NAVAGAM VIBHAG SEVA SAHAKARI MANDLI LTD,NA vs. ARIVS.INCOME TAX OFFICER, WARD 3 , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

condone petition of the assessee society for filling the appeal within prescribed time and dismissed the appeal without going through merits of the case which is unjustified and bad in law. 9. In finance Act, 2006, section 80P(4) inserted to withdraw exemption U/s 80P to tax co-operative bank. There is no-amendment in finance act 2006 or then

NAVAGAM VIBHAG SEVA SAHKARI MANDLI LTD,NA vs. ARIVS.ITO, WARD-3, NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

condone petition of the assessee society for filling the appeal within prescribed time and dismissed the appeal without going through merits of the case which is unjustified and bad in law. 9. In finance Act, 2006, section 80P(4) inserted to withdraw exemption U/s 80P to tax co-operative bank. There is no-amendment in finance act 2006 or then

NAVAGAM VIBHAG SEVA SAHKARI MANDLI LTD.,NA vs. ARIVS.ITO, WARD 3 , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

condone petition of the assessee society for filling the appeal within prescribed time and dismissed the appeal without going through merits of the case which is unjustified and bad in law. 9. In finance Act, 2006, section 80P(4) inserted to withdraw exemption U/s 80P to tax co-operative bank. There is no-amendment in finance act 2006 or then

MOGAR PARTAPORE VIBHAG SEVA SAHKARI MANDLI LTD,NA vs. ARIVS.DCIT, NAVSARI CIRCLE , NAVSARI

In the result, all the appeals filed by the assessee are hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

condone petition of the assessee society for filling the appeal within prescribed time and dismissed the appeal without going through merits of the case which is unjustified and bad in law. 9. In finance Act, 2006, section 80P(4) inserted to withdraw exemption U/s 80P to tax co-operative bank. There is no-amendment in finance act 2006 or then

SHRI MODH PATNI GHANCHI GNATI PUNCH TRUST,SURAT vs. INCOME TAX OFFICER, WARD-2(3)(6), SURAT

In the result, appeal filed by the assessee is allowed for statistical purposes in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.88/Srt/2023 Assessment Year: (2016-17) (Physical Court Hearing) Shri Modh Patni Ghanchi Gnati Income Tax Officer, Punch Trust, Vs. Ward-2(3)(6), Bahulbaug, Prichhadi Road, Surat Haripura, Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabts 2898 D (अपीलाथ"/Assessee) (""थ" /Respondent)

rectification application u/s 154 of the Act before CPC, Bengaluru. An order u/s 154 of the Income Tax Act, 1961 ITA No.88/SRT/2023/AY.16-17 Shri Modh Patni Ghanchi Gnati Punch Trust was passed by DCIT (CPC) vide dated 29.08.2018 adhering to disallowance of exemption of Rs.16,21,600/- claimed u/s 11 of the Act. 10. We note that the certificate of registration

ORCHID CORP,SURAT vs. ITO, WARD 1(1)(1), SURAT

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1119/Srt/2024 Assessment Year: (2021-22) (Hybrid Hearing) Orchid Corp., Vs. Ito, F-11, Orchid Ventura, Nr. New Lp Ward - 1(1)(1), Savani School, Palanpore Canal Surat Road, Surat - 395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaffo2395F (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 31/07/2025 Date Of Pronouncement 29/10/2025

rectification u/s 154 of the Act was rejected by the Central Processing Centre (CPC) vide order dated 24.04.2023 because claim of deduction u/s 80IBA was made in the return, which was filed beyond the due date specified under sub-section (1) of section 139 of the Act. The AO – CPC, accordingly, issued demand notice of Rs.3

SHREE SUIGAM KHODADHOR PANJARA POLE,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

condone such delay. Accordingly, the Gujarat High Court directed that the order of rectification under section 154 be quashed 7.3 In the case of Jt. CIT (OSD) v. Gujarat Energy Development Agency [2023] 154 taxmann.com 348/202 ITD 733 (Ahd. - Trib.), the ITAT held that where assessee, a charitable trust, filed audit report in Form No. 10B during assessment proceedings, Assessing

SHRI LALJIBHAI KALUBHAI MIYANI,SURAT vs. INCOME TAX OFFICER, WARD 3(3)(5), SURAT

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Shri Jivrajbhai Kalubhai Miyani, I.T.O., A/31, 32 Ramdevpir Nagar, Ward 3(3)(2), Vs. Varachha Road, Varachha, Surat. Surat-395006. Pan No. Aempm 3134 P Appellant/ Assessee Respondent/ Revenue Shri Laljibhai Kalubhai Miyani, I.T.O., 83, Shirdidham Society, Hira Ward 3(3)(5), Vs. Baug, Varachha Road, Surat. Surat-395006. Pan No. Ablpp 5096 K Appellant/ Assessee Respondent/ Revenue

u/s 50C of the Act to the extent of substituting the value estimated by the DVO at Rs. 3,54,72,000/- against the actual sale consideration of Rs. 1,80,00,000/- , is liable to be struck down. 4. Your appellant further reserves his right to add, alter, modify or to amend any of the aforesaid grounds before

SHRI JIVRAJBHAI KALUBHAI MIYANI,SURAT vs. INCOME TAX OFFICER, WARD 3(3)(2), SURAT

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Shri Jivrajbhai Kalubhai Miyani, I.T.O., A/31, 32 Ramdevpir Nagar, Ward 3(3)(2), Vs. Varachha Road, Varachha, Surat. Surat-395006. Pan No. Aempm 3134 P Appellant/ Assessee Respondent/ Revenue Shri Laljibhai Kalubhai Miyani, I.T.O., 83, Shirdidham Society, Hira Ward 3(3)(5), Vs. Baug, Varachha Road, Surat. Surat-395006. Pan No. Ablpp 5096 K Appellant/ Assessee Respondent/ Revenue

u/s 50C of the Act to the extent of substituting the value estimated by the DVO at Rs. 3,54,72,000/- against the actual sale consideration of Rs. 1,80,00,000/- , is liable to be struck down. 4. Your appellant further reserves his right to add, alter, modify or to amend any of the aforesaid grounds before

JAYSHRI GOPALLAL MAHARAJSHRINI SURAT SRUSTI TRUST,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

u/s 250 r.w.s. 251 of the Act.” 5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) disallowing the claim of exemption under section 12A Jayshri Gopallal Maharajshrini Surat Srusti Trust vs. ITO (E) Asst. Year –2022-23 - 4– of the Act on account of delay in filing of Form 10B, along with

S M K R VASHI HIGH SCHOOL,NA vs. ARIVS.INCOME TAX OFFICER, EXEMPTION WARD, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपील सं./Ita No.515/Srt/2023 (िनधा"रण वष" / Assessment Year: (2021-22) (Physical Court Hearing) S.M.K.R Vashi High School Income Tax Officer-Exemption Ward, Surat, Aaykar Bhavan, Umbhrat Road Maroli Bazar, Vs. Majura Gate, Surat-395001 Jalalpore Navsari-396436 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aalfs 0980 J (अपीलाथ" /Appellant) (""थ"/Respondent)

rectification under section 154 of the Act dated 25-1-2019 is also quashed and set aside. The application for condonation of delay filed by the petitioner before the respondent is allowed.” The issue before us being identical to that as dealt with by the Hon’ble jurisdictional High Court the decision rendered therein will squarely apply to the present

SHREE HARI RAM CHARITABLE TRUST,SURAT vs. ITO EXEMPTION , SURAT

In the result, the appeal of assessee is treated as dismissed being infructuous

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Shree Hari Ram Charitable Trust, I.T.O.(Exemptions), 304, Meghdhanush Complex, Ward-Surat. Vs. Adajan Patia, Adajan Surat, Gujarat, India- 395009. Pan No. Aajts 1057 L Appellant/ Assessee Respondent/ Revenue

154 dated 05/09/2022: “ Rectification Order In this case, the assessee e-filed its return of income for A.Y. 2016- 17 on 31/03/2017 declaring total income of Rs. Nil. The said return of income was processed by the CPC, Bangalore on 12/07/2019 by assessing total income at Rs. 1,22,46,177/- and raising total demand at Rs.53

NIMESH KANUBHAI TOPIWALA - HUF,SURAT vs. DY. COMMISSIONER OF INCOME TAX CIRCLE - 1(1)(1), SURAT

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

Bench: Shri Pawan Singh(Virtual Hearing) Nimesh Kanubhai Topiwala-Huf, D.C.I.T., B-801, Shri Sarjan Palace, Nr. Nandini Circle-1(1)(1), Vs. 3, Vip Road, Vesu, Surat, Surat. Gujarat-395007. Pan No. Aahhn 1784 K Appellant/ Assessee Respondent/ Revenue

condonation of delay and if there is any delay, the appellant had filed affidavit to that effect. 6. On the facts and circumstances of the case, the e mail on which notice of hearing was issued was not under the knowledge of appellant and the appellant came to know only when notice for outstanding demand was raised

EAGLE FASHIONS PRIVATE LIMITED,SURAT vs. DCIT CIRCLE 1(1)(1), SURAT

The appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.1252/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 Eagle Fashions Private The Deputy Director Of Income Limited, 201, 2Nd Floor बनाम/ Tax, Cpc, Bengaluru Orleaans Building Current Jurisdiction: V/S. Near City Centre Deputy Cit Sosyo Circle, Magdalla Circle-1(1)(1), Surat Bharthana B.O., Surat "थायी लेखा सं./Pan: Aaace 5107 F (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Rasesh Shah, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/06/2025 घोषणा की तारीख /Date Of Pronouncement: 12/09/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Office Of The Commissioner Of Income Tax, Appeal, Addl/Jcit (A), Prayagraj [Hereinafter Referred To As ‘Ld.Cit(A)’] Dated 30/09/2024 For Assessment Year (Ay) 2011-12. The Assessee Is Aggrieved By The Action Of The Ld.Cit(A) In Dismissing The Appeal Of The Assessee Holding The Same As Time- Barred. Eagle Fashions Private Limited Vs. Dcit Asst. Year : 2011-12

154 of the Act on different dates le. 15.01.2019, 25.01.2019, 24.01.2020 and 05.02.2020. 3. The assessee pleaded in the said rectification applications that there was a clerical error at the time of carry forward of opening balance of building and furniture in Schedule 'DOA' in ITR of AY 2011-12 which led to the difference of Rs.21