ACIT, CIRCLE-3(3), SURAT vs. M/S. D P VEKARIYA, SURAT

In the result, the appeal filed by the Revenue is dismissed,

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 172/Srt/2020 Assessment Year: (2009-10) (Physical Court Hearing) The Acit, Circle-3(3), Vs. M/S. D. P. Vekariya, Surat Skylark Shopping, B/H Kapodara Police Station, Varachha Road, Surat, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabfd 8442 Q (Revenue)/(Assessee) (Assessee)/(Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Abhishek Gautam, Sr. Dr 02/06/2022 Date Of Hearing 30/06/2022 Date Of Pronouncement

TDS credit of Rs.1,19,87,117/-, however the corresponding income was not taken into account. Thus, the contract income and interest income amounting to Rs.22,71,231/- was short accounted in profit and loss account. 4. Therefore, on the basis of above information available on record, reasons were recorded u/s 148(2) of the Act, by the assessing officer

SHRI GYANCHAND & JAIN,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

SHRI NARESH R. PAREEK,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(3),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

SHRI VIRENDRA KUMAR LODHA,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(5),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

SHRI ANIL G. KUMAWAT,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

SHRI ANIL G. KUMAWAT,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

SHRI SHARAD Y. JAIN,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(4),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI GYANCHAND SUGAMCHAND JAIN,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI ANIL GHANSHYAMBHAI KUMAWAT,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI ANIL GHANSHYAMBHAI KUMAWAT,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

THE INCOME TAX OFFICER, WARD-3(3)(5),, SURAT vs. SHRI VIRENDRA KUMAR LODHA,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court)

reassessment proceeding have not been fulfilled. 2. On the facts and in the circumstances of the case and in law, the Ld. CIT (A) erred in erred in treating the appellant as diamond trader, without appreciating the fact that the appellant is only a commission agent and the purchase and sale was made on behalf of other parties

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reassessment u/s 147 of the Act, observing as follows: “7. DISCUSSION AND DECISION OF THE APPELLATE AUTHORITY Ground regarding validity of re-opening and assessment there-on; 7.1.1 This ground of appeal pertains to validity of re - opening of the case u/s 147 of the Act and issuance of notice u/s 148 of the I.T. Act. I have perused

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reassessment u/s 147 of the Act, observing as follows: “7. DISCUSSION AND DECISION OF THE APPELLATE AUTHORITY Ground regarding validity of re-opening and assessment there-on; 7.1.1 This ground of appeal pertains to validity of re - opening of the case u/s 147 of the Act and issuance of notice u/s 148 of the I.T. Act. I have perused

ITO, WARD-2(3)(7), SURAT vs. ANSHUMAN RAMDAYALJI KUMAWAT, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reassessment u/s 147 of the Act, observing as follows: “7. DISCUSSION AND DECISION OF THE APPELLATE AUTHORITY Ground regarding validity of re-opening and assessment there-on; 7.1.1 This ground of appeal pertains to validity of re - opening of the case u/s 147 of the Act and issuance of notice u/s 148 of the I.T. Act. I have perused

ITO, WARD 2(3)(8), SURAT vs. MUKESH MAHAVIRPRASAD SEN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reassessment u/s 147 of the Act, observing as follows: “7. DISCUSSION AND DECISION OF THE APPELLATE AUTHORITY Ground regarding validity of re-opening and assessment there-on; 7.1.1 This ground of appeal pertains to validity of re - opening of the case u/s 147 of the Act and issuance of notice u/s 148 of the I.T. Act. I have perused

INCOME TAX OFFICER, WARD 2(3)(8), SURAT vs. SHRI RAJESH KUMAR PAMECHA, AJMER

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

reassessment u/s 147 of the Act, observing as follows: “7. DISCUSSION AND DECISION OF THE APPELLATE AUTHORITY Ground regarding validity of re-opening and assessment there-on; 7.1.1 This ground of appeal pertains to validity of re - opening of the case u/s 147 of the Act and issuance of notice u/s 148 of the I.T. Act. I have perused

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT, SURAT vs. SHRINIDHI ENTERPRIZE , SURAT

In the result, both the appeals of the Revenue are, hereby, dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita Nos.914/Srt/2024 & 797/Srt/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 The Acit Shrinidhi Enterprize Central Circle-3 बनाम/ 6/1862, 63, Ground Floor Surat Ghanshyam Bhuvan V/S. Bali Sheri, Mahidharpura Surat – 395 003 "थायी लेखा सं./Pan:Acbfs 6484 R (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ravi Kant Gupta, Cit(Dr) Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/08/2025 घोषणा की तारीख /Date Of Pronouncement: 23/09/2025 आदेश/O R D E R Per Sanjay Garg:

reassessment proceedings, the Assessing Officer (AO) observed that during the search and survey of Sadhani Brothers’ premises, various incriminating documents and evidence linking the assessee with accommodation entries were found. The AO reproduced complete details of the labour contract transactions amounting to Rs.3,61,86,444/- with parties managed by the Sadhani Brothers. The AO noted various discrepancies such

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT vs. SHRINIDHI ENTERPRIZE, SURAT

In the result, both the appeals of the Revenue are, hereby, dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita Nos.914/Srt/2024 & 797/Srt/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 The Acit Shrinidhi Enterprize Central Circle-3 बनाम/ 6/1862, 63, Ground Floor Surat Ghanshyam Bhuvan V/S. Bali Sheri, Mahidharpura Surat – 395 003 "थायी लेखा सं./Pan:Acbfs 6484 R (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ravi Kant Gupta, Cit(Dr) Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 05/08/2025 घोषणा की तारीख /Date Of Pronouncement: 23/09/2025 आदेश/O R D E R Per Sanjay Garg:

reassessment proceedings, the Assessing Officer (AO) observed that during the search and survey of Sadhani Brothers’ premises, various incriminating documents and evidence linking the assessee with accommodation entries were found. The AO reproduced complete details of the labour contract transactions amounting to Rs.3,61,86,444/- with parties managed by the Sadhani Brothers. The AO noted various discrepancies such

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

TDS for Rs.\n1,15,000/- in page 73 of A-23.\nxiii) The Respondent strongly relies on decision of PCIT V. Shri Kuberji Developers\n(IT (SS) A. No. 7 / SRT / 2024) (Paper book page No. 41 to 50) and DCIT V.\nHiteshkumar Laljibhai Patel (IT (SS) A. No. 114 / SRT / 2023) wherein addition\nwas made on the base