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.

bogus. In response to the notice issued by the undersigned, the assessee vide letter dated 24.07.2015 requested to treat the original return of income filed on 21.08.2008, as return of income filed in response to notice under section 148 of the Act. Notice under section 143(2) of the Act dated 15.12.2015 was issued and served upon the assessee. Notice

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.

bogus. In response to the notice issued by the undersigned, the assessee vide letter dated 24.07.2015 requested to treat the original return of income filed on 21.08.2008, as return of income filed in response to notice under section 148 of the Act. Notice under section 143(2) of the Act dated 15.12.2015 was issued and served upon the assessee. Notice

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.

bogus. In response to the notice issued by the undersigned, the assessee vide letter dated 24.07.2015 requested to treat the original return of income filed on 21.08.2008, as return of income filed in response to notice under section 148 of the Act. Notice under section 143(2) of the Act dated 15.12.2015 was issued and served upon the assessee. Notice

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.

bogus. In response to the notice issued by the undersigned, the assessee vide letter dated 24.07.2015 requested to treat the original return of income filed on 21.08.2008, as return of income filed in response to notice under section 148 of the Act. Notice under section 143(2) of the Act dated 15.12.2015 was issued and served upon the assessee. Notice

INCOME TAX OFFICER, WARD 2(3)(7), SURAT vs. SHRI ANIL PUKHRAJ JAIN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

bogus purchases, is a fresh issue, and such fresh information was not there with the assessing officer at the time of making original assessment for A.Y. 2008-09, under section 143(3) of the Act dated 24.10.2010, hence the AO was right in reopening the assessment. 19. The ld DR also stated that there is no bar to record

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

142(1) of the Act. ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. You are requested to show cause as to why the purchases during the year should not be treated as bogus accommodation entries and accordingly, as to why books of accounts should not be rejected u/s 145(3) of the Act, considering that above mentioned entries

SHRIFAL IMPEX PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

142(1) of the Act. ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. You are requested to show cause as to why the purchases during the year should not be treated as bogus accommodation entries and accordingly, as to why books of accounts should not be rejected u/s 145(3) of the Act, considering that above mentioned entries

SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

142(1) of the Act. ITA Nos. 190 - 191 &250/SRT/2023 Shrifal Impex Pvt. Ltd. You are requested to show cause as to why the purchases during the year should not be treated as bogus accommodation entries and accordingly, as to why books of accounts should not be rejected u/s 145(3) of the Act, considering that above mentioned entries

INCOME TAX OFFICER, WARD-2(3)(8), SURAT vs. MAHAVEER SHANTILAL JAIN, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.453/Srt/2019 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) The Ito, Vs. Mahaveer Shantilal Jain, Ward-2(3)(8), Prop. M/S Mukesh Diamonds, 1St Surat. Office No.401, Floor, H.No.5/1171/72/73/1090, New Dtc, Hath Falia, Haripura, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqupj6439L Appellant By Shri Ritesh Mishra, Cit(Dr) Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 08/09/2023 Date Of Pronouncement 25/09/2023

sections 143(2) and 142(1) of the Act, the assessee furnished the details / explanation before the assessing officer. 6. The assessing officer observed that during the year under consideration, the assessee was engaged in the business of Import, export, and trading in all kinds of diamonds in the name and style of his proprietary concern viz. Divya Jewels. During

DCIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

142 (1) r.w.s. 129 of the Act, was issued on 26.05.2017 and served upon the assessee and assessee was requested to attend the office of the assessing officer, on 06.06.2017. But, the assessee has not complied this notice too. Therefore, a show cause letter for non- compliance of notices and explanation for accommodation entries of bogus purchases amounting to Rs.29

ACIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

142 (1) r.w.s. 129 of the Act, was issued on 26.05.2017 and served upon the assessee and assessee was requested to attend the office of the assessing officer, on 06.06.2017. But, the assessee has not complied this notice too. Therefore, a show cause letter for non- compliance of notices and explanation for accommodation entries of bogus purchases amounting to Rs.29

SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,,SURAT vs. INCOME TAX OFFICER WARD-3(1(1), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

142 (1) r.w.s. 129 of the Act, was issued on 26.05.2017 and served upon the assessee and assessee was requested to attend the office of the assessing officer, on 06.06.2017. But, the assessee has not complied this notice too. Therefore, a show cause letter for non- compliance of notices and explanation for accommodation entries of bogus purchases amounting to Rs.29

SHRI RAVJIBHAI B DHAMELIYA,SURAT vs. DCIT, CIRCLE-2(1)(2), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

142 (1) r.w.s. 129 of the Act, was issued on 26.05.2017 and served upon the assessee and assessee was requested to attend the office of the assessing officer, on 06.06.2017. But, the assessee has not complied this notice too. Therefore, a show cause letter for non- compliance of notices and explanation for accommodation entries of bogus purchases amounting to Rs.29

MAGNIFIQUE GEMS PRIVATE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD -1(1)(4), SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.389 & 458/Srt/2023 "नधा"रण वष"/Assessment Year: (2011-12) (Physical Court Hearing) Magnifique Gems Pvt. Ltd. Income Tax Officer, Ward- 105, Rajshree Building, Maniyara 1(1)(4), Surat, Aayakar Bhawan, Sheri Na Naka,Mahidharpura, Near Majura Gate, Opp. New Surat-395003. Civil Hospital, Surat-395001

142(1) was issued to the assessee on 15.09.2018 calling certain details. In response to the notice issued to the assessee, the assessee submitted its submission before Assessing Officer. After considering the assessee’s submission on merit, the Assessing Officer disallowed bogus purchases of Rs.10,53,02,132/-. 7. Aggrieved by the order of Assessing Officer, the assessee carried

INCOME TAX OFFICER, SURAT vs. MAGNIFIQUE GEMS PRIVATE LIMITED, SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.389 & 458/Srt/2023 "नधा"रण वष"/Assessment Year: (2011-12) (Physical Court Hearing) Magnifique Gems Pvt. Ltd. Income Tax Officer, Ward- 105, Rajshree Building, Maniyara 1(1)(4), Surat, Aayakar Bhawan, Sheri Na Naka,Mahidharpura, Near Majura Gate, Opp. New Surat-395003. Civil Hospital, Surat-395001

142(1) was issued to the assessee on 15.09.2018 calling certain details. In response to the notice issued to the assessee, the assessee submitted its submission before Assessing Officer. After considering the assessee’s submission on merit, the Assessing Officer disallowed bogus purchases of Rs.10,53,02,132/-. 7. Aggrieved by the order of Assessing Officer, the assessee carried

INCOME TAX OFFICER, WARD - 2(3)(6), SURAT vs. SHRI ABHISHEK NAVNITKUMAR DOSHI, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

section 143(3) r.w.s 147 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 16.12.2019. 21 & 38/SRT/2022/AY.2012-13 Abhishek Navnitkumar Doshi 2. Grounds of appeal raised by the Revenue (in ITA No.38/SRT/2022) are as follows: “1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting

ABHISHEK NAVNITKUMAR DOSHI,SURAT vs. INCOME TAX OFFICER, WD. 2(3)(7), SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 21/Srt/2022 Assessment Year: (2012-13) (Physical Court Hearing) Abhishek Navnitkumar Doshi, Vs. The Ito, Ward-2(3)(7), 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) आयकर अपील सं./Ita No.38/Srt/2022 Assessment Year: (2012-13) The Ito, Ward-2(3)(6), Vs. Abhishek Navnitkumar Doshi, 204/205, 2Nd Floor, 6/1911-12, Surat. Jin Shanti Building, Jada Khadi, Mahidharpura – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpd0064M (Appellant) (Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 28/12/2022 09/01/2023 Date Of Pronouncement

section 143(3) r.w.s 147 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 16.12.2019. 21 & 38/SRT/2022/AY.2012-13 Abhishek Navnitkumar Doshi 2. Grounds of appeal raised by the Revenue (in ITA No.38/SRT/2022) are as follows: “1. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in restricting

LEXUS SOFTMAC,SURAT vs. DCIT, CIRCLE1(1)(1), SURAT

In the result, assessee’s appeal ITA No

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.702 & 703/Srt/2024 Ays: (2014-15 &2015-16) (Hybrid Hearing) Lexus Softmac, Deputy Commissioner Of F -3 To F-6, Gujarat Hira Bourse, Income-Tax, Circle 1(1)(1), बनाम/ Gems & Jewellery Park, Surat Room No.108, Vs. Ichchhapore, Aayakar Bhawan, Majura Surat - 394510 Gate, Opp. New Civil Hospital, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabfl 0495 P (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Deven K Kapadia, C.A. राज" की ओर से /Respondent By Shri Ajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 19/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 25/09/2025

section 250 of the Income-tax Act, 1961 (in short, ‘the Act’) both dated 20.05.2024 by the National Faceless Appeal Centre, Delhi/ Ld. Commissioner of Income Tax (Appeals) [in short, ‘CIT(A)’] for the assessment years (AYs) 2014-15 and 2015-16, which in turn arose out of separate assessment orders passed by the Assessing Officer (in short