ENGINEERING PROFESSIONAL CO. PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.541/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Engineering Professional Co. Pvt. Ltd., Vs. The Pcit -1, 444, Royal Arcade, Opp. Sarthana Zoo, Surat Varachha Road, Near Sarthana Jakatnaka, Surat – 395006, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabce0313Q (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ravi Kant Gupta, Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 19/02/2025

capital gain was paid on it. It was also submitted that the difference between the value of Stamp Duty Authority (SVA) and actual sale consideration is less than 10%. Hence, no addition can be made u/s 50C(1) of the Act. It was also submitted that all details were given to AO, who has duly examined the same

RUCHIT DINESHBHAI DOSHI,SURAT vs. INCOME TAX OFFICER WARD - 2(2)(1), SURAT

In the result, grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh(Physical Hearing) Ruchit Dineshbhai Doshi, I.T.O., C-10, 5/6, Somakanji Estate-2, Opp- Ward-2(2)(1), Vs. Sanidev Mandir, Magdalla Bo, Surat. Surat-395007 (Gujarat) Pan No. Afxpd 4008 F Appellant/ Assessee Respondent/ Revenue

capital gain was based on detailed enquiry of Investigation Wing and the assessee has accepted the addition, thus he satisfied that the levy of penalty by Assessing Officer was justified. Further aggrieved, the assessee has filed present appeal before this Tribunal. 6. I have heard the rival submissions of the learned Authorised Representative (ld. AR) of the assessee

SHRI SUNNY CHADRAKANT FUDHANAWALA,,SURAT vs. THE DY. COMMISSIONER INCOME TAX OFFICER, CIR3(3), SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपीलसं./Ita No.271/Srt/2019 ("नधा"रण वष" / Assessment Year: (2014-15) (Virtual Court Hearing) Shri Sunny Chandrakant Deputy Commissioner Of Fudhnawala, 47, Matawadi, Income Tax, Circle-3(3), Vs. Nr. Bhavani Mata Mandir, Aaykar Bhavan, Majura Gate Lambe Hanuman Road, Nr. New Civil Hospital Road, Surat-395006 Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpf 6359 G (Appellant) (Respondent) "नधा"रती क" ओर से /Assessee By : Shri Manish J Shah, Advocate राज"व क" ओर से /Respondent By : Shri Ashok B. Koli, Cit-D.R

gain has been offered by the assessee therefore exemption u/s 54F of the Act, on the same property, should be allowed, as it has already been allowed in case of co-owner. The assessment has been made u/s 143(1) of the Act in case of co-owner of such land. Therefore, assessee should not be treated differently

NEELU MAHANSARIA,SURAT vs. INCOME TAX OFFICER, WARD - 1(3)(3), SURAT

In the result, the addition of undisclosed income under section 68 is deleted

Bench: Shri Pawan Singhआ.अ.सं./Ita No.197/Srt/2023 (Ay 2011-12) (Hearing In Physical Court) Neelu Mahansaria Income Tax Officer, 304, Green Park Apartment, Ward-1(3)(3), Surat Vs City Light Road, Nr. Corner Point Complex, Surat-395007 Pan No: Adbpm 2707 Q अपीलाथ"/Appellant ""थ" /Respondent

capital gains earned by assessee is fully explained. The assessee has no nexus with the company directly or indirectly nor managing affairs with such company. The transactions were conducted through BSE and assessee claimed that her transactions were genuine. Merely because the probe was done by SEBI against the broker or against the company, the assessee cannot be claimed

M/S. MAC INDUSTRIES,,VALSAD vs. THE INCOME TAX OFFICER, WARD- 6,, VAPI

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.1036/Ahd/2016 ("नधा"रणवष" / Assessment Year: (2009-10) M/S. Mac Industries, Vs. Income Tax Officer, Plot No.1, 2407/2, Gidc, Sarigam, Ward-6, Vapi. Ta- Umbergaon, Valsad-396230. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefm2011M (Assessee) (Respondent) Assessee By : Shri Hardik Vora - Ar Respondent By : Ms Anupama Singhla – Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 22/09/2020 घोषणाक"तार"ख/Date Of Pronouncement : 19/10/2020 आदेश / O R D E R Per Dr. A. L. Saini:

capital gains’, and ‘Income from other sources’ will not be part of book profit. Therefore, the excess payment of remuneration of Rs.2,24,247/- was added back to the total income of the assessee. 6. Aggrieved by the order of the Assessing Officer (AO), the assessee carried the matter in appeal before the ld. CIT(A) who has confirmed

SANJAYBHAI ARJUNBHAI PATEL,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, SURAT

gain on\nfluctuation in price/ value. Thus, the assessee earned income from referral,\ninterest income from lending of coins and from staking. DKD cons were operated\nin pseudonymous ownership without any physical address. It functioned as\nscheme with lending and escrows. All such details were found from the personal\nLaptop of assessee \"Snjay_hp_laptop_320_gb-“, which was seized

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, SURAT vs. SHRI SANJAYBHAI ARJUNBHAI PATEL, SURAT

In the result, the appeal of the revenue is dismissed and the cross appeal of\nthe assessee is partly allowed

gain on\nfluctuation in price/ value. Thus, the assessee earned income from referral,\ninterest income from lending of coins and from staking. DKD cons were operated\nin pseudonymous ownership without any physical address. It functioned as\nscheme with lending and escrows. All such details were found from the personal\nLaptop of assessee \"Snjay_hp_laptop_320_gb\", which was seized

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

gain or loss should not be considered in isolation but at a composite transaction since the assessee might have purchased and sold in cash segment or other F&O segments. The appellant had traded in 1,21,87,20,095 units resulting in total volume of Rs.22,385.04 Crore and the volume from few trades

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

gain or loss should not be considered in isolation but at a composite transaction since the assessee might have purchased and sold in cash segment or other F&O segments. The appellant had traded in 1,21,87,20,095 units resulting in total volume of Rs.22,385.04 Crore and the volume from few trades