LATE MAHESH RAMANLAL MODI L/H MANISH MAHESH MODI,BHARUCH vs. ACIT CIRCLE-1, BHARUCH

In the result, ground No. VII of appeal raised by the assessee is also allowed for statistical purposes

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth(Physical Hearing) Late Mahesh Ramanlal Modi, A.C.I.T., Through L-H Manish Mahesh Modi, Circle-1, Vs. Near Shakuntal Apartment, Dahej Bharuch. Bypass Road At Nandelav, Bharuch-392001 (Gujarat) Pan No. Adfpm 4030 N Appellant/ Assessee Respondent/ Revenue

unexplained investment. The assessee filed its reply dated 20/12/2019. In the reply, the assessee submitted that in show cause notice, the difference Rs. 53,67,940/- pointed out on account of investment in immovable property. The assessee stated that they have not purchased any new immovable property nor any capital expenditure was incurred on the renovation of Bungalow. The assessee

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.No.136 & 163/Srt/2023

unexplained expenditure of Rs.15,73,1810/- against the net profit of Rs.7,23,950/- of AY 2019-20 without there being any underlying reasons or fact emerging from any material recovered during search or any fact that has been discovered by the Ld. CIT(A) and without appreciating the facts that the assessee has not submitted date-wise cash flow/fund

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.No.136 & 163/Srt/2023

unexplained expenditure of Rs.15,73,1810/- against the net profit of Rs.7,23,950/- of AY 2019-20 without there being any underlying reasons or fact emerging from any material recovered during search or any fact that has been discovered by the Ld. CIT(A) and without appreciating the facts that the assessee has not submitted date-wise cash flow/fund

THE ITO, WARD-1,, NA vs. ARIVS.SHRI ANILKUMAR AMRUTLAL CHAHWALA, NAVSARI

In the result, this ground of appeal is rejected

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.2078/Ahd/2010 िनधा"रणवष"/Assessment Year: 2006-07 आ.अ.सं./I.T.A No.1003/Ahd/2011 िनधा"रणवष"/Assessment Year: 2007-08 The Income Tax Officer, Vs. Shri Anil Kumar Amrutlal Chahwala, Ward-(1), Navsari. 102, Trimurti Complex, Vijalpore, Navsari. [Pan: Abnpc 6308 F] अपीलाथ" / Appellant ""थ"/Respondent

unexplained investment in advances. (4) On the facts and circumstances of the case and in law, the CIT(A) ought to have upheld the addition and order of assessing officer. (5) It is therefore prayed that the order of the Ld. CIT (A) be set aside and the assessing officer ‘s order be restored to the above extent 2. Brief

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.

unexplained investments. These are well recorded investments in the form of time deposit continuing from previous year. 4. In para 6 of the assessment order for the A.Yr. 2013-14 an income from interest of Rs.23,72,006 was added under the head “income from other sources". These interest incomes may be considered as income after sec 80T deductions

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

unexplained investments. These are well recorded investments in the form of time deposit continuing from previous year. 4. In para 6 of the assessment order for the A.Yr. 2013-14 an income from interest of Rs.23,72,006 was added under the head “income from other sources". These interest incomes may be considered as income after sec 80T deductions

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.No.136 & 163/Srt/2023

unexplained expenditure of Rs.15,73,1810/- against the net profit of Rs.7,23,950/- of AY 2019-20 without there being any underlying reasons or fact emerging from any material recovered during search or any fact that has been discovered by the Ld. CIT(A) and without appreciating the facts that the assessee has not submitted date-wise cash flow/fund

THE ITO-WARD-1(2),, BHARUCH vs. SHRI MOHMEDSAJID A. SAIYAD,, BHARUCH

In the result, appeal of the Revenue in ITA

Bench: Shri.Kul Bharat & Shri O.P.Meenaआ.अ.सं./I.T.A. No.857/A/2016 िनधा"रणवष"/Assessment Year : 2010-11 Income Tax Officer, Ward-1(2), Vs. Shri. Mohmedsajid A. Saiyed, Bharuch-392001 B-13, Apsara Apartment, Kasak, Bharuch-392001. [Pan: Alvps5372H] अपीलाथ" Appellant ""थ"/Respondent िनधा"रतीकीओरसे /Assessee By Shri Hemant Suthar – Ca राज"कीओरसे /Revenue By Shri B.P.K. Panda – Ld. Sr.Dr

investment. 4. The appellant craves to add to, amend or alter the above grounds as may be deemed necessary”. 3. Briefly stated facts are that assessee filed a return of income declaring total income of Rs.3,42,670/-. The case of the assessee was picked up for scrutiny and the assessment Under Section 143(3) of the Income

SHRI GIRISHBHAI R PATEL,MUMBAI vs. ITO, INTERNATIONAL TAXATION, SURAT, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shri Girishbhai R Patel, The Income Tax Officer, A-93, Pl-A, Pranek Garden, International Taxation, Vs. Panchasheel Encl. Anavil Business Centre, Dahanukarwadi Off. M.G. Road, Adajan, Surat. Mumbai Pan : Axnpp 4064 B Applicant Respondent

unexplained investment in mutual funds. 5) On the facts and in the circumstances of the case as well as law on the subject, the learned Commissioner of income Tax (Appeals) has erred in confirming the action of assessing office in not allowing deduction of TDS

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

investment in agricultural land by treating the same as unexplained cash credit u/s. 68 of the Act, 1961, without appreciating the facts that sources of the same stood explained. 6) Without prejudice to Ground No.5, both lower authorities erred in doubly taxing the amount of Rs.10,79,025/- u/s 68 of the Act. 7) Based on the facts and circumstances

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) under section 194C of the Act. As no return of income was filed in response of notice under section 148 the assessing officer proceeded for assessment. The Assessing Officer considered the entire receipt as total turnover of assessee and issued further show cause notice as to why 15% of 2 Sh.Vikram Harshadbhai Modi total receipts should not be treated

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

unexplained ITA Nos.329 & 330/SRT/2025/AYs.2015-16 investment and added the amount of Rs.70,50,000/- u/s.69 of the Act, to the total income of the assessee. 5.2 AO further noticed that even though the assessee had received the salary income and due TDS

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

unexplained ITA Nos.329 & 330/SRT/2025/AYs.2015-16 investment and added the amount of Rs.70,50,000/- u/s.69 of the Act, to the total income of the assessee. 5.2 AO further noticed that even though the assessee had received the salary income and due TDS

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,-3, SURAT vs. SHRI PANNALAL MAHENDRA KOTHARI, SURAT

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Deputy Commissioner Of Shri Pannalal Mahendra Income-Tax, Central Circle-3, Kothari, 8A, Abhishek Vs Room No.507, 5Thfloor, Apartment, S.D. Road, Ayakar Bhavan, Majura Gate, Surat Surat-395001 Pan : Aizpk 3155 F Appellant / Revenue Respondent / Assessee

unexplained investment and the cash received against the cheque. 9. On the other hand, Ld. AR for the assessee supported the order of Ld. CIT(A). Ld. AR for the assessee submits that assessee purchased the flat No.E-1102 Florence, Vasu, Surat vide sale deed dated 07.07.2015 for a sale consideration of Rs.95.17 lakhs jointly with his wife. The assessee made

ITO, WARD-3(3)(1), SURAT vs. SHRI ARVINDBHAI RATANBHAI MOKANI, SURAT

In the result, this appeal of the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) I.T.O., Arvindbhai Ratanbhai Mokani, Ward-3(3)(1), D-260-261, Vittal Nagar Society, Vs. Surat. Varachha Road, Hira Baug, Surat-395006. Pan No. Ahfpm 2302 K Appellant/ Assessee Respondent/ Revenue

unexplained and undisclosed sales consideration, the assessee explained that on the basis of AIR information, the Assessing Officer noted that the assessee sold non-agricultural land situated at Gavier village jointly with other persons at Rs. 10.00 crores, on which the assessee received Rs. 1.50 crore as his share on various dates. To verify the investment as well as sale

SHRI LALCHAND DHARIWAL,,SURAT vs. THE INCOME TAX OFFICER, WARD-1(2)(3),, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.2623/Ahd/2016 िनधा"रण वष"/Assessment Year:2012-13 Shri Lalchand P. Dhariwal, Income Tax Officer, Prop. M/S. Adinath Textile , Ward- 1(2)(3) Surat O-21-23 Bombay Market Umarwada Surat Pan: Aatpd 0682 Q अपीलाथ" Appellant ""यथ"/Respondent

unexplained investment / expenditure. 14. Succinct facts are that the AO found that the assessee has claimed expenses of Rs.1, 98, 750 towards Archana Plot No.85 of which no document evidence was submitted nor any contract confirmation was filed and nor TDS

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)

investment was unexplained therefore, assessing officer made addition of Rs.5,00,000/-. 6. The Assessing Officer also noted that assessee has received salary from Ventura Commodities Pvt. Ltd. amounting to Rs.5,46,524/-. The salary receipts were even though exceed, the minimum taxable income, assessee has not furnished the return of income, as required

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 Ranchi to make enquiries with regard unexplained creditors shown by the assessee. The inquiry report received by the AO were made part of assessment order as Exhibit – Exhibit-I and II. The AO discussed the finding of enquiry report in para No. 8.2 to 87 and summarized the conclusion in chart form in para 8.8 of his order