DUSHYANTSINH YADVENDRASINH CHUDASAMA,VADODARA vs. INCOME TAX OFFICER, WARD-1(2)(4), VADODARA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

234/- was made under Section 40(a)(ia) for non-deduction of TDS on interest expenses related to fleet card charges and late payment. The AO also made a substantial addition of Rs. 22,19,000/- under Section 69, treating the opening balance as unexplained investment due to a lack of documentary evidence. The CIT(A) upheld

DUSHYANTSINH YADVENDRASINH CHUDASAMA,VADODARA vs. DY.COMM. OF INCOME TAX, CIRCLE-1(2), VADODARA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

234/- was made under Section 40(a)(ia) for non-deduction of TDS on interest expenses related to fleet card charges and late payment. The AO also made a substantial addition of Rs. 22,19,000/- under Section 69, treating the opening balance as unexplained investment due to a lack of documentary evidence. The CIT(A) upheld

HARSHA RAJESH JHAVERI,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

In the result, the appeal filed by the assesee is hereby allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Roy

Section 68 of the Act is justified and hence confirmed. Thus, the ground of appeal no. 1 is dismissed. 5. Being aggrieved by the order of the learned CIT(A), the assessee is in appeal before us. 6. The learned AR before us filed a paper book running from pages 1 to 234

INCOME TAX OFFICER WARD-1 HIMATNAGAR, HIMATNAGAR vs. NEW SURROAD GINNING AND PRESSING FACTORY, IDAR

In the result, the appeal of the assessee stands allowed, whereas, the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Annapurna Gupta1.आयकर अपील सं /Ita No.930/Ahd/2024 2.आयकर अपील सं /Ita No.924/Ahd/2024 (िनधा"रण वष" /Assessment Year : 2017-18) 1. New Surroad Ginning & 1. The Ito बनाम/ Pressing Factory Ward-2, V/S. At Post Surroad Himatnagar 383 001 Tal: Idar Himatnagar – 383 430 Dist. Sabarkantha 2. The Ito 2. New Surroad Ginning & Ward-1, Himatnagar Pressing Factory Himatnagar – 383 430 "थायी लेखा सं./Pan: Aakfn 5184 C (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Tej Shah, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 30/01/2026

68 of 1. T. act as a unexplained cash credit for cash deposited in a bank during the demonetization period for the Α.Υ.2017-18. 2. The Learned AO erroneously made addition and invoked section 115 BBE of I. T. Act. 3. Direction to charge interest u/s. 234

NEW SURROAD GINNING AND PRESSING FACTORY,SABARKANTHA vs. THE ITO, WARD-2, HIMATNAGAR

In the result, the appeal of the assessee stands allowed, whereas, the appeal of the Revenue is dismissed

Bench: Shri Sanjay Garg & Annapurna Gupta1.आयकर अपील सं /Ita No.930/Ahd/2024 2.आयकर अपील सं /Ita No.924/Ahd/2024 (िनधा"रण वष" /Assessment Year : 2017-18) 1. New Surroad Ginning & 1. The Ito बनाम/ Pressing Factory Ward-2, V/S. At Post Surroad Himatnagar 383 001 Tal: Idar Himatnagar – 383 430 Dist. Sabarkantha 2. The Ito 2. New Surroad Ginning & Ward-1, Himatnagar Pressing Factory Himatnagar – 383 430 "थायी लेखा सं./Pan: Aakfn 5184 C (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Tej Shah, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 30/01/2026

68 of 1. T. act as a unexplained cash credit for cash deposited in a bank during the demonetization period for the Α.Υ.2017-18. 2. The Learned AO erroneously made addition and invoked section 115 BBE of I. T. Act. 3. Direction to charge interest u/s. 234

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 68 by the Finance Act, 2022 with effect from 01-04-2023 and applicable for the Asst. years 2023-24 onwards only, and not applicable to the present asst. year 2013-14. Hence the entire addition on this count is liable to be deleted and Ground Nos.2 to 7 filed by the assessee are hereby allowed. 14. Ground

YOGESHKUMAR GAJRAJSINGH YADAV,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-3(1)(1), AHMEDABAD

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

Bench: Smt.Annapurna Guptaasstt.Year :2012-13 Yogeshkumar Gajrajsingh Yadav The Ito-Ward-3(1)(1) 26, Nandanbaug Vs Ahmedabad. Club-07 Road, Nr.Apple Wood Village Shela, Sanand Ahmedabad 380 058. Pan : Aaepy 8589 Q (Applicant) (Responent) : Written Submission Assessee By : Shri C. Dharani Nath, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/06/2024 घोषणा क" तारीख /Date Of Pronouncement: 25/06/2024 आदेश आदेश/O R D E R आदेश आदेश

234 B and 234C of the Act.” 2 3. Grievance of the assessee revolves around a single issue i.e. about the addition of Rs.10,21,780/- under section 68

SHREE VEER BUILDBEST PRIVATE LIMITED,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-8(3) NOW WARD-4(1)(1), AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.892/Ahd/2023 "नधा"रण वष" /Assessment Year : 2011-12 Shree Veer Buildbest Pvt.Ltd. The Ito बनाम/ 302, Swapneel – 5 Ward-4(1)(1) Commerce Six Road Ahmedabad- 380 015 V/S. Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aakcs 8358 Q अपीलाथ"/ (Appellant) ….. "" यथ"/ (Respondent) Assessee By : Shri Aseem L. Thakkar, Ar Revenue By : Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 15/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 23/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 21/09/2023 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “ The Ld.Cit(A)” In Short], Arising Out Of The Assessment Order Dated 28/03/2014 Passed By The Assessing Officer (Ao) Under Section 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Relevant To The Assessment Year (Ay) 2011-12. Shree Veer Buildbest Pvt.Ltd. Vs. Ito Asst. Year : 2011-12

68 of the Act. 3. Aggrieved by the order of the AO, the assessee filed an appeal before ld.CIT(A), who dismissed the appeal confirming the additions made by the AO. Therefore, the assessee in appeal before us with the following grounds of appeal: 1. “The learned Commissioner of Income Tax (Appeals), NAC, Delhi has erred in confirming action

LATE SMT. RAMILABEN HARSHADRAI PATEL(THROUGH L/H DEVRAJ H.PATEL),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(2), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 and holding that assessee failed to discharge onus to prove cash credit in as much as that the full details explaining cash credit have been furnished but not considered and the assessee has discharged the onus cast on her. 3. The learned CIT(A) has grievously erred in law and on facts in not considering the detailed submission furnished

ASSISTANT COMMISSIONER OF INCOME-TAX, AHMEDABAD vs. DEVRAJ HARSHADRAY PATEL, AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 and holding that assessee failed to discharge onus to prove cash credit in as much as that the full details explaining cash credit have been furnished but not considered and the assessee has discharged the onus cast on her. 3. The learned CIT(A) has grievously erred in law and on facts in not considering the detailed submission furnished

DEVRAJ HARSHADRAI PATEL,AHMEDABAD vs. THE DY.CIT., CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 and holding that assessee failed to discharge onus to prove cash credit in as much as that the full details explaining cash credit have been furnished but not considered and the assessee has discharged the onus cast on her. 3. The learned CIT(A) has grievously erred in law and on facts in not considering the detailed submission furnished

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

234 wherein in the context of section 2(15) of the Act, education has been explained as a process of training and developing the knowledge, skill, mind and character of students by schooling by way of systematic instruction, schooling or training. Therefore, any form of education activity involving imparting of systematic training in order to develop the knowledge, skill

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

234 wherein in the context of section 2(15) of the Act, education has been explained as a process of training and developing the knowledge, skill, mind and character of students by schooling by way of systematic instruction, schooling or training. Therefore, any form of education activity involving imparting of systematic training in order to develop the knowledge, skill

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

234 wherein in the context of section 2(15) of the Act, education has been explained as a process of training and developing the knowledge, skill, mind and character of students by schooling by way of systematic instruction, schooling or training. Therefore, any form of education activity involving imparting of systematic training in order to develop the knowledge, skill