THE ITO, (INTERNATIONAL TAXATION),, SURAT vs. MICRO INKS LIMITED,, VAPI

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.2375/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 The Income Tax Officer, V Micro Inks Limited, (International Taxation), Surat. S. Bilakhia House, Muktanand Marg, Chala, Vapi – 396 191. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2707/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 Micro Inks Limited, V The Income Tax Officer, Bilakhia House, Muktanand S. (International Taxation), Marg, Chala, Vapi – 396 191. Surat. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Gopala Krishnan – Ca राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr सुनवाईकीतारीख/ Date Of Hearing: 06.02.2020 उ"घोषणाक"तार"ख/Pronouncement On: 14.02.2020

TDS on the said payment, because of benefit of exception Clause provided in Sec-(1)(v)(b) of the Act. However, the ld.Assessing Officer had not considered manufacturing activities through wholly owned subsidiaries as a business carried on outside India. The company had raised debts in foreign currencies. Under scheme quoted by Reserve Bank of India known as external commercial

VIKRAM HARSHADBHAI MODI,SURAT vs. ITO WARD 3(1)(5), SURAT

In the result, Ground No.2 and 3 of the assessee are partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shri Vikram Harshadbhai The Income Tax Officer Modi, Ward-3(1)(5), Aaykar Vs 7/2737, Chandulal Sheth Ni Bhavan, Majura Gate, Sheri, Saiyedpura, Surat-395001 Surat-395003 Pan : Alhpm 2036 Q Assessee / Appellant Revenue /Respondent

TDS was made under section 194C of the Act. The assessee is covered by the provision of section 44AD of the Act and the income earned by the assessee was less than the minimum income chargeable to tax amounting to Rs.1,60,428/- and the assessee was not required to file return of income. Even in response to notice under

THE UDHNA CITIZEN CO OPP. BANK LIMITED ,NOW MERGE WITH KALUPUR COMMERCIAL CO.OP. BANK LTD,AHMEDABAD vs. I.T.O TDS -2 , SURAT

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

Bench: Shri Sanjay Gargshri Narendra Prasad Sinha

section 201(1) of the Act. In order to avoid being treated as “assessee in default” for non-deduction of TDS, the assessee was required to bring on record the evidence that the recipients of rent and legal and consultation fees had satisfied the following conditions and furnish a certificate as under: The Udhna Citizen cooperative Bank Limited

SURAT DISTRICT CO.OP.MILK PRODUCERS UNION LTD.,,SURAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -3(2),, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) The Surat District Co-Op. Dy. Commissioner Of Milk Producer’S Union Ltd., Income Tax, Circle-3(2), Vs Sumul Dairy Road, Station Aaykar Bhavan, Majura Road, Surat Gate, Surat Pan : Aaaas 3450 M Assessee / Appellant Revenue /Respondent

139 of the Act, has taken into account such sum for computing income of such return of income and has paid the tax due on the income declared by him and the person furnishes a certificate to this effect from an accountant in such form as may be prescribed. The assessee further explained has furnished the certificate of Chartered accountant

VIRAL SHAILESH SHAH,VALSAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE, VALSAD, VALSAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.536/Srt/2023 Assessment Year: (2011-12) (Physical Hearing) Viral Shailesh Shah, Vs. The Acit, C/O. Dr. Shailesh V. Shah, B/H. Valsad Circle, Pramanik Store, Opp. Atul First Valsad Gate, Atul, Valsad – 396020. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bfaps6008A (Assessee) (Respondent)

section 139 of I.T. Act. Therefore, assessee’s case was re- opened and accordingly, notice u/s 148 of the Act was issued on 25.03.2018 by the ITO, Ward-4, Valsad after obtaining approval of Ld. Pr. CIT, Valsad u/s 151(1) of the IT Act and the same was duly served upon the assessee. 5. As per AIR information

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:

139(1) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) on 29.09.2015 declaring total income at Rs. 7,60,01,880/-. Subsequently, scrutiny assessment under Section 143(3) of the Act was completed on 20.12.2017 accepting the returned income. The case was reopened under Section 147 of the Act on the basis of information received from

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:

139(1) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) on 29.09.2015 declaring total income at Rs. 7,60,01,880/-. Subsequently, scrutiny assessment under Section 143(3) of the Act was completed on 20.12.2017 accepting the returned income. The case was reopened under Section 147 of the Act on the basis of information received from

ACIT,CIRCLE-2,, BHARUCH vs. SHRI MOHMEDSADIK A SHAIKH, ANKALESHWAR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.682/Srt/2018 ("नधा"रणवष" / Assessment Years: (2014-15) (Virtual Court Hearing) The Acit, Circle-2, Vs. Mohmedsadik A. Shaikh, Bharuch. Prop. Of Earth Power, Behind Mona Complex, Rajpipla Chowkdi, Ankleshwar-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahzps5638N (Appellant)/(Revenue) (Respondent)/(Assessee) Assessee By : Ms Kinjal V. Shah, Ca Revenue By : Shri Deependra Kumar, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 27/04/2022 घोषणाक"तार"ख/Date Of Pronouncement : 27/06/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2014-15, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-3, Vadodara [In Short “The Ld. Cit(A)”] In Appeal No. Cit(A)-Vadodara-3/10033/2017-18, Dated 30.07.2018, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

9) are directed to be deleted except interest on income tax refund which is taxable under any circumstances” without appreciating that the assessee had filed return of income and attended assessment proceedings, the A.O. could not have made best judgment assessment u/s 144 of the Act and consequently, the A.O. had correctly made above referred addition on the basis

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

139/-. The assessee made deposits of Rs. 31,42,500/- on various dates between 10/11/2016 to 03/12/2016. The ld AR for the assessee filed cash flow statement. The ld. AR further submits that the assessee is consistently showing good return of income and furnished following bifurcation of return of income for various years: Income as per Return filed

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,BHARUCH vs. THE DY.CIT.,BHARUCH CIRCLE,, BHARUCH

In the result, this ground of appeal is allowed for statistical purpose

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

9. On the facts and in the circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in adding back the following amount while computing the book profits under section 115JB of the Act. (a) Provision for post closure expenditure – Rs.29,84,694/- (b) Provision of pit covering expenses - Rs.1

THE ACIT,BHARUCH CIRCLE,, BHARUCH vs. BHARUCH ENVIRO INFRASTRUCTURE LTD.,, ANKLESHWAR

In the result, this ground of appeal is allowed for statistical purpose

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

9. On the facts and in the circumstances of the case and in law, the CIT(A) erred in upholding the action of the AO in adding back the following amount while computing the book profits under section 115JB of the Act. (a) Provision for post closure expenditure – Rs.29,84,694/- (b) Provision of pit covering expenses - Rs.1

SWASTIK CORPORATION,VAPI vs. PR. CIT 3, VALSAD

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.21/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) (Virtual Court Hearing) M/S Swastik Corporation The Principal Commissioner Of Income Tax-3, Room No.301, 3Rd Floor, Palak A-305, Surya Co-Operative Vs. Housing Society Ltd., Plot Arcade, Pali Hill Shanti Nagar, Tithal No.61, Vapi-396195 Road,Valsad-396001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abtfs 1028 G अपीलाथ"/ Appellant ""थ" / Respondent

9. We have heard the rival contentions, perused the material on record and duly considered facts of the case in the light of the applicable legal position. In our considered view, it was wholly erroneous on the part of the ld PCIT to exercise jurisdiction u/s 263 of the Act in respect of the part amount for which the Assessing

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT

In the result, Revenue’s appeal is dismissed

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

TDS made on such interest and the amount received and repaid during the year. Such details are recorded by ld CITA) at page No. 18 & 19 of his order. The assessee also stated that the assessing officer considered only peak of all transaction and made addition of Rs. 4.15 Crore in AY 2010-11 and Rs. 2.14 Crore

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

GREENLINE ECOFAB PVT. LTD.,SURAT vs. ACIT, CIRCLE 1(1)(2), SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1373/Srt/2024 Assessment Year: (2012-13) (Physical Hearing) Greenline Ecofab Pvt. Ltd. Assistant Commissioner Of बनाम/ 406, Jeevan Deep, Opp. Sub- Income-Tax, Circle- 1(1)(2), Vs. Jail, Ring Road, Surat-395 002 Surat, 1St Floor, Aaykar Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaecg 2881 N (अपीलाथ"/Appellant) (""यथ"/Respondent)

139 of the Act on 20.10.2012, which was taken up for scrutiny and assessment order u/s 143(3) was passed on 28.03.2012 by the ITO Ward-1(2), Surat. It is evident from the paper book submitted by the appellant that complete details with evidences of share capital and share premium were furnished during the original assessment proceedings. Copy

KISHOR RAMESHBHAI MEHTA,SURAT vs. ITO, WARD-1(5), BHARUCH

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.60/Srt/2025 Assessment Year: 2013-14 (Hybrid Hearing) Kishor Rameshbhai Mehta Vs. Ito, Prop. Of Aditya Infrastructure, Ward - 1(5), 139, Maher Nagar, Opp. Baps Bharuch Hospital, Adajan Gam Circle, Surat - 395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adepm 4458 R (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 10/11/2025

139, Maher Nagar, Opp. BAPS Bharuch Hospital, Adajan Gam Circle, Surat - 395 009 "थायीलेखासं./जीआइआरसं./PAN/GIR No: ADEPM 4458 R (Appellant) (Respondent) Appellant by Shri P. M. Jagasheth, CA Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 12/08/2025 Date of Pronouncement 10/11/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM: This appeal by the assessee emanates

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURA, SURAT vs. PIPODRA TEXTILE PARK LLP, SURAT

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.795/Srt/2024 Assessment Year: (2018-19) (Hybrid Hearing) Acit, Vs. Pipodra Textile Park Llp, S No.85, Vilol. Lindiad, Tal: Central Circle-3, Mangrol, Surat - 395002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aasfp8206B (Appellant) (Respondent) ""या"ेप सं /Co No.27/Srt/2024 (Ay 2018-19) (A/O Ita No.795/Srt/2024 Pipodra Textile Park Llp Vs. Acit, S No.85, Vilol. Lindiad, Tal: Central Circle-3, Mangrol, Surat– 395 002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aasfp 8206 B (Co-Objector) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By Shri Ramesh Malpani, Ca राज"वक" ओर से /Respondent By Shri Mukesh Jain, Cit-Dr & Shri Kevin Langaliya, Ca सुनवाई क" तार"ख/Date Of Hearing 03/09/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 31/10/2025

section 250 of the Income-tax Act, 1961 (in short, 'the Act’) dated 29.05.2024 by the Commissioner of Income-tax (Appeals) - 4, Surat [in short, ‘the CIT(A)’] for the assessment year (AY) 2018- 19, which in turn arises out of assessment order passed by the Assistant ITA No.795/Srt/2024 & CO 27/SRT/2024 A.Y 18-19 Pipodra Textile Park LLP Commissioner

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

139(1) of the Act on 15.11.2017 declaring total income of Rs. 12,76,290/-.\nSubsequently, a search action was conducted u/s 132 of the Act in case of\nKuberji Group on 06.02.2020. The residential premises of Shri Naresh\nBisheshwarlal Agrawal (assessee herein) was also covered during the search and\nseizure operation. Various incriminating documents were found and seized\nwhich