs. PR. CIT-2, SURAT, SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.58/Srt/2022 "नधा"रणवष"/Assessment Year: (2017-18) (Physical Court Hearing) Siddhi Vinayak Knots & Prints Pvt. Ltd. Vs. The Pcit-2, A-26, Central Park, Gidc, Pandesara Surat. S.O., Pandesara, Surat-394221. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamcs4421L

disallowance of such payments is too harsh a punishment for delayed payments. Therefore, we recommend that the deduction for delayed payment of statutory liability relating to labour should be allowed in the year of payment like delayed taxes and interest." Based on the report, the Union introduced amendments to the IT Act, including an amendment to Section 43B; the memorandum

NAVAGAM VIBHAG SEVA SAHAKARI MANDLI LTD,NA vs. ARIVS.INCOME TAX OFFICER, WARD 3 , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

2) (d) which exempt dividend and interest income of co- operative society from other co-operative societies (where co-operative bank is one kind of co-operative society only). 10. The Appellant craved leave to Add, Alter, deletes, amend or rescind any of the above grounds of appeal.” We shall first take up assessee’s appeal in ITA No. 86/Srt/2025

MOGAR PARTAPORE VIBHAG SEVA SAHKARI MANDLI LTD,NA vs. ARIVS.DCIT, NAVSARI CIRCLE , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

2) (d) which exempt dividend and interest income of co- operative society from other co-operative societies (where co-operative bank is one kind of co-operative society only). 10. The Appellant craved leave to Add, Alter, deletes, amend or rescind any of the above grounds of appeal.” We shall first take up assessee’s appeal in ITA No. 86/Srt/2025

NAVAGAM VIBHAG SEVA SAHKARI MANDLI LTD,NA vs. ARIVS.ITO, WARD 3 , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

2) (d) which exempt dividend and interest income of co- operative society from other co-operative societies (where co-operative bank is one kind of co-operative society only). 10. The Appellant craved leave to Add, Alter, deletes, amend or rescind any of the above grounds of appeal.” We shall first take up assessee’s appeal in ITA No. 86/Srt/2025

NAVAGAM VIBHAG SEVA SAHKARI MANDLI LTD.,NA vs. ARIVS.ITO, WARD 3 , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

2) (d) which exempt dividend and interest income of co- operative society from other co-operative societies (where co-operative bank is one kind of co-operative society only). 10. The Appellant craved leave to Add, Alter, deletes, amend or rescind any of the above grounds of appeal.” We shall first take up assessee’s appeal in ITA No. 86/Srt/2025

NAVAGAM VIBHAG SEVA SAHKARI MANDLI LTD,NA vs. ARIVS.ITO, WARD-3, NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

2) (d) which exempt dividend and interest income of co- operative society from other co-operative societies (where co-operative bank is one kind of co-operative society only). 10. The Appellant craved leave to Add, Alter, deletes, amend or rescind any of the above grounds of appeal.” We shall first take up assessee’s appeal in ITA No. 86/Srt/2025

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

23) of the Act whether the Assessee can avail the benefit of exemption u/s 11 of the Act. d) Assessee claims to be a religious and charitable Trust meaning that it has been formed for charitable and religious purpose. Charity has been inclusively defined in Section 2(15) of the Act and is commonly understood as altruistic thought and action

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

disallowed deduction under section 80IA by taking view that the assessee operated and maintained old infrastructure undertaking in contravention of the term of agreement and the assessee has not developed infrastructure facilities and is not eligible for deduction under section 80IA. 23. On appeal against the finding of AO in treating the undertaking as not eligible for deduction under section

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

disallowed deduction under section 80IA by taking view that the assessee operated and maintained old infrastructure undertaking in contravention of the term of agreement and the assessee has not developed infrastructure facilities and is not eligible for deduction under section 80IA. 23. On appeal against the finding of AO in treating the undertaking as not eligible for deduction under section

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

disallowed deduction under section 80IA by taking view that the assessee operated and maintained old infrastructure undertaking in contravention of the term of agreement and the assessee has not developed infrastructure facilities and is not eligible for deduction under section 80IA. 23. On appeal against the finding of AO in treating the undertaking as not eligible for deduction under section

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

disallowed deduction under section 80IA by taking view that the assessee operated and maintained old infrastructure undertaking in contravention of the term of agreement and the assessee has not developed infrastructure facilities and is not eligible for deduction under section 80IA. 23. On appeal against the finding of AO in treating the undertaking as not eligible for deduction under section