IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER आयकरअपीलसं./ITA No. 29/RJT/2018 (cid:467)नधा(cid:91)रणवष (cid:91) / Assessment Year: (2012-13)

(Hybrid Hearing)

The DCIT, circle – 3(1), Vs. M/s. Sonpal Exports Pvt. Ltd.

Rajkot Aayakar bhavan, Room Dhari Bagsara Road, Nr. Ice No. 114, 1^st floor, race course Factory, Amreli ring road, Rajkot PAN No.: AAJCS0177N (Assessee) (Respondent)

Assessee by : Shri Kalpesh Doshi, Ld. AR Respondent by : Shri Praveen Verma, Ld. CIT(DR)

Date of Hearing : 24/06/2025 Date of Pronouncement : 21/08/2025 आदेश / O R D E R Per, Dr. Arjun Lal Saini, AM;

By way of this appeal, the Revenue, has challenged correctness of the order dated 16.11.2017, passed by the learned CIT(A), in the matter of assessment under section 143(3) of the Income Tax Act 1961, for the assessment year 2012-13. Grievances raised by the Revenue, which are interconnected and will be taken up together, are as follows:

“1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 13,96,33,023/- holding that provision of section 195 will not be