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)

bogus purchases had escaped assessment within the meaning of section 147 of the Act and, therefore, recorded his satisfaction that this is a fit case for issue of notice u/s.148 of the Act. While doing so, it is categorically recorded by the Pr.CIT that he came to the conclusion on perusal the reasons recorded by the AO as well

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.

151(1) the Income Tax Act, 1961 of the Pr. CIT-3, Surat, vide letter dated 30.03.2017, the proceedings under section 147 the Income Tax Act, 1961 were initiated, and, notice u/s 148 of the Income Tax Act, 1961 was issued on 31.03.2017 and duly served upon the assessee. In response to the notice issued

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.

151(1) the Income Tax Act, 1961 of the Pr. CIT-3, Surat, vide letter dated 30.03.2017, the proceedings under section 147 the Income Tax Act, 1961 were initiated, and, notice u/s 148 of the Income Tax Act, 1961 was issued on 31.03.2017 and duly served upon the assessee. In response to the notice issued

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.

151(1) the Income Tax Act, 1961 of the Pr. CIT-3, Surat, vide letter dated 30.03.2017, the proceedings under section 147 the Income Tax Act, 1961 were initiated, and, notice u/s 148 of the Income Tax Act, 1961 was issued on 31.03.2017 and duly served upon the assessee. In response to the notice issued

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.

151(1) the Income Tax Act, 1961 of the Pr. CIT-3, Surat, vide letter dated 30.03.2017, the proceedings under section 147 the Income Tax Act, 1961 were initiated, and, notice u/s 148 of the Income Tax Act, 1961 was issued on 31.03.2017 and duly served upon the assessee. In response to the notice issued

SHRI VIRENDRA KUMAR LODHA,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(5),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

SHRI SHARAD Y. JAIN,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(4),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI GYANCHAND SUGAMCHAND JAIN,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

THE INCOME TAX OFFICER, WARD-3(3)(5),, SURAT vs. SHRI VIRENDRA KUMAR LODHA,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI ANIL GHANSHYAMBHAI KUMAWAT,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

SHRI ANIL G. KUMAWAT,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

SHRI NARESH R. PAREEK,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(3),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

SHRI ANIL G. KUMAWAT,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

SHRI GYANCHAND & JAIN,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

THE INCOME TAX OFFICER, WARD-3(3)(1),, SURAT vs. SHRI ANIL GHANSHYAMBHAI KUMAWAT,, SURAT

In the result, the appeal of the assessee for AY 2007-08 is partly allowed and the appeal of the revenue is dismissed

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

section 151 was availed by assessing officer before making reopening has substance. Therefore, we do not find any merit in the ground No. 1 of appeal by assessee. Hence, the ground No. 1 in assessee’s appeal is dismissed. 18. Ground No. 2 in assessee’s and ground No. 1 &2 in revenues appeal are interconnected relates to the additions

DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

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

bogus transaction and in such event, mere disclosure of the transaction cannot be said to be true and full disclosure and the Income-tax Officer would have jurisdiction to reopen the concluded assessment. It would be apt to quote some observations of the Apex Court in the case of Phul Chand Bajrang Lal (supra), which read as under

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

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

bogus transaction and in such event, mere disclosure of the transaction cannot be said to be true and full disclosure and the Income-tax Officer would have jurisdiction to reopen the concluded assessment. It would be apt to quote some observations of the Apex Court in the case of Phul Chand Bajrang Lal (supra), which read as under

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

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

bogus transaction and in such event, mere disclosure of the transaction cannot be said to be true and full disclosure and the Income-tax Officer would have jurisdiction to reopen the concluded assessment. It would be apt to quote some observations of the Apex Court in the case of Phul Chand Bajrang Lal (supra), which read as under