DCIT, CIRCLE-2(2), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LIMITED, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

TDS on the same. (v) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has erred in deleting the disallowance of expenses towards Employees contribution to provident fund/shortfall Rs.29,00,000/- without appreciating the fact that the assessee is using this fund to cover up shortfall and pay employees contribution which is in fact

THE SURAT DISTRICT CO-OP. BANK LTD,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2), SURAT, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

TDS on the same. (v) On the facts and circumstances of the case and in Law, the Ld. CIT(A) has erred in deleting the disallowance of expenses towards Employees contribution to provident fund/shortfall Rs.29,00,000/- without appreciating the fact that the assessee is using this fund to cover up shortfall and pay employees contribution which is in fact

AKSHAR GEMS,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIR.3(2), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.24/Srt/2022 "नधा"रण वष"/Assessment Year: (2016-17) (Virtual Court Hearing) Akshar Gems, Assistant Commissioner Of 3Rd Floor, Shreeji Diamond Apartment, Vs. Income-Tax, Circle-3(2), Nandu Doshi Ni Wadi, Vastadevdi Road, Aaykar Bhavan Nr.Majura Katargam, Surat – 395004 Gate, Opp. New Civil Hospital, Surat-395001 (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aarfa3697A Assessee By Shri Mehul Shah, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 27/12/2022 Date Of Pronouncement 30/01/2023

TDS as per the provisions of the Act. It is worthwhile to mention that Section 195(6) has been amended during the year under consideration i.e. with effect from 01.06.2015 which is reproduced as given below: 'The person responsible for paying to a non-resident, not being a company, or to a foreign company, any sum, whether or not chargeable

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

MADHVI AJITKUMAR RANKA ,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI

In the result, the appeal is allowed for statistical purposes

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.124/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Madhvi Ajitkumar Ranka, Vs. Acit, 88, Sunder Nagar, Jamalpore, Navsari Circle, Navsari – 396445 Navsari "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahfpr5791K (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 01/09/2025 Date Of Pronouncement 26/11/2025

88, Sunder Nagar, Jamalpore, Navsari Circle, Navsari – 396445 Navsari "थायीलेखासं./जीआइआरसं./PAN/GIR No: AHFPR5791K (Appellant) (Respondent) Appellant by Shri Darshit J. Naik, CA Respondent by Shri Ajay Uke, Sr. DR Date of Hearing 01/09/2025 Date of Pronouncement 26/11/2025 आदेश / O R D E R PER BIJAYANANDA PRUSETH, AM: This appeal by the assessee emanates from the order passed under section

AMITKUMAR AGRAWAL,SURAT vs. ACIT, CIRCLE 1(2), SURAT

In the result, ground No.4 is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 25/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Amitkumar Agrawal Assistant Commissioner Of Income- I-2474-75, Millennium Textile Tax, Circle-1(2), Surat, बनाम Market, Ring Road, Room No.213, 2Nd Floor, Vs Surat-395 002 Aaykar Bhavan, Opp. [Pan : Ajtpa 4052 E] New Civil Hospital, Majura Gate, Surat-395 001 अपीलाथ"/Appellant ""थ" /Respondent

88,573/- and in AY.2017-18 of more than Rs.6.00 lakhs. The assessee furnished their confirmation and complete ITR. The ld. CIT(A) without discarding such submission, confirmed the addition of their loan amounts. No investigation of fact was carried out either by ld. CIT(A) or by AO. Once the assessee discharged his primary onus, in term of section

DHANUBEN RAMANBHAI SONAVADIYA,SURAT vs. ITO, WARD 1(3)(6), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.470/Srt/2024 Assessment Year: 2016-17 (Hybrid Hearing) Dhanuben Ramanbhai Income Tax Officer Ward-2(3)(7), बनाम/ Sonavadiya Surat, Anavil Business Center, Vs. A-1/102, Omkar Residency, Adajan Hazira Road, Adajan, Palanpur, Mahidharpura, Surat-395 007 Surat- 395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ebeps 7022 D (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri Sapnesh R Sheth, Advocate राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 29/07/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 27/08/2025

section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) dated 08.04.2024 by the National Faceless Appeal Centre, Delhi/Commissioner of Income-tax (Appeals) [in short ‘Ld. CIT(A)’] for the Assessment Year (AY) 2016-17, which in turn arises out of assessment order passed by Assessing Officer (in short, ‘AO’) u/s 143(3) of the Act dated

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

88,04,101/- without appreciating the\nfacts that in real estate market like in Surat, to evade the taxation, the\ntransactions are made on Plain papers/satakhat without registration of sale\ndeed.\nIt is, therefore, prayed that the order of the Ld. CIT(A) may be set aside and\nthat the AO may be restored to the above extent

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

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

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

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

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

88,04,101/- without appreciating the\nfacts that in real estate market like in Surat, to evade the taxation, the\ntransactions are made on Plain papers/satakhat without registration of sale\ndeed.\nIt is, therefore, prayed that the order of the Ld. CIT(A) may be set aside and\nthat the AO may be restored to the above extent.”\n8.\nGrounds

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

88,04,101/- without appreciating the\nfacts that in real estate market like in Surat, to evade the taxation, the\ntransactions are made on Plain papers/satakhat without registration of sale\ndeed.\nIt is, therefore, prayed that the order of the Ld. CIT(A) may be set aside and\nthat the AO may be restored to the above extent.\"\nGrounds

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

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

CHANCHALBEN DAHYABHAI PATEL,DAMAN vs. ITO, DAMAN

section 250 of the Income-tax Act, 1961 (in short, 'the Act') by\nthe National Faceless Appeal Centre, Delhi/Commissioner of Income-tax\n(Appeals) [in short, “NFAC/CIT(E)”] all dated 13.08.2024, for the Assessment\nYears (AY) 2011-12, 2013-14, 2014-15 and 2015-16, which in turn arose out of\nassessment orders passed by Assessing Officer (in short

ASSISTANT COMMISSIONER OF INCOME TAX,, NA vs. ARIVS.GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,, NAVSARI

In the result, appeal filed by the assessee in ITA No

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

88,58,570.00 2) AGRICULTURAL ITEMS EXEMPT ACTIVITY – POWER 6,91,75,341.00 21.18 TRILLER SALE TOTAL SALES AS PER THE 32,18,49,700.00 ORDER OF THE LEARNED AO 3) DISALLOWANCE – Rs.88,58,570/- 18,76,245.00 @ 21.18% DISALLOWANCE AS PER ASSESSEE 4) DISALLOWANCE AS per AO 64,66,977.00 DIFFERENCE

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

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

88,58,570.00 2) AGRICULTURAL ITEMS EXEMPT ACTIVITY – POWER 6,91,75,341.00 21.18 TRILLER SALE TOTAL SALES AS PER THE 32,18,49,700.00 ORDER OF THE LEARNED AO 3) DISALLOWANCE – Rs.88,58,570/- 18,76,245.00 @ 21.18% DISALLOWANCE AS PER ASSESSEE 4) DISALLOWANCE AS per AO 64,66,977.00 DIFFERENCE

GANDEVI TALUKA KHEDUT SAHAKARI SANGH LTD.,,NA vs. ARIVS.INCOME TAX OFFICER WARD-2, NAVSARI

In the result, appeal filed by the assessee in ITA No

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

88,58,570.00 2) AGRICULTURAL ITEMS EXEMPT ACTIVITY – POWER 6,91,75,341.00 21.18 TRILLER SALE TOTAL SALES AS PER THE 32,18,49,700.00 ORDER OF THE LEARNED AO 3) DISALLOWANCE – Rs.88,58,570/- 18,76,245.00 @ 21.18% DISALLOWANCE AS PER ASSESSEE 4) DISALLOWANCE AS per AO 64,66,977.00 DIFFERENCE