SHRI PRAKASHBHAI HARIBHAI AHIR,SURAT vs. THE INCOME TAX OFFICER, WARD-1(3), SURAT

In the result, the ground No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shri Prakashbhai Haribhai Ahir, The Income Tax Officer, 23, Ashish Society, Ward-1(3)(8), Surat. Vs B/H.Navyug College, Rander Road, Surat. Pan: Abfpa 9237 R Appellant Respondent

section 24(a) of the Act of Rs.1,86,257/-. The AO on perusal of record noticed that in fact the assessee has received commission of Rs.65,20,856/- from Dhru Motors. The Dhru Motors also made TDS

SACH ELECTRO MECH PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(1)(2),, SURAT

In the result ground No. 4 of the appeal is allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr Arjun Lal Saini, Hon'Ble(Virtual Court - Virtual Hearing) आ.अ.सं./I.T.A No.262/Ahd/2017 "नधा"रण वष"/Assessment Year: 2013-14 Sach Electro Mech Pvt. Ltd., V The Income Tax Officer, C/2, Maheshwari Apartment, S Ward-2(1)(2), Surat. Timaliyawad, Nanpura, . Surat – 395 001. [Pan: Aaics 8963 M] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Manish J.Shah – Ar राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr

TDS under section 37 and disallowance of Rs.61,883/- under section 14A of the Act. On appeal before ld. CIT(A), the action of the A.O. was upheld. 3. Being aggrieved, the assessee filed appeal before this Tribunal. 4. We have heard the submissions of learned authorized representative (Ld. AR) of the assessee and the learned departmental representative

ENGINEERING PROFESSIONAL CO. PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.541/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Engineering Professional Co. Pvt. Ltd., Vs. The Pcit -1, 444, Royal Arcade, Opp. Sarthana Zoo, Surat Varachha Road, Near Sarthana Jakatnaka, Surat – 395006, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabce0313Q (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ravi Kant Gupta, Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 19/02/2025

24 Vlshal Limbabhai Desai (TDS Deducted) AUEPD9432H 849,380 25 Bharatbhai H. Mangukiya (Form 26A ARXPM6823D 750,630 attached) 26 Govindbhai R. Patel (Form 26A ANRPP6788L 13,499,921 attached) 27 Jay Balanand Construction (Form 26A AAJFJ7023K 91,959,227 attached) 28 Pareshbhai Punjabhai Vanzara (Form AZDPV7852K 458,000 26A attached) ITA No.541/SRT/2024/AY.2018-19 Engineering Professional Co. Pvt. Ltd. 29 Other

BANK OF INDIA, ,SURAT vs. DY. CIT, TDS, CIRCLE, SURAT, SURAT

In the result, assessee’s both appeals are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am

TDS with the Revenue which are the amount of correction carried out is also not the material and are quite negligible. Such fact is asserted by assessee-bank itself while making such submission. The Ld. AR for the assessee further submits that ITAT Mumbai Benches in the ITA.No 246-248 & 323/SRT/2019 A.Ys.09-10 to 11-12 Bank of India

BANK OF INDIA, ,SURAT vs. DY. CIT, TDS, CIRCLE, SURAT, SURAT

In the result, assessee’s both appeals are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am

TDS with the Revenue which are the amount of correction carried out is also not the material and are quite negligible. Such fact is asserted by assessee-bank itself while making such submission. The Ld. AR for the assessee further submits that ITAT Mumbai Benches in the ITA.No 246-248 & 323/SRT/2019 A.Ys.09-10 to 11-12 Bank of India

BANK OF INDIA,SURAT vs. ITO (TDS-1), SURAT, SURAT

In the result, assessee’s both appeals are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am

TDS with the Revenue which are the amount of correction carried out is also not the material and are quite negligible. Such fact is asserted by assessee-bank itself while making such submission. The Ld. AR for the assessee further submits that ITAT Mumbai Benches in the ITA.No 246-248 & 323/SRT/2019 A.Ys.09-10 to 11-12 Bank of India

BANK OF INDIA, ,SURAT vs. DY. CIT, TDS, CIRCLE, SURAT, SURAT

In the result, assessee’s both appeals are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am

TDS with the Revenue which are the amount of correction carried out is also not the material and are quite negligible. Such fact is asserted by assessee-bank itself while making such submission. The Ld. AR for the assessee further submits that ITAT Mumbai Benches in the ITA.No 246-248 & 323/SRT/2019 A.Ys.09-10 to 11-12 Bank of India

SHREE DURGA SYNTEX PRIVATE LIMITED,SURAT vs. ACIT, CIRCLE-4, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) D.C.I.T. M/S Shree Durga Syntex Pvt. Ltd., Circle-2(1)(2), Block No. 129 & 175, Plot No. Z&E, R.S. Vs. Room No. 205, Aayakar No. 120, Tal: Jolva-394305, Dist- Surat. Bhavan, Majura Gate, Pan: Aabcd 8894 P Surat. Appellant Respondednt M/S Shree Durga Syntex Pvt. Ltd., A.C.I.T. Block No. 129 & 175, Plot No. Circle-4, Vs. Z&E, Jolva Rs No. 120 & 120/1, Surat. Surat-394305. Pan: Aabcd 8894 P Appellant Respondednt

24)(x) of the Act. 2. It is therefore prayed that the above addition made by the Assessing Officer may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 4. Brief facts of the case are that the assessee is a company engaged

DCIT, CIRCLE-2(1)(2), SURAT vs. M/S. SHREE DURGA SYNTEX PVT. LTD, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) D.C.I.T. M/S Shree Durga Syntex Pvt. Ltd., Circle-2(1)(2), Block No. 129 & 175, Plot No. Z&E, R.S. Vs. Room No. 205, Aayakar No. 120, Tal: Jolva-394305, Dist- Surat. Bhavan, Majura Gate, Pan: Aabcd 8894 P Surat. Appellant Respondednt M/S Shree Durga Syntex Pvt. Ltd., A.C.I.T. Block No. 129 & 175, Plot No. Circle-4, Vs. Z&E, Jolva Rs No. 120 & 120/1, Surat. Surat-394305. Pan: Aabcd 8894 P Appellant Respondednt

24)(x) of the Act. 2. It is therefore prayed that the above addition made by the Assessing Officer may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 4. Brief facts of the case are that the assessee is a company engaged

VAPI GREEN ENVIRO LIMITED,VAPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, , VALSAD

In the result, various grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Vapi Green Enviro Limited, Pr.C.I.T., Valsad. 135, 1St Floor, Via House, G.I.D.C. 301, 3Rd Floor, Palak Vs. Char Rasta, Vapi, Gujarat, Arcade, Shanti Nagar, India-396195. Tithal Road, Pan: Aaacv 8289 P Valsad-396001. Appellant Respondednt

TDS. 4. The Ld. Commissioner of Income Tax (Exemption) has erred in overlooking the fact that, the Appellant has claimed gross income of Rs.52,71,01,098/- as exempt on applicability of mutuality principles and the Appellant has not claimed any expenditure as they are related to exempt income. 5. The Ld. Commissioner of Income Tax (Exemption) has erred

THE DCIT, CIRCLE-1,, BHARUCH vs. M/S. GUJARAT NARMADA VALLEY FERTILIZERS & CHEMICALS LTD.,, BHARUCH

In the result, this ground of appeal is also dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.431/Srt/2018 (Ay 2007-08) & (Hearing In Virtual Court) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Bharuch, Fertilizers & Chemicals Vs Above Bank Of Baroda, Ltd. Station Road, Bharuch- P.O. Narmada Nagar, 320001 Dist. Bharuch-392015 Pan : Aaacg 8372 Q अपीलाथ"/Appellant ""यथ" /Respondent आ.अ.सं./Ita No.432/Srt/2018 & ""या"ेप/C.O. No.12/Srt/2021 [A/O Ita No.432/Srt/2018] (Ay 2012-13) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Fertilizers & Chemicals Ltd. Vs Bharuch, Above Bank Of P.O. Narmada Nagar, Dist. Baroda, Station Road, Bharuch-392015 Pan : Aaacg 8372 Q Bharuch-320001 अपीलाथ"/Appellant ""यथ" /Respondent/Co- Objector

TDS is made on the 24 ITA No.431-432/SRT/2018 & CO 12/SRT/2021 (A.Ys 07-08 & 12-13) M/s Gujarat Narmada Valley Fertilizers & Chemicals Ltd. discount of Rs. 4.697 crore made to dealers. The assessing officer held that dealers are acting as agent of the assessee and like commission agent. The so-called dealers have rendered services in the course of buying

THE DCIT, CIRCLE-1,, BHARUCH vs. M/S. GUJARAT NARMADA VALLEY FERTILIZERS & CHEMICALS LTD.,, BHARUCH

In the result, this ground of appeal is also dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.431/Srt/2018 (Ay 2007-08) & (Hearing In Virtual Court) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Bharuch, Fertilizers & Chemicals Vs Above Bank Of Baroda, Ltd. Station Road, Bharuch- P.O. Narmada Nagar, 320001 Dist. Bharuch-392015 Pan : Aaacg 8372 Q अपीलाथ"/Appellant ""यथ" /Respondent आ.अ.सं./Ita No.432/Srt/2018 & ""या"ेप/C.O. No.12/Srt/2021 [A/O Ita No.432/Srt/2018] (Ay 2012-13) Deputy Commissioner Of Gujarat Narmada Valley Income-Tax, Circle-1 Fertilizers & Chemicals Ltd. Vs Bharuch, Above Bank Of P.O. Narmada Nagar, Dist. Baroda, Station Road, Bharuch-392015 Pan : Aaacg 8372 Q Bharuch-320001 अपीलाथ"/Appellant ""यथ" /Respondent/Co- Objector

TDS is made on the 24 ITA No.431-432/SRT/2018 & CO 12/SRT/2021 (A.Ys 07-08 & 12-13) M/s Gujarat Narmada Valley Fertilizers & Chemicals Ltd. discount of Rs. 4.697 crore made to dealers. The assessing officer held that dealers are acting as agent of the assessee and like commission agent. The so-called dealers have rendered services in the course of buying

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

TDS, Circle- Ranchi under section 131 (1)(d) of the Act to conduct enquiries in case of the lenders based at Ranchi. The said officers have sent the enquiry reports, which are framing part of assessment order. The findings of the AO as per chart is as under: S. Name of the Alleged Findings of enquiry N. Lenders Loan(includi

M/S. K.N. DIAMOND,,BILIMORA vs. THE ASSTT. COMMISSIONER OF INCOME TAX, NAVSARI CIRCLE,, NAVSARI

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.1788/Ahd/2016 "नधा"रण वष"/Assessment Year: 2012-13 M/S K.N.Diamond, Vs. The Assistant Commissioner Soniwad, Bilimora, Of Income Tax, Navsari Navsari – 396 321. Circle, Navsari. [Pan: Aadfk 3167 H] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Parimalsinh Parmar – Advocate राज"वक"ओर से /Revenue By Smt. Anupama Singla – Sr.Dr

24% per annum was held to be reasonable. It was and also submitted that in any case, the assessing officer is not supposed to decide the “reasonableness” or any expenditure. It is submitted that the prerogative of a businessman to determine the amount of expenditure. The Assessing Officer cannot step into the shoes of a businessman to determine quantum

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

TDS form was furnished. On the basis of aforesaid submission, the assessee requested to delete the addition under Section 68 of the Act of Rs. 24

SACH ELECTRO MECH PVT. LTD.,,SURAT vs. PR. CIT-2, SURAT

In the result, the grounds of appeal raised by the assessee is allowed

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

TDS services (Rs.) deducted Rs. 1 Weal developers 15,26,796 30,557 2 Synergy Developers 10,00,650 20,113 ITA 392/SRT/2018 Sach Electro Mech P Ltd. Vs PR.CIT 3 Sar Infracon 52,41,574 1,04,831 4 Gurang Yogeshbhai 81,24,446 16,24,489 5 Hazira Lng Ltd 16,86,271 36,556 Total

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

section 24 of Income Tax Act while assessing the total income of the assessee. 3. 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 under chapter VIA of Rs.1,50,000 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

section 24 of Income Tax Act while assessing the total income of the assessee. 3. 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 under chapter VIA of Rs.1,50,000 while assessing the total income