CIT v. Jasjit Singh

155 Taxmann.com 155Supreme Court of India2023#377 most cited

What is CIT v. Jasjit Singh authority for?

For assessments under Section 153C concerning a non-searched person, the relevant date for calculating the block of assessment years is the date on which the jurisdictional Assessing Officer of that person assumes possession of the seized material, not the date of the original search. This date determines the look-back period for reopening assessments under Section 153A read with 153C.

235

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2023 to 2026.

Also referred to as

CIT v. Jasjit Singh · Section 153C · Section 153A · search assessment · non-searched person · third party assessment · date of reckoning · relevant date · seized material possession · block assessment years · assessment under 153C · jurisdictional AO

Also reported as

458 ITR 437295 Taxmann 612

Sections most often in play

Section 153CSection 143(3)Section 153ASection 132Section 1961Section 153DSection 148Section 143(2)
Read the full judgment

Issues it is cited on

section 153(c)(1)section 153(c)section 153c(1)abatement of assessmentblock periodsatisfaction noteretraction of statementsection 153a(1)section 131(1)statement under section 132(4)section 153a(1)(b)search assessment

Judgments citing CIT v. Jasjit Singh

Kasiredday Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 887/BANG/2025[2017-18]Status: DisposedITAT Bangalore02 Feb 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…ance of notice under section 153C of the Act as the case may be. 23.1 The learned AR relying on the judgment of Hon’ble SC in the case of Commissioner of Income-tax vs. Jasjit Singh [2023] reported in 155 taxmann.com 155 (SC)/[2023] 295 Taxman 612 (SC)/[2023] 458 ITR 437 (SC)[26-09-2023] submitted that the amendment in section 153C(1) introduced by the FA, 2008 is not relevant for the purpose of reckoning six AY u/s 153C. 24. On the other hand, the learned DR before us vehemently supported the orders passed by the authorities below. He submitted that the Assessing Officer had rightly made the additions after due…

Kasiredday Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 886/BANG/2025[2016-17]Status: DisposedITAT Bangalore02 Feb 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…ance of notice under section 153C of the Act as the case may be. 23.1 The learned AR relying on the judgment of Hon’ble SC in the case of Commissioner of Income-tax vs. Jasjit Singh [2023] reported in 155 taxmann.com 155 (SC)/[2023] 295 Taxman 612 (SC)/[2023] 458 ITR 437 (SC)[26-09-2023] submitted that the amendment in section 153C(1) introduced by the FA, 2008 is not relevant for the purpose of reckoning six AY u/s 153C. 24. On the other hand, the learned DR before us vehemently supported the orders passed by the authorities below. He submitted that the Assessing Officer had rightly made the additions after due…

Kasireddy Ranadheer Reddy, Bangalore vs. ACIT, Central Circle-2(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 885/BANG/2025[2013-14]Status: DisposedITAT Bangalore02 Feb 2026AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No. 882 to 887/Bang/2025 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Kasireddy Ranadheer Reddy, Vs. The Asst. Commissioner of #6, 1st Floor, Ratan Apartments, Income Tax, Taralabalu Road, MLA Layout, Circle – 2(1), Ganganagar, Bangalore. Bangalore – 560 032. PAN – AMCPR 4790 E APPELLANT RESPONDENT Assessee by : Shri Shivprasad Reddy, AR & Shri B.S Balachandran, Advocate Revenue by : Shri N Balusamy, JCIT (DR) Date of hearing : 17.12.2025 Date of Prono…

Kasireddy Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 884/BANG/2025[2012-13]Status: DisposedITAT Bangalore02 Feb 2026AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…ance of notice under section 153C of the Act as the case may be. 23.1 The learned AR relying on the judgment of Hon’ble SC in the case of Commissioner of Income-tax vs. Jasjit Singh [2023] reported in 155 taxmann.com 155 (SC)/[2023] 295 Taxman 612 (SC)/[2023] 458 ITR 437 (SC)[26-09-2023] submitted that the amendment in section 153C(1) introduced by the FA, 2008 is not relevant for the purpose of reckoning six AY u/s 153C. 24. On the other hand, the learned DR before us vehemently supported the orders passed by the authorities below. He submitted that the Assessing Officer had rightly made the additions after due…

Kasireddy Ranadheer Reddy, Bangalore vs. ACIT, Central Circle-2(1), Bengaluru

In the result, the appeal filed by the assessee is partly allowed

ITA 883/BANG/2025[2011-12]Status: DisposedITAT Bangalore02 Feb 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…ance of notice under section 153C of the Act as the case may be. 23.1 The learned AR relying on the judgment of Hon’ble SC in the case of Commissioner of Income-tax vs. Jasjit Singh [2023] reported in 155 taxmann.com 155 (SC)/[2023] 295 Taxman 612 (SC)/[2023] 458 ITR 437 (SC)[26-09-2023] submitted that the amendment in section 153C(1) introduced by the FA, 2008 is not relevant for the purpose of reckoning six AY u/s 153C. 24. On the other hand, the learned DR before us vehemently supported the orders passed by the authorities below. He submitted that the Assessing Officer had rightly made the additions after due…

Kasireddy Ranadheer Reddy, Bengaluru vs. ACIT, Central Circle-2(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 882/BANG/2025[2010-11]Status: DisposedITAT Bangalore02 Feb 2026AY 2010-11

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Shivprasad Reddy, AR &For Respondent: Shri N Balusamy, JCIT (DR)
Section 132Section 259Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No. 882 to 887/Bang/2025 Assessment Year: 2010-11 to 2013-14 & 2016-17 to 2017-18 Kasireddy Ranadheer Reddy, Vs. The Asst. Commissioner of #6, 1st Floor, Ratan Apartments, Income Tax, Taralabalu Road, MLA Layout, Circle – 2(1), Ganganagar, Bangalore. Bangalore – 560 032. PAN – AMCPR 4790 E APPELLANT RESPONDENT Assessee by : Shri Shivprasad Reddy, AR & Shri B.S Balachandran, Advocate Revenue by : Shri N Balusamy, JCIT (DR) Date of hearing : 17.12.2025 Date of Prono…

M/S Model Tanners (India) Pvt. Ltd., Kanpur vs. Astt. Commissioner of Income Tax, Kanpur

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

ITA 375/LKW/2017[2009-10]Status: DisposedITAT Lucknow30 Jan 2026AY 2009-10
For Appellant: Sh. Ashish Jaiswal, AdvFor Respondent: Sh. Puneet Kumar, CIT DR
Section 153ASection 153CSection 153DSection 801BSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘B’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER ITA Nos.374 & 375/LKW/2017 A.Ys. 2005-06 & 2009-10 M/s MODEL TANNERS (INDIA) PVT. vs. ACIT, LTD., C/o Sultan Tanners, Jajmau, Central Circle-II, Kanpur Kanpur-208010 PAN: AAACM9319D (Appellant) (Respondent) Assessee by: Sh. Ashish Jaiswal, Adv Revenue by: Sh. Puneet Kumar, CIT DR Date of hearing: 04.11.2025 Date of pronouncement: 30.01.2026 O R D E R PER NIKHIL CHOUDHARY, A.M. These two appeals have been filed by the assessee against the orders of the l…

M/S Model Tanners (India) Pvt. Ltd., Kanpur vs. Astt. Commissioner of Income Tax, Kanpur

In the result, ITA No. 374/LKW/2017 is partly allowed while ITA No

ITA 374/LKW/2017[2005-06]Status: DisposedITAT Lucknow30 Jan 2026AY 2005-06
For Appellant: Sh. Ashish Jaiswal, AdvFor Respondent: Sh. Puneet Kumar, CIT DR
Section 153ASection 153CSection 153DSection 801BSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW ‘B’ BENCH, LUCKNOW BEFORE SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY, ACCOUNTANT MEMBER ITA Nos.374 & 375/LKW/2017 A.Ys. 2005-06 & 2009-10 M/s MODEL TANNERS (INDIA) PVT. vs. ACIT, LTD., C/o Sultan Tanners, Jajmau, Central Circle-II, Kanpur Kanpur-208010 PAN: AAACM9319D (Appellant) (Respondent) Assessee by: Sh. Ashish Jaiswal, Adv Revenue by: Sh. Puneet Kumar, CIT DR Date of hearing: 04.11.2025 Date of pronouncement: 30.01.2026 O R D E R PER NIKHIL CHOUDHARY, A.M. These two appeals have been filed by the assessee against the orders of the l…

Rajesh Gandhi, New Delhi vs. Sanghpriya Singh, DCIT, Central Circle-28, New Delhi

The appeals are dismissed

ITA 664/DEL/2025[2021-22]Status: DisposedITAT Delhi29 Jan 2026AY 2021-22

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

…of the non-searched person qua the searched person, becomes date of search in the case of other person [the assessee in the present case]. 12. The above proposition of law has been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437. Relevant findings read as under: “9. It is evident on a plain interpretation of Section 153C( I) that the Parliamentary intent to enact the provision was to cater not merely to the question of abatement but also with regard to the date from which the six year period was to be reckoned, in respect of which the returns were to be filed by the thir…

Rajesh Gandhi, New Delhi vs. Sanghpriya Singh, DCIT, Central Circle-28, New Delhi

The appeals are dismissed

ITA 663/DEL/2025[2020-21]Status: DisposedITAT Delhi29 Jan 2026AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, C: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.- 662/Del/2025 [Assessment Year: 2019-20] Rajesh Gandhi, Sanghpriya Singh, 67-68, Sector-25, Pocket-2, DCIT, Rohini, Vs Central Circle-28, New Delhi-110085. New Delhi-110055. PAN- AZFPG7938P Assessee Revenue ITA No.- 663/Del/2025 [Assessment Year: 2020-21] Rajesh Gandhi, Sanghpriya Singh, 67-68, Sector-25, Pocket-2, DCIT, Rohini, Vs Central Circle-28, New Delhi-110085. New Delhi-110055. PAN- AZFPG7938P Assessee Revenue ITA No.- 664/Del/2025 [A…

Rajesh Gandhi, New Delhi vs. Sanghpriya Singh, DCIT, Central Circle-28, New Delhi

The appeals are dismissed

ITA 662/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Jan 2026AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

…of the non-searched person qua the searched person, becomes date of search in the case of other person [the assessee in the present case]. 12. The above proposition of law has been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437. Relevant findings read as under: 9. It is evident on a plain interpretation of Section 153C( I) that the Parliamentary intent to enact the provision was to cater not merely to the question of abatement but also with regard to the date from which the six year period was to be reckoned, in respect of which the returns were to be filed by the third…

Rajesh Gandhi, New Delhi vs. Sanghpriya Singh, DCIT Central Circle-28, New Delhi

The appeals are dismissed

ITA 661/DEL/2025[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

…of the non-searched person qua the searched person, becomes date of search in the case of other person [the assessee in the present case]. 12. The above proposition of law has been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437. Relevant findings read as under: “9. It is evident on a plain interpretation of Section 153C( I) that the Parliamentary intent to enact the provision was to cater not merely to the question of abatement but also with regard to the date from which the six year period was to be reckoned, in respect of which the returns were to be filed by the thir…

Ramesh Gandhi, New Delhi vs. Sanghpriya Singh, DCIT, Central Circle-28, New Delhi

The appeals are dismissed

ITA 657/DEL/2025[2012-13]Status: DisposedITAT Delhi29 Jan 2026AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 139(1)Section 153Section 153CSection 68

…of the non-searched person qua the searched person, becomes date of search in the case of other person [the assessee in the present case]. 12. The above proposition of law has been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437. Relevant findings read as under: “9. It is evident on a plain interpretation of Section 153C( I) that the Parliamentary intent to enact the provision was to cater not merely to the question of abatement but also with regard to the date from which the six year period was to be reckoned, in respect of which the returns were to be filed by the thir…

Sri Sat Sahib Housing and Infrastructure Development Company, Gurgaon vs. DCIT/ACIT CC-31, New Delhi, Delhi

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3115/DEL/2025[2010-11]Status: DisposedITAT Delhi28 Jan 2026AY 2010-11

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, H: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.- 3113/Del/2025 [Assessment Year: 2008-09] Sri Sat Sahib Housing and DCIT/ACIT, Infrastructure Development CC-31, Jhandewalan Extension, company, Vs New Delhi-110055. KFF 101, Palam Triangle Market, Palam Vihar, Gurugram, Haryana- 122017. PAN- ABIFS1543 Assessee Revenue ITA No.- 3114/Del/2025 [Assessment Year: 2009-10] Sri Sat Sahib Housing and DCIT/ACIT, Infrastructure Development CC-31, Jhandewalan Extension, company, Vs New Delhi-110055. KFF…

Sri Sat Sahib Housing and Infrastructure Development Company, Gurgaon vs. DCIT/ACIT CC-31, New Delhi, Delhi

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3114/DEL/2025[2009-10]Status: DisposedITAT Delhi28 Jan 2026AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, H: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA No.- 3113/Del/2025 [Assessment Year: 2008-09] Sri Sat Sahib Housing and DCIT/ACIT, Infrastructure Development CC-31, Jhandewalan Extension, company, Vs New Delhi-110055. KFF 101, Palam Triangle Market, Palam Vihar, Gurugram, Haryana- 122017. PAN- ABIFS1543 Assessee Revenue ITA No.- 3114/Del/2025 [Assessment Year: 2009-10] Sri Sat Sahib Housing and DCIT/ACIT, Infrastructure Development CC-31, Jhandewalan Extension, company, Vs New Delhi-110055. KFF…

Sri Sat Sahib Housing and Infrastructure Development Company, Gurgaon vs. DCIT/ ACIT CC-31 New Delhi, New Delhi

In the result, both the captioned appeals of the Revenue in ITA Nos

ITA 3113/DEL/2025[2008-09]Status: DisposedITAT Delhi28 Jan 2026AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh

Section 132Section 153C

…of the non-searched person qua the searched person, becomes date of search in the case of other person [the assessee in the present case]. 12. The above proposition of law has been well settled by the Hon'ble Supreme Court in the case of CIT Vs. Jasjit Singh 458 ITR 437. Relevant findings read as under: “9. It is evident on a plain interpretation of Section 153C( I) that the Parliamentary intent to enact the provision was to cater not merely to the question of abatement but also with regard to the date from which the six year period was to be reckoned, in respect of which the returns were to be filed by the thir…

Deputy Commissioner of Income Tax, Central Circle 25, New Delhi, Delhi vs. Shri Balaji Metal Tech Pvt Ltd, Haryana

In the result, the appeal of the revenue is allowed for statistical purpose

ITA 2167/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Jan 2026AY 2013-14

Bench: Shri C.N. Prasad & Shri Brajesh Kumar Singhassessment Year 2013-14 Commissioner Of Income Vs. Shri Balaji Metal Tech Pvt. Ltd. Tax,Centralcircle-25, New Haryana 20/21B, 2Nd Floor, Fruit Garden Delhi Nit Faridabad, Haryana Faridabad Pan No. Aaqcs0136E Appellant Respondent Appellant Sh. Mahesh Kumar, Cit Dr Respondent Sh. Madhur Aggarwal, Advocate

Section 153C

…sment year under consideration i.e. 2013-14 is beyond the block period as per the decision of the Hon’ble Delhi High Court in the case of PCIT Vs. Ojjus Medicare (P) Ltd. (465 ITR 101) and the decision of the Hon’ble Supreme court in the case of Jasjit Singh (458 ITR 437). 5. Heard rival submissions, perused the orders of the authorities below. The following application under Rule 27 of I.T. A. T. Rules 1963 was filed by the Assessee. “APPLICATION UNDER RULE 27 OF THE INCOME TAX APPELLATE TRIBUNAL RULES, 1963 Hon'ble Sir(s). 1. The captioned appeal filed by the revenue was heard by the Hon'ble Bench on 21.07.202…

ACIT Cir-19(1), New Delhi vs. Shipra Bansal, New Delhi

In the result, appeal of the revenue is dismissed

ITA 4474/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Jan 2026AY 2012-13

Bench: SHRI ANUBHAV SHARMA, JUDICAL MEMBER, SHRI MANISH AGARWAL (Accountant Member)

Section 132Section 142(1)Section 143(2)Section 153Section 153ASection 153C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ACIT, Circle 19(1), Shipra Bansal, Room No.221, 2nd Floor, CR Vs. W-82, Ground Floor, Building, New Delhi-110002 Greater Kailash-I, New-Delhi-110048 PAN:AAAPS4862N (Appellant) (Respondent) Department by Ms. Pooja Swaroop, CIT DR Assessee by Dr. Rakesh Gupta & Shri Somil Aggarwal, Advs. Date of hearing 21.01.2026 Date of pronouncement 27.01.2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the revenue against the order of the Ld. Commissioner of In…

Popatbhai Talashibhai Savani, Surat vs. DCIT, Central Circle 2, Surat

In the result, both the appeals of the assessee are allowed

ITA 810/SRT/2025[2014-15]Status: HeardITAT Surat22 Jan 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 132Section 143(3)Section 153ASection 153CSection 263

…IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 809 & 810/SRT/2025 (Assessment Year: 2013-14 & 2014-15) Popatbhai Talashibhai Savani, Principal Commissioner of Vs. 35/36, Narayanmuni Society, Income-tax, Gurukal Road, Ved Road, Central, Surat Katargam S.O., Dabholi BO, Surat-395004 [PAN : ABLPP 4585 H] (Appellant) .. (Respondent) Appellant represented by : Shri Rasesh Shah, CA Respondent represented by: Shri Mukesh Jain, CIT (DR) Date of Hearing 20.01.2026 Date of Pronouncement 22.01.2026 O R D E R PER DR. B.R.R. KUM…

Popatbhai Talashibhai Savani, Surat vs. PCIT, Central, Surat

In the result, both the appeals of the assessee are allowed

ITA 809/SRT/2025[2013-14]Status: HeardITAT Surat22 Jan 2026AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 132Section 143(3)Section 153ASection 153CSection 263

…IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 809 & 810/SRT/2025 (Assessment Year: 2013-14 & 2014-15) Popatbhai Talashibhai Savani, Principal Commissioner of Vs. 35/36, Narayanmuni Society, Income-tax, Gurukal Road, Ved Road, Central, Surat Katargam S.O., Dabholi BO, Surat-395004 [PAN : ABLPP 4585 H] (Appellant) .. (Respondent) Appellant represented by : Shri Rasesh Shah, CA Respondent represented by: Shri Mukesh Jain, CIT (DR) Date of Hearing 20.01.2026 Date of Pronouncement 22.01.2026 O R D E R PER DR. B.R.R. KUM…