M/S. PATEL AMBALAL HARGOVANDAS & CO.,,SURAT vs. THE DCIT, CENTRAL CIRCLE-2,, SURAT

In the results, appeal filed by Revenue (in IT(SS)A Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं/.It(Ss)A No.49/Srt/2022 Assessment Year: (2019-20) (Physical Hearing) The Acit, Central Circle-2, Vs. Rasikbhai Narottamdas Patel, Surat. Flat No.9-10, Mahavir Nagar Co.Op H.S. Ltd., Bldg-12, Nr. Gayatri Mandir, Udhna Magdalla Road, Surat – 395007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Adgpp4550M (Appellant) (Respondent) आयकर अपील सं/.It(Ss)A No.86/Srt/2022 Assessment Year: (2015-16) The Dcit, Central Circle-2, Vs. Ashish Karamshibhai Koshiya, Surat. 40, Jivandeep Soceity, Singanpor Road, Katargam, Surat, Gujarat – 395004. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aojpk1118G (Appellant) (Respondent) आयकर अपील सं/.Ita No.185/Srt/2022 Assessment Year: (2020-21) M/S. Patel Ambalal Hargovandas Vs. The Dcit, Central Circle-2 & Co., Surat. 5/725, Haripura, Bhavaniwad, Opp. Dhobi Sheri, Surat – 395003. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aadfp2517N (Appellant) (Respondent) Appellant By Shri Ashok B. Koli, Cit(Dr) Shri Vartik Choksi, Shri Biren Shah & Shri Respondent By Nitin Gheewala, Ar Date Of Hearing 26/04/2023 Date Of Pronouncement 26/05/2023 आदेश /O R D E R Per Bench:

Section 292C(1) of the Act. [ii] On the facts and in the circumstances of the case and in law, the Ld.CIT(A) has erred in deleting the protective addition made by the Assessing Officer of Rs.10,74,15,724/- on account of unaccounted income under Sec.69A of the Act by observing that the Assessing Officer was not able

ASSISTANT COMMISSIONER OF INCOME TAX, VALSAD CIRCLE, VALSAD vs. M/S. MANGALDEEP, VALSAD

In the result, appeals in ITA No

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.699/Srt/2018 ("नधा"रणवष" / Assessment Years: (2015-16) (Virtual Court Hearing) The Acit, Valsad Circle, Vs. M/S. Mangaldeep, 1St Floor, Shankeshwar Complex, Valsad. Dhobiwad, Valsad, Valsad-396001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfm7130L (Appellant) (Respondent) Cross Objection No.11/Srt/2021 [Arising In Ita No.699/Srt/2018] ("नधा"रणवष" / Assessment Years: (2015-16) (Virtual Court Hearing) M/S. Mangaldeep, Vs. The Acit, Valsad Circle, 1St Floor, Shankeshwar Complex, Valsad. Dhobiwad, Valsad, Valsad-396001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfm7130L (Applicant-Co-Objector) (Respondent)

gains of business or profession. The assessee`s case was selected for scrutiny and notice u/s 143(2) of the Act was issued on 16/08/2016.In assessee`s case a survey u/s 133A of the Act was conducted on 15.10.2014. During the course of survey proceedings, certain incriminating material was found and discrepancies were noticed. To seek clarification/explanation on these incriminating

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

69A of Income Tax Act on account of cash deposit in Bank Account. 2. On the facts and in the circumstances of the case, and in law, the learned Commissioner of Income Tax (Appeals) as well as learned Assessing Officer have erred in not allowing deduction of housing loan interest of Rs.2,00,000/- as per section 24 of Income

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

69A of Income Tax Act on account of cash deposit in Bank Account. 2. On the facts and in the circumstances of the case, and in law, the learned Commissioner of Income Tax (Appeals) as well as learned Assessing Officer have erred in not allowing deduction of housing loan interest of Rs.2,00,000/- as per section 24 of Income

INCOME TAX OFFICER, WARD- 2(3)(1), SURAT vs. HITESH B PONKIA HUF, SURAT

In the result, the appeal of the revenue is dismissed

69A of the Act in the disguise of exempted long term capital gains on\naccount of sale of the share of JRI Industries and Infrastructure Limited, a penny\nstock and without appreciating the findings of the Assessing Officer that the price\nmovement of the company were not supported by financial fundamentals of the\ncompany?\n(ii) On the facts

INCOME TAX OFFICER 331, MAJURA GATE SURAT vs. SHARDABEN GORDHANBHAI ASODARIA, SURAT

In the result, the appeal of the revenue is dismissed

69A of the Act in the disguise of exempted long term capital gains on\naccount of sale of the share of JRI Industries and Infrastructure Limited, a penny\nstock and without appreciating the findings of the Assessing Officer that the price\nmovement of the company were not supported by financial fundamentals of the\ncompany?\n(ii) On the facts

SHRI RAJNIKANT THAKARBHAI PATEL, ,DAMAN vs. ITO DAMAN WARD, DAMAN, DAMAN

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

Bench: Shri Pawan Singhआ.अ.सं./Ita Nos.182 & 183/Srt/2019 (Ay 2009-10) (Hearing In Virtual Court) Shri Jayesh Thakorbhai Patel House No.96/1, Dabhel Income Tax Officer Kumbhar Faliya, Dabhel, Nani Daman Ward, Daman Daman-396210 Jivanji Hotel Building, Vs Pan : Avwpp 3568 M Devka Road, Kathiria, Nani Daman-396210 Shri Rajnikanta Thakorbhai Patel, House No.96/1, Dabhel Kumbhar Faliya, Dabhel, Nani Daman-396210 Pan : Amjpp 2914 M अपीलाथ"/Appellant ""यथ" /Respondent

capital gain. 6. On the facts and in the circumstances of the case as well as law on the subject, the learned commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in initiating penalty proceedings u/s 271(1)(c) of the Income Tax Act, 1961. 7. On the facts and in the circumstances

SHRI JAYESH THAKARHAI PATEL,DAMAN vs. ITO ,DAMAN WARD,, DAMAN

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

Bench: Shri Pawan Singhआ.अ.सं./Ita Nos.182 & 183/Srt/2019 (Ay 2009-10) (Hearing In Virtual Court) Shri Jayesh Thakorbhai Patel House No.96/1, Dabhel Income Tax Officer Kumbhar Faliya, Dabhel, Nani Daman Ward, Daman Daman-396210 Jivanji Hotel Building, Vs Pan : Avwpp 3568 M Devka Road, Kathiria, Nani Daman-396210 Shri Rajnikanta Thakorbhai Patel, House No.96/1, Dabhel Kumbhar Faliya, Dabhel, Nani Daman-396210 Pan : Amjpp 2914 M अपीलाथ"/Appellant ""यथ" /Respondent

capital gain. 6. On the facts and in the circumstances of the case as well as law on the subject, the learned commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in initiating penalty proceedings u/s 271(1)(c) of the Income Tax Act, 1961. 7. On the facts and in the circumstances

ARCHANA PRANAV DESAI,VALSAD vs. ITO, WARD-1, VAPI

In the result, appeal filed by the assessees is partly allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.557/Srt/2019 Assessment Year: (2010-11) (Physical Court Hearing) Pranav Dolatrai Desai, Vs. The Ito, Ward-7, Desai Bunglow, Gautam Colony, Vapi. Balakhadi, Killa Pardi, Valsad-396125. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Airpd2160R (Appellant) (Respondent) आयकर अपील सं./Ita No.558/Srt/2019 Assessment Year: (2010-11) (Physical Court Hearing) Archana Pranav Desai, Vs. The Ito, Ward-7, Pranav Bunglos, Gautam Colony, Vapi. Balakhadi, Killa Pardi, Valsad-396125. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Airpd2161Q (Appellant ) (Respondent) Assessee By Shri Suresh K. Kabra, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 30/06/2022 Date Of Pronouncement 24/08/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By Different Assessees, Pertaining To The Assessment Years (Ay) 2010-11, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Valsad [In Short “The Ld. Cit(A)”], Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer U/S 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

section 148 of the Act, the assessee filed letter of authority and also filed return of income (ROI), declaring income of Rs.1,39,530/-, after claiming deduction of Rs.1,00,000/- under Chapter VI-A of the Act. In view of the return filed by the assessee, reasons recorded for reopening of the assessment were provided to assessee, vide letter

PRANAV D. DESAI,SURAT vs. ITO VAPI WARD, 7 VAPI, VAPI

In the result, appeal filed by the assessees is partly allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.557/Srt/2019 Assessment Year: (2010-11) (Physical Court Hearing) Pranav Dolatrai Desai, Vs. The Ito, Ward-7, Desai Bunglow, Gautam Colony, Vapi. Balakhadi, Killa Pardi, Valsad-396125. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Airpd2160R (Appellant) (Respondent) आयकर अपील सं./Ita No.558/Srt/2019 Assessment Year: (2010-11) (Physical Court Hearing) Archana Pranav Desai, Vs. The Ito, Ward-7, Pranav Bunglos, Gautam Colony, Vapi. Balakhadi, Killa Pardi, Valsad-396125. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Airpd2161Q (Appellant ) (Respondent) Assessee By Shri Suresh K. Kabra, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 30/06/2022 Date Of Pronouncement 24/08/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: Captioned Two Appeals Filed By Different Assessees, Pertaining To The Assessment Years (Ay) 2010-11, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Valsad [In Short “The Ld. Cit(A)”], Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer U/S 143(3) R.W.S 147 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

section 148 of the Act, the assessee filed letter of authority and also filed return of income (ROI), declaring income of Rs.1,39,530/-, after claiming deduction of Rs.1,00,000/- under Chapter VI-A of the Act. In view of the return filed by the assessee, reasons recorded for reopening of the assessment were provided to assessee, vide letter

THE DCIT, CIRCLE-3,, SURAT vs. M/S. SHYAM CORPORATION, SURAT

In the result, revenue’s appeal is dismissed

Bench: Shri Amarjit Singh & Ms. Madhumita Roydcit, Vs. M/S. Shyam Corporation, Circle - 3, “Silver Crest”, F.P. No.67 & Surat 70, T.P.S. No.14(Pal), Pal, Surat -395 005. [Pan No. Abefs 9360 G] (Appellant) .. (Respondent)

69A, 69B and 69C being treated separately, since it is not the income from salary, house property, profit and gains of the business or profession or capital gains nor the income from other sources became the provision of Section

SHRI ASHISH NATVARLAL VASHI,,NA vs. ARIVS.THE INCOME TAX OFFICER, WARD-1,, NAVSARI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.3522/Ahd/2016 ("नधा"रणवष" / Assessment Years: (2007-08) (Virtual Court Hearing) Ashish Natvarlal Vashi, Vs. The Income Tax Officer, Ward-1, Tolat Falia, At & Post. Kaccholi, Navsari. Taluka Gandevi, Dist: Navsari, Navsari - 396370. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abypv5202C (Assessee) (Respondent)

69A of the Act. 2. It is therefore prayed that above addition made by Assessing Officer and confirmed by CIT(A) may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” Assessment Years.2007-08 Ashish Natvarlal Vashi 2. Assessee has also raised additional grounds

BHARATSINH KISHORSINH MEDHAT,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2), SURAT

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Bench: Ld. Cit(A). The Appellate Commissioner Confirmed Both The Additions, Since The Assessee Failed To Produce Substantial Details In Support Of Its Claim.

capital gain on sale of land 3) The ld CIT(A) has erred in law and on facts in not adjudicating the substituted ground no 2 pertaining to the prayer to adopt the average rate of Rs. 137 per Sq Meter as on 01/04/1981 as cost of acquisition of land. 4) The ld. CIT(A) has erred

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-2,, SURAT vs. SHRI RAMESHBHAI RAGHAVBHAI BHADANI, SURAT

In the result, summarized and concise ground No

Bench: Shri Pawan Singh, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./It(Ss)A Nos.25 &31/Srt/2021 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Deputy Commissioner Of Rameshbhai Raghavbhai Bhadani, Prop. Of M/S Rangeela Fashion, 14, Income-Tax, Central Circle-2, Room No. 505, 5Th Floor, Nirman Industrial Estate, A.K. Road, Fulpada, Surat Aaykar Bhawan, Majura Gate, Vs. Surat-395001. Deputy Commissioner Of Income- Rameshbai Raghavhai Bhadani Plot No.14-16, Nirman Tax, Central Circle-2, Room No.505, 5Th Floor, Aaykar Bhawan, Majura Industrial Estate, A./K. Road, Surat-395008 Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.45/Srt/2021 ("नधा"रणवष" / Assessment Year: (2014-15) Deputy Commissioner Of Shri Rameshbhai Raghavbhai Income-Tax, Circle-3, Room No. Bhadani, Prop. Of M/S Rangeela Vs. 505, 5Th Floor, Aaykar Bhawan, Fashion, 14, Nirman Industrial Majura Gate, Surat-395001. Estate, A.K. Road, Fulpada, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent)

gain on sale of land. (c) Ground No.3 of IT(SS) No.25/SRT/21, for A.Y. 2013-14. Addition of Rs.1,00,00,000/- on account of unaccounted investment. (d). Ground No.2 of IT(SS) No.45/SRT/21, for A.Y.2014-15, addition of Rs.1,84,28,500/- on account of unexplained investments. (e) Ground No.3 of IT(SS) No.45/SRT/21, for A.Y.2014-15, addition of Rs.50

SHRI DHAVAL RAJKUMAR JAIN,DAMAN vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singhआ.अ.सं./Ita No.416/Srt/2023 (Ay 2011-12) (Hearing In Virtual Court) Shri Dhaval Rajkumar Jain Income Tax Officer, Plot No.12, “Mahvir” Airport Ward-Daman, Hotel Vs Road, Naii Daman, Daman- Diwanji Building, 396210 Devkanand, Daman- Pan No: Aedpj 9192 B 396210 अपीलाथ"/Appellant ""थ" /Respondent

69A being appellant’s investment in plot no.21 and 22 of survey no 261/1 located at Keshar Industrial Estate, Village-Bhimpor, Daman Sh. Dhaval R. Jain ignoring the fact that the said plots were purchased in A.Y 2009-10 and entire investment is disclosed in books of account. 2. Ld. CIT[A], NFAC, DELHI has erred

HOTEL ROYAL GARDEN,,DAMAN AND DIU (UT) vs. THE PCIT, VALSAD, VALSAD

In the result, appeal filed by assessee is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.103/Srt/2022 Assessment Year: (2017-18) (Physical Court Hearing) Hotel Royal Garden, Vs. The Pcit, Valsad. Main Road, Dabhel, Nani Daman – 396210, Daman & Diu (Ut). "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefh2587H (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca With Jayraj M. Naik, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) Date Of Hearing 05/01/2023 Date Of Pronouncement 21/03/2023

69A,69B,69C of the Income Tax Act. The assessee has also given a plethora of cases without verifying whether the facts of the case are similar to the facts of the case of the assessee. In the present case the assessee was duty-bound to come out with full particulars which it has not done. In fact

INCOME TAX OFFICER, SURAT vs. ILESH B PONKIA, SURAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

69A of the Act in the disguise of exempted long term capital gains on account of sale of the share of JRI Industries and Infrastructure Limited, a penny stock and without appreciating the findings of the Assessing Officer that the price movement of the company were not supported by financial fundamentals of the company? ii. On the facts and circumstances

ARVINDBHAI RATILAL SHAH T L/H KOKILABEN ARVINDBHAI SHAH,SURAT vs. ITO, WARD 2(3) (6), SURAT

In the result, the appeal of the assessee is dismissed

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Arvindbhai Ratilal Shah, T L/H Ito Ward 2(3)(6), Kokilaben Arvindbhai Shah, Income Tax Office, Room 405, C/O Sun Gems, 203 Syndicate Vs. Anavil Business Centre, Pal- House, Gujjar Falia Haripura, Hazira Road, Adajan, Surat-395003. Surat-394270. Pan No. Actps 6533 K Appellant Respondent

capital gains on equity shares, dividend, commission income, and interest. The return so filed was processed under section 143(1) of the Income-tax Act, 1961. Subsequently, the case was selected for scrutiny assessment. 2.1. During the course of assessment proceedings, the Assessing Officer observed that the assessee had deposited cash in various bank accounts during the period of demonetisation