CIT v. Kabul Chawla

380 ITR 573High Court2016#3 most cited

What is CIT v. Kabul Chawla authority for?

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

3,235

judgments rely on this decision, according to BharatTax’s citation analysis of 367,842 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Kabul Chawla · Kabul Chawla · section 153A · section 132 · incriminating material · search assessment · non-abated years · scope of assessment · additions · undisclosed income

Also reported as

61 Taxmann.com 412234 Taxmann 300281 CTR 45

Sections most often in play

Section 153ASection 132Section 143(3)Section 147Section 148Section 153CSection 132ASection 143(2)
Read the full judgment

Issues it is cited on

section 158bcstatement under section 132(4)section 132asection 158bblock periodsection 132(1)section 153a(1)section 158section 153bsearch assessmentpanchnamaincriminating material

Judgments citing CIT v. Kabul Chawla

Kartikay Nayyar, New Delhi vs. ACIT Central Circle - 20, New Delhi

ITA 22/DEL/2020[2013-14]Status: DisposedITAT Delhi21 Jun 2022AY 2013-14

Bench: Sh. N. K. Billaiya & Sh.Yogesh Kumar Us

Section 132Section 153Section 153ASection 69

…nsideration are completed assessment years and, therefore, any addition to be made u/s.153A of the Act has to be made on the basis of any incriminating material found at the time of search as held by the Hon’ble High Court of Delhi in the case of Kabul Chawla 380 ITR 573 and Meeta Gugutia in ITA No.306 of 2017. 8. Per contra though the DR strongly supported the findings of the AO but could not controvert the fact that the impugned additions are de-hors incriminating material. 9. We have carefully considered the orders of the authorities below. The undisputed fact is that all the captioned assessment years are com…

Kartikay Nayyar, New Delhi vs. ACIT Central Circle - 20, New Delhi

ITA 21/DEL/2020[2012-13]Status: DisposedITAT Delhi21 Jun 2022AY 2012-13

Bench: Sh. N. K. Billaiya & Sh.Yogesh Kumar Us

Section 132Section 153Section 153ASection 69

…nsideration are completed assessment years and, therefore, any addition to be made u/s.153A of the Act has to be made on the basis of any incriminating material found at the time of search as held by the Hon’ble High Court of Delhi in the case of Kabul Chawla 380 ITR 573 and Meeta Gugutia in ITA No.306 of 2017. 8. Per contra though the DR strongly supported the findings of the AO but could not controvert the fact that the impugned additions are de-hors incriminating material. 9. We have carefully considered the orders of the authorities below. The undisputed fact is that all the captioned assessment years are com…

Kartikay Nayyar, New Delhi vs. ACIT Central Circle - 20, New Delhi

ITA 20/DEL/2020[2011-12]Status: DisposedITAT Delhi21 Jun 2022AY 2011-12

Bench: Sh. N. K. Billaiya & Sh.Yogesh Kumar Us

Section 132Section 153Section 153ASection 69

…nsideration are completed assessment years and, therefore, any addition to be made u/s.153A of the Act has to be made on the basis of any incriminating material found at the time of search as held by the Hon’ble High Court of Delhi in the case of Kabul Chawla 380 ITR 573 and Meeta Gugutia in ITA No.306 of 2017. 8. Per contra though the DR strongly supported the findings of the AO but could not controvert the fact that the impugned additions are de-hors incriminating material. 9. We have carefully considered the orders of the authorities below. The undisputed fact is that all the captioned assessment years are com…

ACIT, Central Circle- 26, New Delhi vs. G.D. Bakers Pvt. Ltd. (Formerly Known As Tops Exports (India) P.Ltd), New Delhi

In the result, all the three appeals of the Revenue in ITA Nos

ITA 1461/DEL/2018[2013-14]Status: DisposedITAT Delhi16 Jun 2022AY 2013-14

Bench: Shri N.K. Billaiya & Shri Yogesh Kumar U.S

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Surender Pal, CIT- DR
Section 132

…naccounted sale was Rs. 5,49,447/- in Assessment Year 2013-14, Rs. 1,92,307/- in Assessment Year 2014-15 and Rs. 9,24,189/- in Assessment Year 2015-16. 13. Drawing support from the decision of the Hon'ble Delhi High Court in the case of CIT Vs. Kabul Chawla 61 Taxmann.com 412, the ld. CIT(A) restricted the addition made by the Assessing Officer on account of g.p. on unaccounted sales found in the seized documents. Accordingly, addition was restricted to Rs. 4,44,640/- in Assessment Year 2013-14, Rs. 33,14,181/- in Assessment Year 2014-15 and Rs. 1,91,108/.- in Assessment Year 2015-16. 14. Coming to the addi…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 27/CHNY/2012[2007-2008]Status: DisposedITAT Chennai08 Jun 2022AY 2007-2008

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 26/CHNY/2012[2006-2007]Status: DisposedITAT Chennai08 Jun 2022AY 2006-2007

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 25/CHNY/2012[2005-2006]Status: DisposedITAT Chennai08 Jun 2022AY 2005-2006

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 24/CHNY/2012[2004-2005]Status: DisposedITAT Chennai08 Jun 2022AY 2004-2005

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 23/CHNY/2012[2003-2004]Status: DisposedITAT Chennai08 Jun 2022AY 2003-2004

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 22/CHNY/2012[2002-2003]Status: DisposedITAT Chennai08 Jun 2022AY 2002-2003

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Smt. V.Prremalatha, Chennai vs. ACIT, Chennai

The appeal stand partly allowed

ITA 21/CHNY/2012[2001-2002]Status: DisposedITAT Chennai08 Jun 2022AY 2001-2002

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate ) – Ld. ARFor Respondent: Shri Karthick Ranganathan
Section 132Section 132ASection 143(2)Section 143(3)Section 153ASection 234BSection 234C

…not produced in the course of original assessment but found in the course of search, and undisclosed income or undisclosed property discovered during search. 5. We find that similar view has been expressed by Hon’ble Delhi High Court in CIT Vs. Kabul Chawla (380 ITR 573) which has summarized the legal position as under: - 37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153A(1) will hav…

Shri Jivrajbhai H. Balar, Surat vs. The Income Tax Officer, Ward-8(2), Surat

In the result, appeals filed by the assessee for assessment years 2004-05 to 2007-08, ( IT(SS)A Nos

ITA 1245/AHD/2015[2010-11]Status: DisposedITAT Surat31 May 2022AY 2010-11

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./It(Ss)A No.150 To 154/Ahd/2015 ("नधा"रणवष" / Assessment Year: (2004-05 To 2008-09) (Physical Court Hearing) Jivrajbhai Harkhabhai Balar, The Dcit, Central Circle-1, Vs. 59, Kantareshwar Society, Surat. Katargam Road, Surat-395004. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abopb8649M (Appellant) (Respondent) आयकरअपीलसं./Ita No.1245/Ahd/2015 ("नधा"रणवष" / Assessment Year: (2010-11) Jivrajbhai Harkhabhai Balar, Vs. The Dcit, Central Circle-1, 59, Kantareshwar Society, Surat. Katargam Road, Surat-395004. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abopb8649M (Appellant) (Respondent)

For Appellant: Shri Rasesh Shah, CAFor Respondent: Shri H. P. Meena, CIT(DR) & Ms Anupama Singla, Sr. DR
Section 143(3)Section 153C

…11.2009. To support his arguments, Ld. Counsel relied on the following judgments:  PCIT vs Saumya Construction [81 taxmann.com 292] (Guj HC)  CIT vs Continental Warehousing Corporation (Nhava Sheva) Ltd [58 taxmann.com 78] (Bombay HC)  CIT vs Kabul Chawla [380 ITR 573] (Del HC)(SLP Dismissed in SC – 380 ITR (ST) 4)  CIT vs Veerprabhu Marketing Ltd.[ 388 ITR 574](Cal HC)  PCIT vs. Meeta Gutgutia [ 82 taxmann.com 287 ](Del. HC) 33. We note that following were the disputed expenditure: Opening balance 16,118 01.04.03 Premium payable 17,24,800 27.05.03 Premium paid 27,59,067 19.09.03 Revenue duty paid 1200 27.…

ACIT, Central Circle- 30, New Delhi vs. Sanjivani Industries Pvt. Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 4214/DEL/2018[2009-10]Status: DisposedITAT Delhi31 May 2022AY 2009-10

Bench: Sh. Anil Chaturvedi & Sh. Yogesh Kumar Usacit Vs. Sanjivani Industries Pvt. Central Circle -30 Ltd. New Delhi 1/8, West Patel Nagar, New Delhi – 110 008 Pan No. Aafcs 8669 H (Appellant) (Respondent)

Section 131Section 132Section 132(4)Section 143(1)Section 153A

…ome, which was found during search operation but also with regard to material that was available at time of original assessment. With respect to the reliance placed by CIT(A) on the decision of Hon’ble Delhi High Court in the case of Kabul Chawla reported in 380 ITR 573, he submitted that facts of the case are distinguishable as in that case no statement was recorded during search and no documentary evidence was found and the earlier assessment was completed twice. In the present case, he submitted that Mr. Mul Chand Malu who is the promoter and head of the group has admitted to undisclosed income and that Shri…

Deputy Commissioner of Income Tax, Central Circle- 1(3), Bangalore vs. Shri. T. Nadakrishna, Bangalore

In the result, assessee’s appeal in ITA No

ITA 575/BANG/2020[2007-08]Status: DisposedITAT Bangalore27 May 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

M/S. Spr Spirits Private Limited (Formerly Known As Spr Group Holdings Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Central Circle- 1(3), Bangalore

In the result, assessee’s appeal in ITA No

ITA 127/BANG/2020[2007-08]Status: DisposedITAT Bangalore27 May 2022AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1661/BANG/2018[2011-12]Status: DisposedITAT Bangalore27 May 2022AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1660/BANG/2018[2010-11]Status: DisposedITAT Bangalore27 May 2022AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

M/S Spr Spirits Pvt.Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle -1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1659/BANG/2018[2009-10]Status: DisposedITAT Bangalore27 May 2022AY 2009-10

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

M/S Spr Spirits Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income Tax Central Circle - 1 (3), Bengaluru

In the result, assessee’s appeal in ITA No

ITA 1658/BANG/2018[2008-09]Status: DisposedITAT Bangalore27 May 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Bharath L., A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 132Section 153ASection 37(1)Section 40A(3)

…d had not considered the matter on merits.” ITA Nos.1658 to 1661/Bang/2018, ITA No.127/Bang/2020 & ITA 575/Bang/2020 M/s. SPR Spirits Pvt. Ltd., Bangalore & T. Nadakrishna, Bangalore Page 34 of 55 18. In Commissioner of Income Tax V/s. Kabul Chawla [(2016) 380 ITR 573 (Delhi)], Hon’ble Delhi High Court considering the decision in CIT V/s. Anil Kumar Bhatia [(2013) 352 ITR 493 (Del)], has held thus: “21. Therefore it is clear that the decision in CIT V/s. Anil Kumar Bhatia (supra) does not deal with a situation where, as in the present case, no incriminating material was found during the search conducted under…

Dy. Commissioner of Income Tax, Central Cir.-3, Surat vs. Sh. Hareshbhai Mohanbhai Sakariya, Surat

In the result, Revenue’s appeal is dismissed

ITA 48/SRT/2021[2017-18]Status: DisposedITAT Surat25 May 2022AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

Section 132Section 132(1)Section 143(3)Section 14ASection 153ASection 153CSection 158BSection 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER IT(SS)A No.01/SRT/2021 (AY 2010-11) IT(SS)A No.09/SRT/2020 (AY 2014-15) (Hearing in Physical Court) Deputy Commissioner of Shri Dineshchandra D Income-tax, Central Circle- Koradia, 3Room No.507, 5th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/h.Navyug College, Gate, Surat-395001 Rander Road, Surat PAN No: ACUPK 3696 A Assistant Commissioner of Vs Income-tax, Central Circle-3, Room No.507, 5th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue…