SMT. URVASHI SANJAYKUMAR GUPTA,,SURAT vs. ITO, WARD-2(3)(4), SURAT

In the result, this appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainismt. Urvashi Sanjaykumar Gupta, I.T.O., Ratna Vihar Apartment, New City Ward-2(3)(4), Vs. Light, Surat-395007. Surat. Pan No. Aanpg 4855 C Appellant/ Assessee Respondent/ Revenue

gain. It is also undisputed fact that the Assessing officer has not issued any show cause notice to the assessee on 6 Smt. Urvashi Sanjaykumar Gupta Vs ITO the issue of long term capital or on penny stock. The case of assessee throughout the proceeding are that she intended to avail benefit of TDS

SHRI DINESHBHAI VITTALBHAI PATEL,,SURAT vs. THE INCOME TAX OFFICER,, SURAT

In the result, the appeal of the assessee partly allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.970/Ahd/2016 िनधा"रण वष"/Assessment Year:2009-10 Shri Dineshbhai Vittalbhai Income Tax Officer, Patel, Ward- 2(3)(7), Surat 6/1261, Bhut Sheri, Mahidharpura Surat Pan: Aatwpp 3597J अपीलाथ" Appellant ""यथ"/Respondent

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

DHANSUKHBHAI PARAGJIBHAI PATEL,,SURAT vs. THE DCIT, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee partly allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1021/Ahd/2016 िनधा"रण वष"/Assessment Year:2009-10 Shri Dhansukhbhai Deputy Commissioner Of Paragjibhai Patel, Income-Tax, 143, Brahaman Faliya, Circle - 2(3) Surat Dindoli Udhna 394210 Pan: Avdpp7007 L अपीलाथ" Appellant ""यथ"/Respondent

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

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

TDS had been deducted thereupon, but the assessee failed to file the return of income/computation of income. Therefore, the salary income of Rs.82,12,480/- was added to the total income without allowing deductions u/s.24(b) and Chapter VIA therefrom. 5.3 With regard to purchase of equity shares, AO on perusal of P & L statement furnished by the assessee, noticed

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

TDS had been deducted thereupon, but the assessee failed to file the return of income/computation of income. Therefore, the salary income of Rs.82,12,480/- was added to the total income without allowing deductions u/s.24(b) and Chapter VIA therefrom. 5.3 With regard to purchase of equity shares, AO on perusal of P & L statement furnished by the assessee, noticed

SARLABEN DAHYABHAI PATEL,SURAT vs. INCOME TAX OFFICER, WARD - 2(2)(4), SURAT

In the result, this ground is allowed for statistical purposes

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

long term capital gain was increase on the basis of deeming fiction of Section 50C, the Assessing Officer ought to have allowed higher deduction under section 54F of the Act on proportionate basis due to increase in the figure of capital gain. The Assessing Officer disallowed deduction under section 54F by holding that assessee has not furnished confirmation of contractor

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, Vs. Jeevanji Hotel Building, Kathiria, Nani, Daman-396 210 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.

Long term capital gain not short term capital gain as considered in the order. 2.2. Even the purchase consideration and improvement thereon was considered as NIL. This is an absurd consideration for raising an exorbitant demand to make a dossier case without appreciating the facts of the case. Calculation of LTCG is attached in annexure of the submission. 2.3. These

SHRI PRAVINKUMAR M. PATEL,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(2),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI ISHWARBHAI ZINABHAI PATEL,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(3)(2),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI NATVARBHAI K. PATEL,,SURAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI SATISHBHAI M. PATEL,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI SAMEERKUMAR J. PATEL,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI GOPALBHAI H. PATEL,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(3)(5),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI CHAMPAKBHAI K. PATEL,,SURAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(3),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

SHRI ISHWARBHAI M. PATEL,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(3)(2),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

PREMILABEN M. BHANDARI,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, RANGE-2(3),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

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

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain

VASANTBHAI MOHANBHAI BHANDHARI,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(3)(4),, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member Sn

TDS certificate dated 11.04.2008 bearing certificate No. 7195 wherein it is stated under “NATURE OF PAYMENT “as Contractor Bill may be read as “Compulsory acquisition” (Land/Building). Any inconvenience on account of same may kindly be excused. Therefore, it was contended that the agricultural land in question was acquired under compulsory acquisition hence; no long-term capital gain