SHRI VIJAY CHAMPAK PATEL,SURAT vs. THE INCOME TAX OFFICER, WARD-6(4), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.281/Ahd/2016 ("नधा"रणवष" / Assessment Year: 2011-12) Vijay Champak Patel, Vs. Income Tax Officer, Pachhlu Faliyu, Near Water Ward-6(4), Surat Tank, Bharthana, Vesu, Surat

capital Gain (LTCG) in the subsequent year`s Return of Income filed for A.Y. 2013-14 as per the provision of section 54F(4) of the Act. Hence, ld. Counsel submits before us that there is no mala fide intention on the part of the assessee to defraud the revenue and hence no adverse inference could be drawn that

SHRI VIJAYBHANSINGH LALLUSINGH RAJPUT,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(3)(4),, SURAT

Bench: C .M. Garg, Jm & O. P. Meena, Am आ.अ.सं./I.T.A No. 2990/Ahd/2015 िनधा"रण वष"/Assessment Year:2011-12 Vijaybhaisingh Lallusingh Rajput V. The Income Tax Officer, Plot No. 258/10-11 Near Shiv Ward-2(3)(4), Surat. Vijay Processors, Gidc, Pandesara, Surat – 394221. [Pan:Abxpr3970L] अपीलाथ" Appellant ""यथ"/Respondent िनधा"रती क" ओर से Assessee By Shri Ramesh Kumar Malapani, Ca राज"व क" ओर से Revenue By Shri R. P. Rastogi, Sr. D.R. सुनवाई क" तारीख Date Of Hearing 31.07.2018 उ"ोषणा क" तारीख Date Of 28.09.2018 Pronouncement आदेश /Order Per O. P. Meena, Am 1. This Appeal At The Instance Of The Assessee Is Directed Against An Order Dated 24.08.2015 Passed By Learned Commissioner Of Income Tax (Appeals)- 1, Surat (In Short “The Cit (A)”) For The Assessment Year 2011-12. 2. Grounds Raised By The Assessee Read As Under :

capital gains. The assessee has purchased the property for Rs. 50 Lakh and sold for Rs. 56 Lakh hence, the land value given in sale deed is fair market value. Further, the provisions of section 50C provides that where there is difference in value assessed by Stamp Duty Authorities then the matter may be referred to DVO for determining fair

SHRI PRANAV DHANIBHAI PATEL,SURAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Amarjit Singh & Shri O.P.Meenaआ.अ.सं./I.T.A No.152/Srt/2018: "नधा"रण वष"/Assessment Year: 2011-12 Shri Pranav Dhanibhai Patel, V Dcit, Central Circle-4, Surat. 2, Tirupati Society, Ajrmar Chowk, . B/H. Navyug College, Surat. [Pan: Adipp 5397 G] अपीलाथ" / Appellant ""यथ"/Respondent

capital gain has been offered as per provision of section 50C; hence, there is no positive concealment of income. It is trite law that penalty proceedings are distinct and separate proceedings from assessment proceedings. The finding recorded in the assessment order is not conclusive for deciding the imposition of penalty. It only has a persuasive value. Any finding recorded

BALUBHAI MUSTUFABHAI MAHIDA,SURAT vs. DCIT, CIRCLE-2(2), SURAT

In the result, this ground of appeal is allowed for statistical purposes

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Balubhai Mustufabhai Mahida, D.C.I.T., Post Valak, Valak Kamrej, Circle-2(2), Vs. Surat-394180 Surat. Pan No. Bkdpm 8643 R Appellant/ Assessee Respondent/ Revenue

Section 54B was disallowed. The Assessing Officer further recorded that the DVO has not given any report and the matter was getting time bared so the Assessing Officer treated the value of entire sale consideration as long term capital gain in the following manner: “(i) R.S. No. 200, 202, 176, Block No. 158

SHRI RAMESH LALJIBHAI POLRA,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2,, SURAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Bhavnesh Saini & Shri O.P.Meenaआ.अ.सं./I.T.A.No.2320 & 2290/Ahd/2016 िनधा"रणवष"/Assessment Years: 2013-14 Vs. 1. Ramesh Laljibhai Polra, 1. The Deputy Commissioner 11, Haridarshan Society, Of Income Tax, Gajera School Circle, Central Circle-2, Surat. Surat. [Pan: Adlpp 8395 D] 2. Ramesh Laljibhai Polra, 2. The Deputy 11, Haridarshan Society, Commissioner Of Income Gajera School Circle, Surat. Tax,Central Circle-2, [Pan: Adlpp 8395 D] Surat. अपीलाथ" Appellant ""यथ"/Respondent

158/- u/s.54B of the Act on account of long term capital gain on sale of agricultural land, subsequently the said amount was invested in purchase of another agricultural land. On perusal of the details, submitted by the assessee, in respect of claim of deduction u/s.54B of the Act, it is seen that all the three lands which were sold during

THE DCIT, CENTRAL CIRCLE-2,, SURAT vs. SHRI RAMESH L. POLRA,, SURAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Bhavnesh Saini & Shri O.P.Meenaआ.अ.सं./I.T.A.No.2320 & 2290/Ahd/2016 िनधा"रणवष"/Assessment Years: 2013-14 Vs. 1. Ramesh Laljibhai Polra, 1. The Deputy Commissioner 11, Haridarshan Society, Of Income Tax, Gajera School Circle, Central Circle-2, Surat. Surat. [Pan: Adlpp 8395 D] 2. Ramesh Laljibhai Polra, 2. The Deputy 11, Haridarshan Society, Commissioner Of Income Gajera School Circle, Surat. Tax,Central Circle-2, [Pan: Adlpp 8395 D] Surat. अपीलाथ" Appellant ""यथ"/Respondent

158/- u/s.54B of the Act on account of long term capital gain on sale of agricultural land, subsequently the said amount was invested in purchase of another agricultural land. On perusal of the details, submitted by the assessee, in respect of claim of deduction u/s.54B of the Act, it is seen that all the three lands which were sold during

BHADRABALA DHIMANTRAI JOSHI,SURAT vs. ACIT CIRCLE-1(3), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.126/Srt/2025 Assessment Year: 2017-18 (Hybrid Hearing) Bhadrabala Dhimantrai Joshi Assistant Commissioner Of बनाम/ 6Th Shree Nagar Society, Ghod Income-Tax, Circle-1(3), Surat, Vs. Dod Road, Surat-395 001 Anavil Business Centre, Adajan, Surat-395 007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aazpj 4561 G (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri P.M. Jagasheth, Ca राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 04/08/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 20.01.2025 By The National Faceless Appeal Centre, (Nfac), Delhi /Commissioner Of Income-Tax (Appeals) [In Short, The ‘Cit(A)’] For The Assessment Year (Ay) 2017- 18, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S. 143(3) Of The Act On 03.12.2019. 2. Grounds Of Appeal Raised By The Assessee For The Appeal Are As Under: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Action Of The Assessing Officer In Making Addition Of Rs.1,21,92,898/- On Account Of Alleged Disallowing Immunity Claimed U/S.2(14) Of Income-Tax Act, 1961 By Treating Again As Business Income, Which Ground Has Never Been Conveyed And/Or Initiated To Respond & Revealed Through Assessment Order Only. As No Opportunity Is Afforded Either Through Any Notice And/Or More

section 2(14)(iii) of the Act for being treated as agricultural land and exempted from ITA No.126/Srt/2025 A.Y 17-18 Bhadrabala D Joshi capital asset. In view of these facts, the CIT(A) held that lands sold by the assessee was not eligible for exemption u/s 2(14)(iii) of the Act and accordingly, the addition of Rs.1

SHRI SALAHUDDIN H. BAIG,,BHARUCH vs. THE ACIT, BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

158 (SC) and Hon’ble Rajasthan High Court decision in case of Chandra Pal Bagga vs ITAT 261 ITR 67 (Raj) for the proposition that mere denial of a legal claim cannot be held as furnishing inaccurate particulars of income. It was accordingly submitted that the penalty order so passed by the AO u/s 271(1)(c) is not sustainable

M/S. MITSU PRIVATE LIMITED,,VAPI vs. THE ACIT, VAPI CIRCLE,, VAPI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

gains of business or, profession", which incorporates the entire procedure for computing the business income under s. 28 to 44 of the Act. De hor s. 80HHC of the Act. the consistent approach is that where the statutory provision talks of "income derived from" the business activity in question, the nexus theory should be applied in order to determine whether

THE ASSTT. COMMISSIONER OF INCOME TAX, VAPI CIRCLE,, VAPI vs. M/S. MITSU LIMITED,, DAMAN

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

gains of business or, profession", which incorporates the entire procedure for computing the business income under s. 28 to 44 of the Act. De hor s. 80HHC of the Act. the consistent approach is that where the statutory provision talks of "income derived from" the business activity in question, the nexus theory should be applied in order to determine whether

SIDDHI VINAYAK KNOTS & PRINTS PRIVATE LIMITED,SURAT vs. PR. CIT-2, SURAT, SURAT

In the result, the appeal filed by the assessee is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.58/Srt/2022 "नधा"रणवष"/Assessment Year: (2017-18) (Physical Court Hearing) Siddhi Vinayak Knots & Prints Pvt. Ltd. Vs. The Pcit-2, A-26, Central Park, Gidc, Pandesara Surat. S.O., Pandesara, Surat-394221. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aamcs4421L

capital receipt had been concluded against the revenue. The satisfaction of the Commissioner, therefore, was based on no material, either legal or factual, which would have given him the jurisdiction to take action under section 263.” 17. In view of the above submission, your honours are requested to quash the revision order passed

INCOME TAX OFFICER, WARD-1(2)(1), SURAT, SURAT vs. DEEPESH VISHNU AGARWAL, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.833/Srt/2024

capital gains out of sale of scrip of Kushal Ltd. nor that the aforementioned stock/scrip was not a penny stock. Hence, the AO treated the amount transacted of Rs.84,32,905/- as unexplained investment u/s.69 r.w.s.115BBE of the Act. Further, the AO added an amount of Rs.2,52,987/- (3% of Rs.84,32,905/-) on account of commission paid

M/S. SHANGRILA LATEX INDUSTRIES LIMITED,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX - 4, SURAT

In the result, appeal filed by the assessees is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.38/Srt/2017 Assessment Year: (2006-07) (Physical Court Hearing) Shangrila Latex Industries Limited, Vs. The Acit, Circle-4, C/O. B.M. Parekh & Co., 203, 2Nd Surat. Floor, Navjivan Society, Bldg. No. 03, Lamington Road, Mumbai-400008. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaics1479E (Appellant) (Respondent) Assessee By Shri Sanjay S. Kapadia, Ca Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 01/07/2022 28/09/2022 Date Of Pronouncement

capital receipt which is not taxable in the eye of law. 13. In respect of ground No. 2 and 3, the ld. Counsel then argued that Assessing Officer also erred in not allowing the set off, of carry forward of depreciation to the tune of Rs.1,20,54,688/-. Apart from this, Assessing Officer also denied

MANOJJ GANESHLAL BHATIA, SURAT vs. ACIT, CIR 1(3), SURAT

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.494/Srt/2019 ("नधा"रणवष" / Assessment Years: (2015-16) (Virtual Court Hearing) Assistant Commissioner Of Manojj Ganeshlal Bhatia Income-Tax, Circle-1[3], Room B-703, Opera House Building, Vs. 3Rd No.301, Floor, Anavil Nr. Agarsen Bhavan, City Light Business Centre, Adajan-Hazira Road, Surat-395007 Road, Adajan, Surat-395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacpb 9748 E (अपीलाथ" /Assessee) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By : Shri Mehul K.Patel, Advocate राज" की ओर से/Revenue By : Shri Ashok B. Koli, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing : 21/03/2023 घोषणा क" तार"ख/Date Of Pronouncement : 16/06/2023 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year (Ay) 2015-16, Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (Appeals)-2, Surat [Ld. Cit(A) For Short] Dated 28.08.2019 Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”] Dated 29.12.2017. 2. Grounds Of Appeal Raised By The Revenue Are As Follows: “1) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.3,97,77,965/- Made On Account Of Profit From Future & Options Ignoring That Assessee Has Failed To Tender Evidence & Explanation In This Regard? 2) Whether On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Is Justified In Deleting The Addition Of Rs.5,60,54,528/- Made On Account Of Unexplained Increase In Capital Holding That The Capital Accumulation Is Fully Explained On The Basis Of Capital In The Itr Of A.Y 2011-12 & Accumulated Income In The Roi For A.Y 2012-13 To A.Y 2014-15 Ignoring That Assessee Has Shown Nil Capital Balance In Itr Filed For A.Y 2014-15?

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”] dated 29.12.2017. 2. Grounds of appeal raised by the Revenue are as follows: “1) Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is justified in deleting the addition of Rs.3,97,77,965/- made on account

SHRI VIJAYSING P. SOLANKI,SURAT vs. THE DY. COMM. OF INCOME TAX, CIRCLE -3(1), SURAT

In the result, the appeals filed by the assessees (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.697 & 698/Srt/2018 ("नधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing)

capital gain (LTCG). The assessee contended before assessing officer that there was no willful incorrect claim under section 54B of the Act. 10. We note that during the year under consideration the assessee has sold a plot of land in respect of which deduction u/s 54B of the Act has been claimed. During the ITA 697 & 698/SRT/2018 Assessment Year

MAYUR MATHURDAS PATEL,SURAT vs. ITO WARD 1(3)(7), SURAT

In the result, the appeals filed by the assessees (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.697 & 698/Srt/2018 ("नधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing)

capital gain (LTCG). The assessee contended before assessing officer that there was no willful incorrect claim under section 54B of the Act. 10. We note that during the year under consideration the assessee has sold a plot of land in respect of which deduction u/s 54B of the Act has been claimed. During the ITA 697 & 698/SRT/2018 Assessment Year

BAYER VAPI PVT. LTD., (FORMERLY KNOWN AS BILAG INDUSTRIES PVT.LTD.,),VAPI vs. THE A CIT., VAPI CIRCLE,, VAPI

In the result, appeal of the assessee for A

Bench: Shri H.S.Sidhu & Shri O.P.Meenaआ.अ.सं./I.T.A. No.1688/Ahd/2014 िनधा"रण वष"/Assessment Year : 2005-06 Bayer Vapi Private Limited, Vs. The Assistant Commissioner Of (Formerly Known As Bilag Industries Income Tax, Private Limited), Plot No.306/3, Vapi Circle, Vapi. Phase-Ii, Vapi – 396 195, Gujarat. [Pan: Aabcb 2100 L] अपीलाथ" Appellant ""यथ"/Respondent िनधा"रती क" ओर से /Assessee By Shri Mehul K Patel, Advocate & Shri A. Gopalakrishnan, Ca Shri Prasenjit Singh – Cit(Dr) राज"व क" ओर से /Revenue By 18.07.2019 सुनवाई की तारीख/ Date Of Hearing: उ"ोषणा क" तारीख/Pronouncement On: 27.08.2019 आदेश /O R D E R Per O.P.Meena, Am: This Appeal Filed By The Assessee Is Directed Against The 1. Order Of Learned Commissioner Of Income Tax(Appeals)- Valsad, Valsad(In Short “The Cit(A)”) Dated 31.03.2014 Pertaining To Assessment Year 2005-06. The Grounds Raised By The Assessee In Ita 2. No.1688/Ahd/2014 Read As Under : “01. The Appellant Company Has Neither Concealed Its Income Nor Submitted Any Inaccurate Particulars Of Income & The Adjustments/ Additions Of The Learned Commissioner Of Income Tax (Appeals) Is Contrary To The Facts Of The Case & Law & Deserves To Be Deleted. 02. On Appreciation Of The Facts & Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeals) Has Erred In Bayer Vapi Pvt. Ltd.,(Formerly Known As Bilag Industries Pvt. Ltd., Vs.Acit-Vapi/Ita No.1688/Ahd/2014: A.Y.2005-06 Page 2 Of 20

gains or not. The sale of the business was upheld as genuine business transaction. However, the AO has never doubted the genuineness of the slump sale but raised the issue of valuation and payment made towards the purchase of intangible assets in form of manufacturing and process know-how etc., Therefore, the assessee has not justified as how the assets

THE ITO, WARD-1,, BARDOLI vs. M/S. GIRIRAJ DEVELOPERS,, SURAT

In the result, all the Seven Appeals of various assessee’s as listed

Bench: Smt. Diva Singh & Shri O.P.Meena

capital gain, which was assessed by AO as business income, it cannot amount to furnishing of inaccurate particulars for purpose of levy of penalty u/s.271 (1)(c). 2) The Hon'ble Mumbai Bench of the ITAT in the case of ITO Vs. Roborant Investments (P) Ltd. (2006) 7 SOT 181 (Mumbai) has held that the assessee having made full

THE ITO, WARD-2(3)(1),, SURAT vs. M/S. AASTHA ECO HOMES,, SURAT

In the result, all the Four Appeals of various assessee’s as listed

Bench: Smt. Diva Singh & Shri O.P.Meenas. आ.अ.सं./I.T.A अपीलाथ" Appellant Vs ""यथ"/Respondent No . No. & िनधा"रण वष" /A Y:

capital gain, which was assessed by AO as business income, it cannot amount to furnishing of inaccurate particulars for purpose of levy of penalty u/s.271 (1)(c). 2) The Hon'ble Mumbai Bench of the ITAT in the case of ITO Vs. Roborant Investments (P) Ltd. (2006) 7 SOT 181 (Mumbai) has held that the assessee having made full