HASMUKHBHAI DEVRAJBHAI GABANI,SURAT vs. ITO, WARD 3(2)(3), SURAT

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ITA 347/SRT/2025Status: DisposedITAT Surat30 October 2026AY 2016-1711 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partly allowed Ground No. 1 concerning the addition of Rs. 40,00,000/- on account of unsecured loans. While acknowledging that the assessee had provided some documentation, the Tribunal noted that the creditors had deposited cash in their bank accounts immediately before advancing the loans. Considering the surrounding circumstances and the alternative plea of the Revenue, the Tribunal sustained 50% of the addition, i.e., Rs. 20,00,000/-, and deleted the remaining Rs. 20,00,000/-. The reasoning was that the balance was available with the creditors, but the direct nexus and creditworthiness were not fully established. For Ground No. 2, the Tribunal allowed the appeal concerning the addition of Rs. 14,04,322/- on account of cash deposits. The Tribunal found that the assessee's case contained a proper day-to-day running balance in the cash book, and the assessee had explained the source of cash generated and established a nexus between withdrawals and deposits. Therefore, the addition was not sustained. The decision of the Gujarat High Court in Blessing Construction vs. ITO was considered applicable.

What were the facts?

The assessee, Hasmukhbhai Devrajbhai Gabani, filed an appeal against the order of the CIT(A), NFAC, Delhi, for Assessment Year 2016-17. The assessee, engaged in embroidery job work, declared an income of Rs. 3,77,380/-. His case was selected for limited scrutiny. The Assessing Officer (AO) observed that the assessee imported machinery costing Rs. 2,07,04,322/-, financed by a term loan of Rs. 1,53,00,000/- from Allahabad Bank. The balance Rs. 40,00,000/- was sourced from third parties as unsecured loans, and Rs. 14,04,322/- was invested by the assessee through cash deposits in his bank account. The AO noted that lenders often deposited cash before advancing loans, deeming it suspicious. The AO made an addition of Rs. 54,04,322/- for unexplained unsecured loans and cash deposits. The CIT(A) dismissed the assessee's appeal.

What were the issues?

1. Whether the addition of Rs. 40,00,000/- on account of alleged unexplained unsecured loans is justified, as per Section 68 of the Income Tax Act, 1961. - Assessee's contention: The assessee argued that the lenders provided funds via account payee cheques, and their identity, creditworthiness, and genuineness were established through confirmations, bank statements, balance sheets, and audited financial statements. The assessee claimed to have discharged the onus of proving the source of funds, not the source of source. Reliance was placed on decisions like Orissa Corpn. (P) Ltd. and Gopal Heritage (P) Ltd. - Revenue's contention: The Revenue argued that the transactions were suspicious due to the immediate cash deposits by lenders before advancing loans, the timing and amounts being directly connected. The creditworthiness of lenders was also questioned, citing their low declared income versus the loan amounts. Reliance was placed on PCIT vs. M/s. NRA Iron Steel Pvt. Ltd. As an alternative plea, the Revenue suggested sustaining 50% of the addition. 2. Whether the addition of Rs. 14,04,322/- on account of unexplained cash credits (deposits) is justified, as per Section 68 of the Income Tax Act, 1961. - Assessee's contention: The assessee claimed the cash deposits were out of his own funds, derived from cash withdrawals from the bank and embroidery job work income. The assessee maintained a day-to-day cash book and submitted it, asserting that the AO did not doubt the cash books or transaction details. - Revenue's contention: The Revenue argued that the assessee failed to establish the availability of cash. The cash book commenced from June 1, 2015, lacked a proper running balance, and the opening cash balance could not be verified. The assessee's explanation for the source of cash was inconsistent, and no satisfactory cash-flow statement or withdrawal-to-deposit nexus was provided. The declared income was significantly lower than the cash deposited.

Which sections of the Income-tax Act were involved?

Section 68,Section 143(2),Section 142(1),Section 133(6)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT BENCH, SURAT

Before: MS. SUCHITRA KAMBLE & SHRI B.M. BIYANI

Pronounced: 30.10.2026

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE MS. SUCHITRA KAMBLE, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER ITA No.347/SRT/2025 (निर्धारण वर्ा/Assessment Year: 2016-17) HASMUKHBHAI DEVRAJBHAI INCOME TAX OFFICER, GABANI WARD - 3(2)(3) B 602, 6TH FLOOR, OM HERITAGE AAYAKAR BHAWAN, NEAR HEIGHTS, OPP BRAHMALOK, Vs. MAJURA GATE, OPP. NEW DABHOLI, SURAT-395004, CIVIL HOSPITAL, SURAT GUJARAT SURAT-395001, GUJARAT अपीलधर्थी (APPELLANT) प्रत्यर्थी (RESPONDENT)

Permanent Account Number of Assessee: AIHPG5961B

अपीलधर्थी द्वारा/Appellant represented by: Shri Sapnesh Sheth, Advocate प्रत्यर्थी द्वारा/Respondent represented by: Shri Ashish Kumar, Sr. DR सुनवाई की तारीख / Date of conclusion of hearing: 06.08.2026 घोषणा की तारीख / Date of pronouncement: 30.10.2026

O R D E R PER : SUCHITRA KAMBLE, J M: The appeal filed by the assessee is against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short “CIT(A)”] dated 21.01.2025 for the Assessment Year (in short “AY”) 2016-17.

2.

The assessee has raised the following grounds of appeal: “1. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals), NFAC has erred in confirming the action of assessing officer in making addition of Rs. 40,00,000/- as alleged unexplained loans.

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO 2. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals), NAFC has erred in confirming the action of assessing officer in making addition of Rs. 14,04,322/-on as unexplained cash credits.

3.

It is therefore prayed that above addition made by assessing officer and confirmed by Commissioner of Income-tax (Appeals) may please be deleted.

4.

Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 3. During the year under consideration, the assessee was engaged in business of embroidery job work under his proprietorship firm namely, M/s. Shreeji Fashion. The assessee filed return of income for A.Y. 2016-17 on 29.09.2016 declaring total income of Rs.3,77,380/-. The case was selected for limited scrutiny. Subsequently, statutory notice u/s.143(2) of the Income Tax Act, 1961 (in short, “the Act”) was issued on 18.08.2017 and served upon the assessee. Thereafter notice u/s.142(1) r.w.s. 129 of the Act alongwith questionnaire was issued on 13.06.2018. Further notice u/s. 142(1) dated 12.07.2018 and 16.10.2018 were issued and served upon the assessee. The assessee filed response as well as details from time to time. The Assessing Officer observed that the assessee has imported machinery costing to Rs.2,07,04,322/- sourcing Rs.1,53,00,000/- from term loan from Allahabad Bank, while balance of Rs.40,00,000/- has been sourced from various third parties providing the fund to assessee in form of unsecured loan. Balance of Rs.14,04,322/- invested by the assessee by depositing cash on various dates in his own Bank current account maintain with Allahabad Bank. The assessing Officer further observed that almost all parties who provided loan to the assessee during the year have deposited cash in their respective bank account which was viewed by department as suspicious as the assessee could not prove genuineness of the transactions involved in. The Assessing Officer issued show cause notice dated 12.11.2018 asking the assessee in respect of unsecured loan of Rs.40,00,000/- and cash deposits of Rs.14,04,322/-. The assessee filed reply. The Assessing Officer issued notice u/s.133(6) of the Act to M/s. Shree Hari Embroidery (Rs.10,50,000/- loan given to assessee) in respect of 2

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO unsecured loan but the notice returned back with remark ‘Left’. The Assessing Officer observed that the assessee could not explain the unsecured loan as well as cash deposits, therefore, made addition of Rs.54,04,322/-.

4.

Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee.

5.

The Ld. Authorized Representative (in short “the Ld. AR”) for the assessee submitted that as regards to Ground No.1 relating to addition on account of unsecured loans of Rs.40 Lakhs, the assessee during the year under consideration imported machinery costing Rs.2,07,04,322/- sourcing Rs.1,53,00,000/- from term loan from Allahabad Bank, Surat while balance of Rs. 40,00,000/- has been sourced from various third parties providing the fund to the assessee in the form of unsecured loan. The balance of Rs. 14,04,332/- invested by the assessee out of his own funds. The Ld. AR further submitted that the lenders have provided the funds to the assessee via account payee cheque. The assessee submitted copy of confirmation alongwith bank statements, copy of cash flow statements, copy of acknowledgment of return of income, copy of P&L account and Balance Sheet of the lenders before the Assessing Officer. In fact, loan given to the assessee was duly reflected in the balance sheet of lenders. The audited balance sheet of the assessee was also reflected the loan taken from the parties and the assessee had duly submitted all the relevant documents to prove the genuineness of the transaction and identity and creditworthiness of the lenders. The assessee submitted all the details during the assessment proceeding. The Ld. AR submitted that the assessee is liable to prove source of funds only & not source of source of funds. The Ld. AR relied upon the following decisions: i) Orissa Corpn. (P) Ltd. (Civil Appeal No. 1379-1380 (NT) of 1974) 159 ITR 78 (SC) ii) Gopal Heritage (P) Ltd. (Tax Appeal No. 243 of 2021) (Guj. HC)

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO iii) Ranchhod Jivabhai Nakhava (208 Taxman 35) (Appeal No. 30 of 2011) (Guj. HC) iv) Rohini Builders (Tax Appeal No. 65 of 2001) 256 ITR 360 (Guj. HC) v) Murlidhar Lahorimal vs. CIT (153 taxman 451) (Guj. HC) vi) CIT vs. Pragati Co-op. Bank Ltd. 278 ITR 170 (Guj. HC) vii) Hingora Industries Ltd. (ITA No. 2109/Ahd/2018 dt. 12.10.2012) Thus, the Ld. AR submitted that the addition on account of unsecured loan amounting to Rs. 40,00,000/- be deleted.

6.

As relates to ground no. 2 regarding addition on account of unexplained cash of Rs. 14,04,332/-, the ld. AR submitted that during the year under consideration the machinery imported was partly financed by the assessee out of his own funds amounting to Rs. 14,04,332/-. During the course of assessment proceedings, the assessee explained that the assessee was engaged in the business of embroidery job work income. The assessee audited his books of accounts and maintaining day to day cash book regularly. The cash deposits in the bank account during the year under consideration were made out of cash withdrawals from the bank and embroidery job work income. During the course of assessment proceedings, the assessee furnished day to day cash book duly reflecting the same. Thus, assessee had duly discharged onus of proving nature and source of credits and hence, addition made u/s. 68 be deleted. The Ld. AR further submitted that the Assessing Officer never doubted the cash books and details of transactions carried out by the assessee.

7.

The Ld. Departmental Representative (in short “the Ld. DR”) for the Revenue submitted that as regards Ground No.1 relating to addition of Rs.40,00,000/- on account of unsecured loans, the Assessing Officer made the same under section 68 of the Act in respect of unsecured loans received from five persons. The assessee has relied upon confirmations, PAN, ITR acknowledgements, computations, balance sheets and bank statements of the lenders and has contended that the identity and genuineness of the transactions stand established. However, the issue has to be examined not

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO merely on the basis of documents produced but on the totality of the surrounding circumstances. The most important fact in the present case is that, in each of the five cases, the lender deposited cash in his/her bank account immediately before advancing the loan to the assessee. In three cases, cash of Rs.10,50,000/-, Rs.10,50,000/- and Rs.9,00,000/- was deposited on 18.12.2015 and exactly corresponding amounts were advanced to the assessee on 19.12.2015. Similarly, in the remaining two cases, cash of Rs.5,00,000/- each was deposited on 01.01.2016 and the corresponding loans were given on 02.01.2016. Thus, the cash deposits and the subsequent loans are directly connected both in amount and timing. The creditworthiness of the lenders is also doubtful. As recorded by the Assessing Officer, the income declared by the lenders for A.Y. 2015-16 ranged only between approximately Rs.2.60 lakh and Rs.3.03 lakh, whereas the loans advanced by them ranged between Rs.5 lakh and Rs.10.50 lakh. The bank accounts also did not demonstrate sufficient regular financial activity or availability of funds before the cash deposits. The circumstances therefore do not support the claim that the lenders independently possessed the funds which were subsequently advanced to the assessee. It is also relevant that two of the lenders were closely related to the assessee. They accounted for Rs. 21,00,000/- out of the total loan of Rs. 40,00,000/-. Further, in the case of one lender, notice issued under section 133(6) was returned with the postal remark "Left", and the lender could not be verified at the address furnished by the assessee. The Revenue submits that the mere filing of confirmation, PAN, ITR and bank statement does not automatically establish the genuineness of a credit. Under section 68, the assessee is required to satisfactorily establish the identity of the creditor, creditworthiness of the creditor and genuineness of the transaction. In the present case, although the assessee has furnished confirmations, PAN, ITRS and bank statements, the surrounding circumstances appearing from the very documents furnished by the assessee raise serious doubts regarding the genuineness and creditworthiness of the lenders. The issue is squarely supported by the

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO judgment of the Hon'ble Gujarat High Court, being the jurisdictional High Court, in Blessing Construction v. Income-tax Officer, [2013] 32 taxmann.com 366 (Gujarat). The facts of the said case are particularly relevant to the present case. In Blessing Construction, the assessee had received unsecured loans from different persons. The bank accounts of the depositors showed meagre balances, followed by substantial cash deposits immediately before the amounts were advanced to the assessee. The Court noted that the capacity of the depositors to raise such cash was not established and upheld the addition under section 68. The Hon'ble Gujarat High Court, after examining the entire material on record, held that where the bank accounts of the creditors contained meagre balances and substantial amounts were deposited in cash immediately before the amounts were advanced to the assessee, and where the capacity of the creditors to raise such funds was not established, the genuineness of the transactions itself was not established. The Hon'ble Court further clarified that such a case is not merely a case of asking the assessee to prove the "source of source"; rather, the conclusion is based on the facts and appreciation of the evidence demonstrating that the transaction itself was not genuine. The ratio of the aforesaid judgment of the jurisdictional High Court is directly applicable to the facts of the present case. In the present case also, the bank accounts of all five lenders show that cash was deposited immediately before the loans were advanced to the assessee. In three cases, cash of Rs.10,50,000/-, Rs.10,50,000/- and Rs.9,00,000/-was deposited on 18.12.2015 and the corresponding loans were given on 19.12.2015. In the remaining two cases, cash of Rs.5,00,000/- each was deposited on 01.01.2016 and the corresponding loans were given on 02.01.2016. Thus, the pattern is not an isolated transaction but is repeated in respect of all five lenders. Further, the declared income of the lenders is substantially lower than the amounts advanced by them. Their bank accounts also do not demonstrate sufficient independent availability of funds before the cash deposits. In one case, the notice issued under section 133(6) was returned with the remark "Left". Thus, the facts relating to the

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO financial capacity and immediate source of the funds remain unexplained. The Revenue therefore submits that the present case is even more significant inasmuch as the same pattern of cash deposit followed immediately by corresponding loan is found in respect of all five lenders. The documentary evidence relied upon by the assessee, instead of supporting the genuineness of the transactions, reveals the circumstances in which the funds were introduced into the bank accounts of the lenders immediately before being transferred to the assessee. The assessee has relied upon various decisions including DCIT v. Rohini Builders, CIT v. Ranchhod Jivabhai Nakhava, Gopal Heritage (P.) Ltd., M/s. Kejriwal Industries Ltd. and other cases. However, those decisions are distinguishable on facts. More importantly, the present case is governed by the judgment of the Hon'ble Gujarat High Court in Blessing Construction(supra), wherein the Court considered materially similar circumstances and upheld the addition under section 68. The said decision, being of the jurisdictional High Court, deserves to be given due weight and is directly applicable to the facts of the present case. In view of the above facts and particularly in view of the binding principles laid down by the Hon'ble Gujarat High Court in Blessing Construction, the Revenue respectfully submits that the assessee has failed to satisfactorily establish the genuineness and creditworthiness of the disputed unsecured loans. Accordingly, the addition of Rs. 40,00,000/- deserves to be sustained in full. The Ld. DR also relied upon the decision of the Hon’ble Supreme Court in case of PCIT vs. M/s. NRA Iron Steel Pvt. Ltd. (2019) 412 ITR 161 (SC).

8.

In alternate, without prejudice to the Revenue's primary submission, the Ld. DR submitted that the entire addition of Rs. 40,00,000/- is sustainable, it is respectfully submitted that, if the Tribunal is inclined to grant any relief from the full addition, a reasonable portion of the addition may be sustained having regard to the peculiar facts and circumstances of the present case. In this regard, reliance is placed on the decision of the ITAT, Indore Bench in Shri Om Prakash Patidar (HUF) v. ITO, ITA 7

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO No.220/Ind/2017, A.Y. 2013-14, order dated 03.01.2019. In that case also, the creditors had deposited cash in their bank accounts shortly before advancing loans to the assessee. The Tribunal found the creditworthiness of the creditors doubtful. However, considering the overall facts and the possibility of some genuine component, the Tribunal sustained 50% of the addition and deleted the balance 50%. The aforesaid decision is relied upon only for the limited and alternative proposition that, where the Tribunal considers that the entire credit may not be treated as unexplained, an appropriate percentage of the disputed amount can be sustained having regard to the facts of the particular case. The Ld. DR further submitted that various Benches of the Tribunal, including the Surat Bench, have adopted different percentages in appropriate cases depending upon the nature of the transactions, evidence available on record and the deficiencies noticed in the explanation furnished by the assessee. Therefore, there is no fixed or universal percentage which can be applied mechanically to every case. In the present case, the following circumstances deserve particular consideration:

a. the cash deposited by each lender was exactly equal to the loan subsequently advanced; b. the cash was deposited only one day before the loan was advanced; c. the same pattern was repeated in respect of all five lenders; d. the declared income of the lenders was substantially lower than the amount advanced; e. the bank accounts did not establish sufficient independent availability of funds before the cash deposits; one lender could not be verified at the address furnished by the assessee; and f. the immediate source of the cash deposited by the lenders has not been satisfactorily explained.

These facts, particularly the repeated pattern of immediate cash deposits followed by corresponding loans, are directly supported by the ratio of the jurisdictional Gujarat High Court in Blessing Construction. Therefore, the

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO Revenue's primary contention remains that the entire addition of Rs.40,00,000/- should be sustained. However, without prejudice to the above, if the Tribunal is inclined to grant any relief, the Revenue respectfully submits that at least 50% of the disputed loan amount, i.e. Rs.20,00,000/-, may be sustained, following the approach adopted by the ITAT, Indore Bench in Shri Om Prakash Patidar (HUF). The Revenue respectfully submits that the plea for sustaining 50% is only an alternative plea and does not dilute the Revenue's primary claim for sustaining the entire addition. The Revenue does not contend that 50% is a fixed or mandatory rate. If the Tribunal considers that some estimation is warranted, the appropriate percentage may be determined by the Tribunal on the basis of the facts, surrounding circumstances and evidence in the present case, keeping in view the various decisions of different Benches, including the Surat Bench.

9.

The Ld. DR further submitted that as regards Ground No.2 relating to addition of Rs.14,04,322/- on account of cash deposited by the assessee in his own current account and subsequently utilised towards the purchase of plant and machinery. The assessee was therefore required to satisfactorily explain the nature and source of such cash and establish that the cash was actually available with him. The assessee failed to establish the availability of the said cash. The cash book furnished by the assessee commenced only from 01.06.2015, instead of 01.04.2015. Further, the cash book did not contain a proper day-to-day running balance. Consequently, the availability of opening cash balance as on 01.04.2015 and the availability of sufficient cash on the dates of the deposits could not be properly verified. The Assessing Officer specifically required the assessee to furnish the financial statements Tor A.Y. 2015-16 so as to verify the opening cash balance. However, the assessee failed to furnish the same. Even during the appellate proceedings, despite opportunities, the assessee could not satisfactorily establish the availability of cash of Rs. 14,04,322/-. It is further relevant that the explanation of the assessee regarding the source of the cash was

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO not consistent. Before the Assessing Officer and in the Statement of Facts, the assessee stated that the investment was made out of his own funds. Subsequently, before the CIT(A), the assessee explained the source as cash withdrawals from bank and embroidery job-work income. However, no satisfactory cash-flow statement, withdrawal-to-deposit nexus or peak cash balance was furnished to establish the availability of the disputed cash. The assessee had declared total income of only Rs.3,77,380/-, whereas cash of Rs. 14,04,322/- was deposited and utilised towards acquisition of plant and machinery. The mere fact that the amount was deposited in the assessee's own bank account does not establish the source of the cash. The assessee was required to establish the actual availability of the cash with supporting contemporaneous evidence, which he failed to do. The decisions relied upon by the assessee in support of the availability of cash are distinguishable on facts, in those cases, the availability of cash was supported by properly maintained cash books, cash flow statements and other corroborative evidence. In the present case, such evidence is absent and the assessee has failed to establish the source and availability of the cash. In view of the above facts, the Ld. DR submits that the assessee has failed to satisfactorily explain the source of the cash deposit of Rs 14,04,322/ The addition made by the Assessing Officer and confirmed by the CIT(A) is therefore justified and deserves to be sustained in full. The Ld. DR relied upon the decision of Hon'ble Apex court in case of PCIT vs. M/s. NRA Iron Steel Pvt. Ltd. (2019) 412 ITR 161 (SC).

10.

We have heard both the parties and perused all the relevant materials available on record. The contention of the Ld. DR that the assessee has taken a loan and some of the lenders are closely related to the assessee, more particularly, two lenders. They accounted for Rs. 21 Lakhs out of the total loan of Rs.40 Lakhs, and thus, the assessee has satisfactorily explained the creditworthiness as explained by the assessee. But from the perusal of record, it can be seen that the assessee could not establish the creditworthiness of the said parties and has also not given the details of re-payment. Thus, the alternate contention of Ld. DR that a 10

ITA No.347/SRT/2025 (A.Y. 2016-17) HASMUKHBHAI DEVRAJBHAI GABANI vs. ITO reasonable portion of the addition may be sustained is taken into consideration and taking into account that the creditors had deposited cash in their bank accounts before advancing the loans to the assessee. The balance was available with the creditors and, hence, 50% of the addition is sustained. Thus, Ground No.1 is partly allowed.

11.

As regards Ground No.2 on account of cash deposited by the assessee, the assessee’s case did not contain a proper day-to-day running balance and from the perusal of the cash book, it appears that the assessee explained the source of this cash generated and established nexus between withdrawal and deposits and, hence, the addition does not sustain. The decision of Hon’ble Gujarat High Court in the case of Blessing Construction vs. ITO, [2013] 32 taxmann.com 366 (Gujarat) will be applicable in present case. Ground No.2 is allowed.

12.

In result, appeal of the assessee is partly allowed.

Order pronounced in the open court on 30.10.2026 Sd/- Sd/- (B.M. BIYANI) (SUCHITRA KAMBLE) ACCOUNTANT MEMBER JUDICIAL MEMBER Surat; Dated: 30.10.2026 * SKS, Sr. P.S. Copy of the Order forwarded to: 1. The Appellant 2. The Respondent 3. CIT- concerned 4. DR, ITAT, Surat 5. Guard File By order, HEMA KISHORE JAKKA Digitally signed by HEMA KISHORE JAKKA Date: 2026.11.02 15:33:20 +05'30' Assistant Registrar/Sr.PS/PS ITAT, Surat Bench

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