IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER IT (SS)A No.233& 234 & 235 & 236 /Rjt/2016 Assessment Year: (2009-10 to 2012-13)

(Hybrid Hearing)

Asstt. Commissioner of Income Tax, Vs. M/s. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham - Kutch Öथायीलेखासं./जीआइआरसं./PAN/GIR No.: AAACT1769L (Appellant) (Respondent)

ITA No. 366 /Rjt/2017 Assessment Year: (2013-14)

(Hybrid Hearing)

Asstt. Commissioner of Income Tax, Vs. M/s. Kutch Salt & Allied Gandhidham Circle, Industries Ltd., Gandhidham - Kutch Maitri Bhavan, Plot No.-18, Sector-8, Gandhidham – Kutch Öथायीलेखासं./जीआइआरसं./PAN/GIR No.: AAACT1769L (Appellant) (Respondent)

CO No. 23 & 24 & 25 & 26 /Rjt/2016 Assessment Year: (2009-10 to 2012-13)

(Hybrid Hearing)

M/s. Kutch Salt & Allied Vs. Asstt. Commissioner of Income Industries Ltd., Tax, Maitri Bhavan, Plot No.-18, Gandhidham Circle, Sector-8, Gandhidham – Kutch Gandhidham - Kutch Öथायीलेखासं./जीआइआरस.ं /PAN/GIR No.: AAACT1769L (Appellant) (Respondent)

Appellant by : Shri K. C. Thacker, Ld. A.R.

Respondent by : Shri Sanjay Punglia,Ld.CIT (DR)

Date of Hearing : 20/02/2025 Date of Pronouncement : 17/03/2025 आदशे / O R D E R Per Bench, This is bunch of nine appeals, out of that five appeals filed by the Revenue and four Cross objections filed by the assessee, pertaining to assessment years 2009-10 to 2013-14, all these appeals filed by the Revenue and Cross Objections filed by the assessee, are directed against the separate orders passed by the Commissioner of Income Tax (Appeals), which in turn arise out of separate assessment orders, passed by the assessing officer, under sections 143(3) r.w.s. 153A(1) (b)/143(3) of the Income Tax Act, 1961,( hereinafter referred to as “the Act”).

2. Since, these five appeals filed by the Revenue and four cross objections of assessee, pertain to the same assessee and identical and common issues are involved, therefore, these appeals of revenue and cross objections of assessee, have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity.

3. Although, these appeals filed by the Revenue and Cross-Objections filed by the Assessee, contain multiple ground of appeals. However, at the time of hearing we have carefully perused all the grounds raised by the Revenue as well as cross objections raised by the Assessee. Most of the grounds raised by the Revenue as well as Assessee, are either academic in nature or contentious in nature. However, to meet the end of justice, we confine ourselves to the core of the controversy and main grievances of Revenue and the Assessee as well. With this background, we summarize and concise the grounds raised by the Revenue as well as Assessee as follows:

(i) Ground No.1. The ld. CIT(A) has erred in law and on facts in deleting the addition made on account of washing/ handling loss of salt of Rs.2,67,03,424/-.

This is Ground No.1 of Revenue`s appeal for assessment year 2009-10 in ITA No. 233/Rjt/ 2016. The above similar and identical ground is raised by the revenue, in other appeals, which are as follows:

(a) Ground No.1, in Revenue`s appeal in ITA No.234/Rjt/2016, for assessment year

2010–11, at Rs.5,11,72,998/-.

(b) Ground No. 1 in Revenue`s appeal in ITA No. 235/RJT/ 2016, for assessment year, 2011–12, at Rs. 5,03,65,370/-.

(c ) Ground No.1 in Revenue`s appeal in ITA No. 236/RJT/ 2016, for assessment year

2012–13 at Rs.5,96,99,728/-.

(d) Ground No.2 in Revenue`s appeal in ITA No. 366/RJT/ 2017, for assessment year

2013–14, at Rs.9,63,60,980/-.

(ii) Ground No.2. The ld. CIT(A) has erred in law and on facts in deleting the addition made on account of purchase of group concern of Rs.2,76,70,570/-. This is ground No. 2 of Revenue`s appeal in ITA No. 233/RJT/ 2016 for assessment year 2009 –10. [ There is similar ground No.2 in revenue`s appeal in ITA No.234/RJT