BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

56,73,002/- U/s 36(1)(viia). The ae was asked to furnish the justification and working for the above claim. In response the assessee has submitted the calculation as under Gross Total income before claiming 10,20,63,748 deduction U/s36(1)(viia) 7.5% 76,54,781 Avg. Aggregate Rural Advances 20,05,106,000 10% of above

SHREE KHEDUT SAHAKARI KHAND UDYOG MANDLI LTD.,BARDOLI vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

SAHAKARI KHAND UDUOG MANDAL LTD.,NA vs. ARIVS.DCIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD.,, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,.,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, , NAVSARI

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

SAHAKARI KHAND UDYOG MANDAL LTD.,,GANDEVI vs. ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG, KAND UDYOG SAHAKARI MANDALI LTD., NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

SAHADARI KHAND UDYOG MANDAL LTD.,,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

ACIT, NA vs. ARI CIRCLE., NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,, NAVASARI

56,23,819/- sustained by the CIT(A) is deleted. The AO is directed to\nallow the full deduction of FCP paid and further grant set-off of brought-\nforward depreciation in accordance with law. Accordingly, all grounds raised\nby the assessee for AY 2016-17 in ITA No.209/SRT/2024 stand allowed and\nthe appeal is allowed in full.\nSahakari Khand

DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

price. In this way, the assessee and other group concerns brought back their unaccounted job work receipts income into regular books of account without payment of tax. The Assessing Officer further stated that all these investor companies are Kolkata based companies and had no prior relationship either business or otherwise, suddenly invest in the assessee group companies at an exorbitantly

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

price. In this way, the assessee and other group concerns brought back their unaccounted job work receipts income into regular books of account without payment of tax. The Assessing Officer further stated that all these investor companies are Kolkata based companies and had no prior relationship either business or otherwise, suddenly invest in the assessee group companies at an exorbitantly

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

price. In this way, the assessee and other group concerns brought back their unaccounted job work receipts income into regular books of account without payment of tax. The Assessing Officer further stated that all these investor companies are Kolkata based companies and had no prior relationship either business or otherwise, suddenly invest in the assessee group companies at an exorbitantly

BILAKHIA HOLDING P LTD,VAPI vs. THE ACIT,VAPI CIRCLE, VAPI

In the result, the appeal of the assessee is allowed for assessment year 2010-11

Bench: Shri Pawan Singh, Hon'Ble & Dr.Shri Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A’S No.181 & 182/Srt/2017 "नधा"रण वष"/Assessment Years: 2009-10 & 2010-11 Bilakhia Holding P Ltd., Vs The Assistant Bilakhia House, Muktanand Marg, . Commissioner Of Income Chala, Surat – 394 520. Tax, Vapi Circle, Vapi. [Pan: Aadcs 4420 J] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Gopalakrishnan Aiyer – Ar राज"वक"ओर से /Revenue By Smt. Usha Shrote – Sr.Dr सुनवाई की तारीख/ Date Of Hearing: 13.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 19.05.2021 आदेश /O R D E R Per Dr.Arjun Lal Saini, Accountant Memeber: 1. Captioned Two Appeals Filed By Assessee Pertaining To Assessment Year 2009-10 & 2010-11, Are Directed Against The Separate Orders Passed By The Ld.Cit(A), Which In Turn Arise Out Of Separate Orders Passed By The Assessing Officer Under Section 271(1)(C) Of The Income Tax Act, 1961 (Here In After Referred To As The ‘Act’).

section 92-B of the IT Act and the transfer pricing provisions are not applicable as there is no income. Therefore, considering the same, as the assessee has also given loan to obtain the benefits of full profits earned by the subsidiary and to ensure full control over the operations of the subsidiary. Therefore, this is not comparable