SACHIN NOTIFIED AREA,SURAT vs. PR. COMMISSIONER OF INCOME TAX , SURAT - 1, SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.343/Srt/2022 "नधा"रण वष"/Assessment Year: (2017-18) (Physical Hearing) Sachin Notified Area, Vs. The Pcit, Surat-1 Plot No.5719, Unnati Building, Sachin Gidc, Sachin, Surat-394230. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaals0146H Shri P. M. Jagasheth, Ca Appellant By Shri Ravinder Sindhu, Cit(Dr) Respondent By Date Of Hearing 31/05/2023 Date Of Pronouncement 26/06/2023

condone the delay and admit the appeal for hearing. 4. Succinctly, the factual panorama of the case is that assessee before us is deemed Municipality working in the name and style as ‘Sachin Notified Area’. The assessee had filed its return of income for assessment year (A.Y.) 2017-18 on 24/03/2018, declaring total income NIL, after claiming deduction of Rs.13

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT CHEMICAL PORT TERMINAL CO.LTD.,, BHARUCH

In the result, Cross Objection appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.1501/Ahd/2014 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Gujarat Chemical Port Terminal V The Commissioner Of Income Tax, Vadodara. Company Ltd., S Po Lakhigam, Via Dahej, . Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2998/Ahd/2014 "नधा"रण वष"/Assessment Year: 2010-11 The Deputy Commissioner Of Income V M/S.Gujarat Chemical Port Tax, Circle-1(1), Baroda. S Terminal Company Ltd., . Po Lakhigam, Via Dahej, Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent Cross Objection No.30/Ahd/2015 (Arising Out Of Ita No.2998/Ahd/2014) "नधा"रण वष"/Assessment Year: 2010-11 M/S.Gujarat Chemical Port Vs. The Deputy Commissioner Of Terminal Company Ltd., Income Tax, Circle-1(1), Po Lakhigam, Via Dahej, Baroda. Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent

263 itself is not maintainable, therefore there is no need to deal with the other issues. 10. In the result net result, appeal is allowed.” 10. And also in CIT vs. Roadmaster Industries of India Ltd., it is held as “A revisional order can be passed only after giving an opportunity of hearing to assessee. 11. After appreciating the facts

M/S. GUJARAT CHEMICAL PORT TERMINAL CO.LTD.,,BHARUCH vs. THE CIT-I, BARODA

In the result, Cross Objection appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.1501/Ahd/2014 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Gujarat Chemical Port Terminal V The Commissioner Of Income Tax, Vadodara. Company Ltd., S Po Lakhigam, Via Dahej, . Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2998/Ahd/2014 "नधा"रण वष"/Assessment Year: 2010-11 The Deputy Commissioner Of Income V M/S.Gujarat Chemical Port Tax, Circle-1(1), Baroda. S Terminal Company Ltd., . Po Lakhigam, Via Dahej, Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent Cross Objection No.30/Ahd/2015 (Arising Out Of Ita No.2998/Ahd/2014) "नधा"रण वष"/Assessment Year: 2010-11 M/S.Gujarat Chemical Port Vs. The Deputy Commissioner Of Terminal Company Ltd., Income Tax, Circle-1(1), Po Lakhigam, Via Dahej, Baroda. Bharuch – 392 130. [Pan: Aaacg 6861 A] अपीलाथ" / Appellant ""यथ"/Respondent

263 itself is not maintainable, therefore there is no need to deal with the other issues. 10. In the result net result, appeal is allowed.” 10. And also in CIT vs. Roadmaster Industries of India Ltd., it is held as “A revisional order can be passed only after giving an opportunity of hearing to assessee. 11. After appreciating the facts

NAYNABEN ARUNBHAI JAIN,AHURA NAGAR SOCIETY vs. PCIT SURAT-1, AAYAKAR BHAVAN

In the result, the appeal of the assessee is allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.571 & 572/Srt/2024 Assessment Years: (2013-14 & 2014-15) (Hybrid Hearing) Naynaben Arunbhai Jain Principal Commissioner Of बनाम/ 255-257, Ahura Nagar Society Income-Tax, Surat-1, Income Tax Vs. Surat – 395009 Office, 123, 1Stfloor, Aaykar Bhavan, Majura Gate, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acnpj 5784 D (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से / Appellant By Shri Rasesh Shah, Ca राज" की ओर से /Respondent By Shri Ravinder Sindhu, Cit-Dr सुनवाई की तारीख/Date Of Hearing 23/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 19/09/2025

delays in filing the appeals are condoned and we proceed to decide the cases on merit. 3. Grounds of appeal raised by the assessee in ITA No.571/SRT/2024 (AY 2013-14) are as under: “1. On the facts and in circumstances of the case as well as law on the subject, the learned Pr.CIT has erred in passing the order u/s

NAYNABEN ARUNBHAI JAIN,AHURA NAGAR SOCIETY vs. PCIT SURAT-1, AAYAKAR BHAVAN

In the result, the appeal of the assessee is allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.571 & 572/Srt/2024 Assessment Years: (2013-14 & 2014-15) (Hybrid Hearing) Naynaben Arunbhai Jain Principal Commissioner Of बनाम/ 255-257, Ahura Nagar Society Income-Tax, Surat-1, Income Tax Vs. Surat – 395009 Office, 123, 1Stfloor, Aaykar Bhavan, Majura Gate, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acnpj 5784 D (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से / Appellant By Shri Rasesh Shah, Ca राज" की ओर से /Respondent By Shri Ravinder Sindhu, Cit-Dr सुनवाई की तारीख/Date Of Hearing 23/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 19/09/2025

delays in filing the appeals are condoned and we proceed to decide the cases on merit. 3. Grounds of appeal raised by the assessee in ITA No.571/SRT/2024 (AY 2013-14) are as under: “1. On the facts and in circumstances of the case as well as law on the subject, the learned Pr.CIT has erred in passing the order u/s

SHRI KAMALUDDIN POPATLAL SURANI,VAPI vs. PCIT, VALSAD

In the result, the appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.666/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Kamaluddin Popatlal Surani, Vs. The Pcit, A/12, Golden Park, Kabrastan Road, Valsad Vapi - 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajyps2442M (Appellant) (Respondent) Appellant By Shri Rajesh Upadhyaya, Ar Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 02/12/2024 Date Of Pronouncement 02/01/2025

u/s 263 of the Act came to the knowledge of Shri Kunal Pitalia on 06.06.2024, when the appellant inquired about the result of revision proceedings by the PCIT for which reply was filed in March,2024. When he visited ITBA portal, it was found that the revision order was passed by the PCIT on 15.03.2024. Thereafter, he immediately informed Shri

SHHLOK TRITON ASSOCIATES ,SURAT vs. PR. COMMISSIONER OF INCOME TAX, SURAT

In the result, the appeal of the appellant is allowed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.638/Srt/2024 Assessment Year:(2014-15) (Hybrid Hearing) M/S Shhlok Triton Associates, Vs. Pcit – 1, F.P. No. 388, Paikee Udhna Surat Darwaja, Ring Road, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aclfs6819A (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Mukesh Jain, Cit (Dr) Date Of Hearing 18/06/2025 Date Of Pronouncement 19/08/2025

condone the delay and admit the appeal for hearing. 4. Brief facts of the case are that the assessee filed its return of income for AY 2014-15 on 27.11.2014, declaring total income of Rs.2,32,06,770/-. The assessment u/s 143(3) of the Act was passed on 09.12.2016, accepting the returned income. The ld. PCIT called

SHRI MURLI FATANDAS SAWLANI,SURAT vs. INCOME TAX OFFICER, WARD-1(3)(3), SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.215/Srt/2022 Assessment Year: (2013-14) (Virtual Hearing) Shri Murli Fatandas Sawlani, Vs. The Ito, Ward – 1(3)(3), C/O. Ketan H. Shah, Advocate, Surat. 9Th Floor, Sopphire Ciomplex, C.G. Road, Navrangpura, Ahmedabad – 380009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adeps9862M (Appellant) (Respondent) Appellant By Shri Ketan Shah, Ar & Shri Aman K. Shah, Ar Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 25/04/2023 17/05/2023 Date Of Pronouncement

condonation of delay, which is reproduced below: “I, Murli Son of Fatandas Sawlani age about 63 years, residing at Sawlani Estate, Surat do hereby solemnly affirm as under: 1. That, I have filed my return of income for the AY 2013-14 on 23-11-2013 and thereafter, there was 143(3) assessments made making addition in reference to ITA.215/SRT/2022/AY.2013-14

POPATBHAI TALASHIBHAI SAVANI,SURAT vs. DCIT, CENTRAL CIRCLE 2, SURAT

In the result, both the appeals of the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Delay condoned. These two appeals filed by the assessee are directed against the separate orders passed by the learned Principal Commissioner of Income-Tax (Central), Surat [herein-after referred to as “PCIT”] dated 29.03.2025 and 30.03.2025 respectively, in exercise of revisionary powers under Section 263 of the Income- tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment

POPATBHAI TALASHIBHAI SAVANI,SURAT vs. PCIT, CENTRAL, SURAT

In the result, both the appeals of the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Delay condoned. These two appeals filed by the assessee are directed against the separate orders passed by the learned Principal Commissioner of Income-Tax (Central), Surat [herein-after referred to as “PCIT”] dated 29.03.2025 and 30.03.2025 respectively, in exercise of revisionary powers under Section 263 of the Income- tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment

JAYKANT UTTAMCHAND SHAH,VAPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX ,, VALSAD

In the result, this appeal of assessee is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

u/s 263 of the Act setting aside the order of A.O. and directing A.O. to pass fresh assessment order may please be quashed. 5. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 2. Perusal of record reveals that the impugned order was passed

ASHWINKUMAR ARBAN CO-OPERATIVE SOCIETY LTD.,,SURAT vs. PR. COMMISSIONER OF INCOME TAX - 1, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) Ashwinkumar Arban Co- Principal Commissioner Of Operative Society Ltd., Income Tax-1, Surat. Vs. 7-8, Hiranagar-2, Patel Nagar, Varachha A.K. Road, Surat- 395008 (Gujarat) Pan No. Aabta 0698 R Appellant/ Assessee Respondent/ Revenue

u/s 263 of the I.T. Act, 1961 setting aside the order of Assessing Officer and directing Assessing Officer to pass fresh assessment order may please be quashed.” 2. Perusal of record shows that the impugned order was passed by the ld. Pr.CIT on 15/02/2023, however, the present appeal is filed on 29/09/2023, thus, there is delay in filing appeal before

SHRI KARANBHAI MANJIBHAI PATEL,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX-1, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.27/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15) (Virtual Court Hearing) Shri Karanbhai Manjibhai Patel Principal Commissioner Of Income Tax, Surat-1, 1St Floor, Aaykar Bhavan, 14, Akhandanand Society B/H Vs. Vishal Nagar, Adajan Road, Majura Gate,Surat-395001 Surat-395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahnpd9673 L (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Ashutosh P Nanavaty, C.A राज"व क" ओर से /Respondent By: Shri Ashok B. Koli, Cit-D.R

u/s 263 of the I.T 1961 adopting verbatim copy from proposal of revision by Ld.DCIT-1(3) which admits full and complete filling of submission by assessee and inquiry in all issues as specified in limited scrutiny notice in recommendation letter by DCIT-1(3) hence there is no independent application of mind by Ld.PCIT-1. 5) PCIT

NARESHBHAI BABUBHAI SAVANI,SURAT vs. DCIT CENTRAL CIRCLE 2, SURAT

In the result, both the appeals of the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Delay condoned. These two appeals have been filed by the different assessees against separate orders passed by the learned Principal Commissioner of Income-Tax (Central), Surat [herein-after referred to as “PCIT”], both dated 30.03.2025, in exercise of revisionary powers under Section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year

NITINBHAI POPATBHAI SAVANI,SURAT vs. DCIT, CENTRAL CIRLE 2, SURAT

In the result, both the appeals of the assessee are allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Delay condoned. These two appeals have been filed by the different assessees against separate orders passed by the learned Principal Commissioner of Income-Tax (Central), Surat [herein-after referred to as “PCIT”], both dated 30.03.2025, in exercise of revisionary powers under Section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year

PURPLE MEDICAL SOLUTIONS PVT. LTD [SUCCESSOR OF MIV THERAPEUTICS (INDIA) PVT. LTD],MULUND vs. PR. CIT-1, SURAT

In the result, this appeal of the assessee is dismissed as withdrawn

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Purple Medical Solutions Private Limited Pr.C.I.T. (Successor Of Miv Therapeutics (India) Surat-1, Vs. Pvt. Ltd.) Surat. 615/616 Avior, Nirmal Galaxy, Lbs Road, Mulund (W), Mumbai-400080. Pan: Aaecp 3664 L Appellant Respondednt

revision of such order is beyond the scope of section 263 of the Act. Purple Medical Solutions P Ltd Vs Pr.CIT 2. The ld. Pr.CIT erred in passing the order u/s 263 of the Act on a non- existent entity and hence the order passed is void and bad in law and liable to be quashed. 3. The ld. Pr.CIT

VAPI GREEN ENVIRO LIMITED,VAPI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, , VALSAD

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Vapi Green Enviro Limited, Pr.C.I.T., Valsad. 135, 1St Floor, Via House, G.I.D.C. 301, 3Rd Floor, Palak Vs. Char Rasta, Vapi, Gujarat, Arcade, Shanti Nagar, India-396195. Tithal Road, Pan: Aaacv 8289 P Valsad-396001. Appellant Respondednt

263 considering that the order passed by National e-Assessment Centre, Delhi, u/s. 143(3) is erroneous and prejudicial to the interest of the revenue. 2. The Ld. Commissioner of Income Tax (Exemption), has further erred in law and on facts, in as much as, while passing order u/s.263 of the I.T. Act, 1961 on 31.03.2023 without considering the fact