ITO, WARD -2(3)(8), SURAT vs. SHRI MAYUR ASHESHBHAI JOSHI, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

SONU DHARMICHAND BAFNA PROP. OF BRIGHT DIAMONDS,SURATY vs. INCOME TAX OFFICER, WD- 2(3)(8), SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

ITO, WARD 2(3)(8), SURAT vs. SHRI PARAG NARESHBHAI MEHTA, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

MAYUR ASHESHBHAI JOSHI PROP. SHRUSHTI ENTERPRISE,SURAT vs. INCOME TAX OFFICER, WARD, - 2(3)(8), SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

INCOME TAX OFFICER, WARD -2(3)(8), SURAT vs. SHRI SONU DHARMICHAND BAFNA,, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

THE ITO, WARD-2(3)(8),, SURAT vs. SHRI VRAJENDRA JAGJIVANDAS THAKKAR,, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

VRAJENDRA JAGJIVANDAS THAKKAR PROP. OF ADITI EXPORTS,SURAT vs. INCOME TAX OFFICER, WD- 2(3)(8), SURAT

In the result the ground No

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

condonation of delay in case of ITA No.167/SRT/2021 in the case of Sonu Dharmichand Bafna (supra) is as follows: “I have filed an appeal under section 253(1) of the Income Tax Act, 1961 on 01.10.2021 vide ITA No.167/SRT/2021 against the order of the Commissioner (Appeals) relating to A.Y.2013-14 made on the 29.11.2018, Though this appeal should have been filed

KIRANBEN YOGESHBHAI PATEL,SURAT vs. ITO WARD-2 (2)(2), SURAT

In the result, both the appeals filed by the assessees are allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.200/Srt/2020 Assessment Year: (2008-09) (Physical Court Hearing) Smt.Kiranben Yogeshbhai Patel, Vs. Income Tax Officer, Ward- 2(2)(2), Room No.625, 6Th At & Post: Sosak, Tal: Olpad, Dist: Sura-394540. Floor, Aayakar Bhavan, Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxapp0342K (Appellant) (Respondent) आयकर अपील सं./Ita No.201/Srt/2020 Assessment Year: (2008-09) (Physical Court Hearing) Smt. Manjulaben Kiritbhai Patel, Vs. The Ito, Ward-2(2)(2), Post Orma, Taluka Olpad, Dist: Surat. Surat-394540. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxapp0220J (Appellant) (Respondent) Shri Mehul Shah, Ca Assessee By Revenue By Shri J. K. Chandnani, Sr. Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 22/ 08/2022

section 154 of the Act, and in this process assessee took more than one and half year. Thereafter, six months delay was due to COVID-19 pandemic. This way, assessee has explained the delay in a satisfactorily manner. We note that since assessee was seeking alternative remedy available under the law, and therefore delay should be condoned, for that reliance

MANJULABEN KIRITBHAI PATEL,SURAT vs. ITO WARD - 2(2)(3), SURAT

In the result, both the appeals filed by the assessees are allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.200/Srt/2020 Assessment Year: (2008-09) (Physical Court Hearing) Smt.Kiranben Yogeshbhai Patel, Vs. Income Tax Officer, Ward- 2(2)(2), Room No.625, 6Th At & Post: Sosak, Tal: Olpad, Dist: Sura-394540. Floor, Aayakar Bhavan, Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxapp0342K (Appellant) (Respondent) आयकर अपील सं./Ita No.201/Srt/2020 Assessment Year: (2008-09) (Physical Court Hearing) Smt. Manjulaben Kiritbhai Patel, Vs. The Ito, Ward-2(2)(2), Post Orma, Taluka Olpad, Dist: Surat. Surat-394540. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxapp0220J (Appellant) (Respondent) Shri Mehul Shah, Ca Assessee By Revenue By Shri J. K. Chandnani, Sr. Dr Date Of Hearing 24/06/2022 Date Of Pronouncement 22/ 08/2022

section 154 of the Act, and in this process assessee took more than one and half year. Thereafter, six months delay was due to COVID-19 pandemic. This way, assessee has explained the delay in a satisfactorily manner. We note that since assessee was seeking alternative remedy available under the law, and therefore delay should be condoned, for that reliance

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

condonation of delay. In the application, the assessee/applicant contended that the impugned order passed by the ld. CIT(A) dated 20/09/2017 was served upon the assessee on 27/10/2017 and as such, the time limit for filing appeal was up to 25/12/2017. After the order of ld. CIT(A), the order giving effect and demand notice under Section

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

condonation of delay. In the application, the assessee/applicant contended that the impugned order passed by the ld. CIT(A) dated 20/09/2017 was served upon the assessee on 27/10/2017 and as such, the time limit for filing appeal was up to 25/12/2017. After the order of ld. CIT(A), the order giving effect and demand notice under Section

RAZAK ABDULKARIM MANSURI,VAPI vs. INCOME TAX OFFICER, WARD-7, VAPI

Appeal is allowed for statistical purpose

Bench: Dr. Dinesh Mohan Sinha&Shri Bijayananda Pruseth

48 days. The assesse filed an affidavit of condonation of delay. During the period under consideration, the appellant was commission agent. He was engaged in a distributorship of Suvidha Infoserve Pvt. Ltd and had earned commission income from the same. He had earned rent ~ 2 ~ ITA- 352/SRT/2024 Razak Abdulkarim Mansuri income from the house property and interest income. The appellant

MANOJKUMAR ISHWARBHAI PATEL,BARDOLI vs. INCOME TAX OFFICER, WARD-1, , BARDOLI

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपील सं./Ita No.710/Srt/2023 (िनधा"रण वष" / Assessment Year: (2015-16) (Hybrid Hearing) Manojkumar Ishwarbhai Patel Income Tax Officer, Ward-1, Bardoli, 2Nd Floor, Income Tax 2/917 Sahil Bungalow, Vs. Office, Bsnl Building, Station Vallabhwadi, Bardoli-394601 Road, Bardoli-394601 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bhlpp 2872 G (अपीलाथ" /Appellant) (""थ"/Respondent)

section 144 of the Income Tax Act, 1961 (in short ‘the Act’), dated 28.03.2023. 2. The grounds of appeal raised by assessee are as follows:- “1. That on facts and circumstances of case as well as law on subject the learned CIT(A) erred in confirming the action of Assessing Office in assessing total income at Rs.56,48

DIVYABEN PRAFULCHANDRA PARMAR,SURAT vs. INCOME TAX OFFICER, WARD 1(3)(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.73/Srt/2023 (Assessment Year: 2014-15) (Physical Hearing) Divyaben Prafulchand Parmar, Vs. The Ito, Ward-1(3)(1), 1-2, Harikrishna Niwas, B/H Braham Surat. Kumari Ashram, Bhatar Road, Surat – 395017. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acbpp9559Q (Appellant) (Respondent)

condone the delay in filing appeal and admit the appeal for hearing. 9. Succinctly, the factual panorama of the case is that assessee before us is an Individual and filed her return of income on 04.03.2015, declaring total income of Rs.4,22,502/-. The assessee`s case was selected for scrutiny through CASS and notice

RUPAL DEVANG NAIK ,NA vs. ARIVS.ITO, WARD-4, NAVSARI

In the result, the appeal of the assessee is treated as allowed for statistical\npurposes

condoned the 65-day delay in filing the appeal, finding it unintentional. The matter was restored to the AO for de novo adjudication, with a cost of Rs. 5,000/- imposed on the assessee.", "result": "Allowed", "sections": [ "148", "144", "50C", "142(1)", "48

BAKER ABDULAZIZ NORAT,PANOLI, BHARUCH, GUJARAT vs. INCOME TAX OFFICE, WARD 1(1), BHARUCH, BHARUCH, GUJARAT

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1232/Srt/2024 Assessment Year: (2018-19) (Hybrid Hearing) Baker Abdulaziz Norat, Vs. Ito, 107, Panoli Travels, Station Road, Ward – 1(1), Panoli, Bharuch – 394115 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Akepn7411Q (Appellant) (Respondent) Appellant By Ms Vidhi Pandya, Ca Respondent By Shri Abhishek Gautam, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 21/11/2025

48,210/-, which was treated as unexplained cash credits u/s 68 of the Act. The total income was assessed at Rs.32,56,740/- as against returned income of Rs.4,08,530/-. Subsequently, penalty proceeding u/s 270A of the Act was initiated on 17.03.2021 by issuing show cause notices dated 09.06.2021 and 27.07.2021, requesting to file its reply. The assessee

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

48, a decision of a Division Bench of this Court:- “It is well know that the whole catena of sections starting from s. 68 have been introduced into the taxing enactments step by step in order to plug loopholes and in order to place certain situations beyond doubt even through there were judicial decisions covering some of the aspects

HETALKUMAR CHANDRAKANTBHAI PATEL,SURAT vs. ITO, WARD 1(3)(7), SURAT

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

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1340/Srt/2024 Assessment Year: (2012-13) (Hybrid Hearing) Hetalkumar Chandrakantbhai Patel, Vs. The Ito, A-371/3, Sundervan Raw House, Nr. Ward – 1(3)(7), Subhash Garden, Jahangirabad, Surat Bhesan, Surat - 395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bkrpp5151R (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Rajesh Upadhyay, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 02/04/2025 Date Of Pronouncement 07/05/2025

condone the delay and admit the appeal for hearing. ITA No.1340/SRT/2024/AY.2012-13 Hetalkumar Chhandrakantbhai Patel 7. The facts of the case in brief are that the assessee did not file return of income for AY.2012-13 and the assessee was identified as a non-filler in the Non-filler Monitoring System (NMS). From the information available in ITS, the Assessing Officer