SHRI AMITKUMAR MATHURDAS KANERIA,,SURAT vs. THE INCOME TAX OFFICER, WARD -1(3),, SURAT

In the result, appeal of the assessee for A

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.2031 & 2663/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Amitkumar Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7315 J) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No’S.1545 & 2029/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Smt.Jayaben Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7316 M) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2030/Ahd/2015/Srt िनधा"रण वष"/Assessment Year : 2010-11 Smt.Jullie Amit Kaneria, Vs. The Income Tax Officer, 64, Himgiri Bunglows, Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Aizpk 3199 B) अपीलाथ" Appellant ""यथ"/Respondent

cash deposits in the bank accounts. It is further seen that declaration of gift has been not made on the stamp paper, therefore, the CIT(A) has rightly placed reliance in the case of Sumati Dayal vs. CIT 214 ITR 801 (SC) which refers the human probability and behavior. According to which as per Indian / Gujarati Customs and Culture where

SMT. JULLIE AMIT KANERIA,,SURAT vs. THE INCOME TAX OFFICER, WARD -3(3),, SURAT

In the result, appeal of the assessee for A

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.2031 & 2663/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Amitkumar Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7315 J) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No’S.1545 & 2029/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Smt.Jayaben Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7316 M) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2030/Ahd/2015/Srt िनधा"रण वष"/Assessment Year : 2010-11 Smt.Jullie Amit Kaneria, Vs. The Income Tax Officer, 64, Himgiri Bunglows, Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Aizpk 3199 B) अपीलाथ" Appellant ""यथ"/Respondent

cash deposits in the bank accounts. It is further seen that declaration of gift has been not made on the stamp paper, therefore, the CIT(A) has rightly placed reliance in the case of Sumati Dayal vs. CIT 214 ITR 801 (SC) which refers the human probability and behavior. According to which as per Indian / Gujarati Customs and Culture where

SMT. JAYABEN MATHURDAS KANERIA,,SURAT vs. THE THE INCOME TAX OFFICER, WARD -1(3),, SURAT

In the result, appeal of the assessee for A

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.2031 & 2663/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Amitkumar Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7315 J) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No’S.1545 & 2029/Ahd/2015/Srt िनधा"रण वष"/Assessment Years : 2010-11 & 2011-12 Smt.Jayaben Mathurdas Kaneria, Vs The Income Tax Officer, 64, Himgiri Bunglows, . Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Adppk 7316 M) अपीलाथ" Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2030/Ahd/2015/Srt िनधा"रण वष"/Assessment Year : 2010-11 Smt.Jullie Amit Kaneria, Vs. The Income Tax Officer, 64, Himgiri Bunglows, Ward-3(3), Surat. Near: Rajhans Cinema, Piplod, Dumas Road, Surat – 395 007. [Pan: Aizpk 3199 B) अपीलाथ" Appellant ""यथ"/Respondent

cash deposits in the bank accounts. It is further seen that declaration of gift has been not made on the stamp paper, therefore, the CIT(A) has rightly placed reliance in the case of Sumati Dayal vs. CIT 214 ITR 801 (SC) which refers the human probability and behavior. According to which as per Indian / Gujarati Customs and Culture where

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, SURAT vs. M/S. KEJRIWAL INDUSTRIES LTD.,, SURAT

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri O.P.Meena

cash deposits. Moreover, it has also been found that the company has been merely used as conduit and the funds has been routed through the net work of the same person / concerns. 45 Sandip 1,68,809 Un-signed confirmations. Bank account Kejriwal Statements and other document could not establish the creditworthiness and genuineness of transaction. 46 Vishnu

DINABEN DILIPKUMAR PATEL,NA vs. ASRIVS.INCOME TAX OFFICER, WARD-2, NAVSARI

In the result, ground related to the credit entry of Rs

Bench: Shri Pawan Singh

TDS was made on interest income and the same cannot be considered as undisclosed income as no return of income was filed as the income was below the taxable income. The ld. CIT(A) held that the addition of cash deposit

DINABEN DILIPKUMAR PATEL,NA vs. ARIVS.INCOME TAX OFFICER, WARD-2, NAVSARI, NAVSARI

In the result, ground related to the credit entry of Rs

Bench: Shri Pawan Singh

TDS was made on interest income and the same cannot be considered as undisclosed income as no return of income was filed as the income was below the taxable income. The ld. CIT(A) held that the addition of cash deposit

ARJUNSINH HARISINH THAKOR,SURAT vs. INCOME TAX OFFICER, BARDOLI

In the result, grounds No

Bench: Shri Pawan Singh(Physical Hearing) Arjunsinh Harisinh Thakor, I.T.O., 1 Thakor Niwas, Zanda Chowk, Ward-1, Vs. Tarasadi Road, Kosamba, Bardoli. Surat-394120. Pan No. Aabpt 1270 G Appellant/ Assessee Respondent/ Revenue

TDS of Rs. 1.00 lac on 18/04/2016 which was repaid on 11 Arjunsinh Harisinh Thakor Vs ITO 18/04/2016 itself and on remaining entries in this account are about Rs.2,000/- only except one deposit of Rs. 15,000/- on 29/10/2016 and thereafter cash

ITO, WARD-3(3)(1), SURAT vs. SHRI ARVINDBHAI RATANBHAI MOKANI, SURAT

In the result, this appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) I.T.O., Arvindbhai Ratanbhai Mokani, Ward-3(3)(1), D-260-261, Vittal Nagar Society, Vs. Surat. Varachha Road, Hira Baug, Surat-395006. Pan No. Ahfpm 2302 K Appellant/ Assessee Respondent/ Revenue

cash deposit on various dates in his bank account. The assessee furnished such details as per para 3.1 as recorded on page No. 5 of order of ld. CIT(A). The assessee submitted that the assessee has shown turnover of Rs. 27,19,043/-, the assessee was having sufficient inflow of funds to make necessary deposits

CHIRAGBHAI S. GADHIYA,SURAT vs. I.T.O., WARD-3(2)(6),, SURAT

In the result, this appeal of assessee is allowed

Bench: Shri Pawan Singh(Physical Hearing) Chiragbhai S. Gadhiya, I.T.O., 79, Mani Nagar Society, Nana Ward-3(2)(6), Vs. Varachha, Nr. Sarthana Jakat Naka, Surat. Surat-395006. Pan No. Ajypg 7927 K Appellant/ Assessee Respondent/ Revenue

cash deposit during demonetization period. Copy of TDS form was furnished. On the basis of aforesaid submission, the assessee requested

SHRI BALKRISHNA M. GOSWAMI,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(2)(1),, SURAT

In the result, the appeal of the assessee is partly allowed

Bench: C .M. Garg, Jm & O. P. Meena, Am

cash from clients and deposit the same in his bank account which later on remitted through DD or cheque to Insurance Company as payment towards premium on behalf of the clients. The ld. A.R. referred Paper Book Page No. 8 to 14 being bank statement and submitted that the withdrawal in bank account clearly indicate that these were withdrawn towards

NARESHBHAI VIJAYBHAI GAMIT,TAPI vs. INCOME TAX OFFICER, WARD - 1, BARDOLI

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh(Virtual Hearing) Nareshbhai Vijaybhai Gamit, I.T.O., Shop No. 37, Riddhi Siddhi Palace, Ward-1, Vs. Old Bus Stand, Vyara, Bardoli. District- Tapi-394650. Pan No. Bqbpg 4350 D Appellant/ Assessee Respondent/ Revenue

cash deposit. The assessee filed his reply and submitted that he has received commission of Rs. 2,87,352/- from Idea Cellular on which TDS

SATHAIYA GANAPATHY,PUDUKOTTAI vs. ITO, WARD 1, BARDOLI

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.329 & 330/Srt/2025 Assessment Years: (2015-16) (Physical Hearing) Sathaiya Ganapathy, Vs. Ito, Ts No.4114, South 3 Rd Street, Ward – 1, Pukukottai, Tamil Nadu - 622001 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahbpg2414Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mayank A. Ogriwala, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 26/11/2025

cash deposit in Bank Account. 2. On the facts and in the circumstances of the case, and in law, the learned Commissioner of Income Tax (Appeals) as well as learned Assessing Officer have erred in not allowing deduction of housing loan interest of Rs.2,00,000/- as per section 24 of Income Tax Act while assessing the total income

SATHAIYA GANAPATHY,PUDUKOTTAI vs. ITO, WARD 1 , BARDOLI

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.329 & 330/Srt/2025 Assessment Years: (2015-16) (Physical Hearing) Sathaiya Ganapathy, Vs. Ito, Ts No.4114, South 3 Rd Street, Ward – 1, Pukukottai, Tamil Nadu - 622001 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahbpg2414Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mayank A. Ogriwala, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 26/11/2025

cash deposit in Bank Account. 2. On the facts and in the circumstances of the case, and in law, the learned Commissioner of Income Tax (Appeals) as well as learned Assessing Officer have erred in not allowing deduction of housing loan interest of Rs.2,00,000/- as per section 24 of Income Tax Act while assessing the total income

SHREE ABHISHEK BIPINBHAI NAIK,SURAT vs. INCOME TAX OFFICER, WARD 1(2)(1), SURAT

In the result, the ground No

Bench: Shri Pawan Singh(Virtual Hearing) Abhishek Bipinbhai Naik I.T.O., (Prop. Of M/S Shivbhole Services), Ward 1(2)(1), Vs. House No. 1, Desai Faliyu, At Po Surat. Vaktana, Tal, Choryasi Via Sachin, Surat-394230. Pan No. Agppn 5994 H Appellant/ Assessee Respondent/ Revenue

cash deposit with supporting evidence. The Assessing Officer recorded that the assessee has not furnished any reply/document/explanation or information to the said show cause notice. The Assessing Officer in absence of any explanation added the entire amount as unexplained and brought the same to tax under Section 115BBE of the Income Tax Act, 1961 (in short

CHANCHALBEN DAHYABHAI PATEL,DAMAN vs. INCOME TAX OFFICER, DAMAN

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1035-1038/Srt/2024 (Ays: 2011-12, 2013-14, 2014-15 & 2015-16) (Hybrid Hearing) Chanchalben Dahyabhai Patel Income Tax Officer, Ward-Daman, 40, A.Dabhel Ghelwad Faila, बनाम / Jeevanji Hotel Building, Kathiria, Nani, Daman-396 210 Vs. Devka Road, Nani Daman-396 210 स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aljpp 3816 D (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Appellant By Shri Chandra Jha, Ar राजस्व की ओर से /Respondent By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 26/03/2025 उद्घोषणा की तारीख/Date Of Pronouncement | 09/06/2025 आदेश / Order Per Bijayananda Pruseth, Am: These Four Appeals By The Assessee Emanate From Separate Orders Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act') By The National Faceless Appeal Centre, Delhi/Commissioner Of Income-Tax (Appeals) [In Short, “Nfac/Cit(E)”] All Dated 13.08.2024, For The Assessment Years (Ay) 2011-12, 2013-14, 2014-15 & 2015-16, Which In Turn Arose Out Of Assessment Orders Passed By Assessing Officer (In Short, ‘Ao') U/S 147 R.W.S. 144 R.W.S.144B Of The Act On 26.12.2018, 25.03.2022 & 28.03.2022 Respectively. In All The Appeals, The Facts Are Common & Grounds Of Appeals Raised By The Assessee Are Similar Except Variance Of Amounts. Hence, With The Consent Of The Parties, All The Appeals Were Clubbed & Heard Together & Are Decided By This Consolidated Order For Sake Of Convenience & Brevity.

cash deposits are not income. 4. In para 12 of the assessment order there is an addition of Rs.20,00,000 as unexplained investments. All fixed deposits are made and paid from the bank accounts itself. It is evident from the bank statements, where from fixed deposits are made.in the previous two paragraphs all the credit entries are added

SHRI LALCHAND DHARIWAL,,SURAT vs. THE INCOME TAX OFFICER, WARD-1(2)(3),, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.2623/Ahd/2016 िनधा"रण वष"/Assessment Year:2012-13 Shri Lalchand P. Dhariwal, Income Tax Officer, Prop. M/S. Adinath Textile , Ward- 1(2)(3) Surat O-21-23 Bombay Market Umarwada Surat Pan: Aatpd 0682 Q अपीलाथ" Appellant ""यथ"/Respondent

deposited in bank account of those creditors because under the law the assessee can be asked to prove the source of credits in his books of accounts but not the source of source. In view of these facts, the addition of Rs. 18,56,000 is therefore, deleted. We further note that the loan of Rs. 2,75,000 taken

ANILKUMAR HARISHANKAR PANDEY,SURAT vs. INCOME TAX OFFICER, WARD - 2(3)(1), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.587/Srt/2023 Assessment Year: (2010-11) (Physical Hearing) Anilkumr Harishankar Pandey Income Tax Officer, Okit Bi,38/A, Kailash Nagar Vs. Ward-2(3)(1), Surat, Room Society, Godadara Road, No.614, Aayakar Bhawan, Surat–394211 Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Akopp 3431C (अपीलाथ"/Appellant) (""थ" /Respondent)

deposited total cash of Rs.11,11,350/- and Rs.12,56,050/- on various dates in his bank accounts. Further from the verification of ITS data/26AS details, it was observed by Assessing Officer that the assessee received an amount of Rs.4,35,134/- and Rs.37,800/- from Rapid Transport Corporation and Vinay Cargo Movies respectively on various dates on which TDS

PARVATIBEN BHAGUBHAI PATEL,VALSAD vs. INCOME TAX OFFICER, WARD-7, VAPI, VAPI

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

Bench: Shri Pawan Singh(Physical Hearing) Parvatiben Bhagubhai Patel, Vs. The Ito, Dungri, Ponia Falia Udwada, Ward -7, Valsad – 396185. Vapi Pan : Afipp2146M Appellant Respondednt

deposited cash of Rs.9,80,000/- in the bank account for Bank of Baroda (BoB) and also earned salary income on which TDS