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

72,620/- towards Dividend received from other Co-operative Society deduction disallowed under section u/s 80P(2)(d) which is void ab initio hence rejection of deduction is bad in law. 4. The Learned CIT(A)/ NFAC has erred in rejecting the delay condone

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

72,620/- towards Dividend received from other Co-operative Society deduction disallowed under section u/s 80P(2)(d) which is void ab initio hence rejection of deduction is bad in law. 4. The Learned CIT(A)/ NFAC has erred in rejecting the delay condone

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

72,620/- towards Dividend received from other Co-operative Society deduction disallowed under section u/s 80P(2)(d) which is void ab initio hence rejection of deduction is bad in law. 4. The Learned CIT(A)/ NFAC has erred in rejecting the delay condone

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

72,620/- towards Dividend received from other Co-operative Society deduction disallowed under section u/s 80P(2)(d) which is void ab initio hence rejection of deduction is bad in law. 4. The Learned CIT(A)/ NFAC has erred in rejecting the delay condone

RAGHUNANDAN IMPEX PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-2(1)(1), SURAT, SURAT

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

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Raghunandan Impex Pvt. Ltd., Ito Ward 2(1)(1), 6/2037, Office No. 205, 2Nd Floor, Room No. 222, Papadwala Building, Bhoja Bhai Vs. Aayakar Bhavan, Ni Sheri, Mahidharpura, Majura Gate, Surat-395003. Surat-395001. Pan No. Aaecr 5688 Q Appellant Respondent

72,500/- in respect of addition made u/s.68 of alleged in respect of addition made u/s.68 of alleged non-genuine purchase of traded goods made from M/s. genuine purchase of traded goods made from M/s. genuine purchase of traded goods made from M/s. Gangotri Exim P Lid and M/s. Aditi Gems Pvt Ltd of Exim P Lid and M/s. Aditi

KESHRI EXPORT,SURAT vs. INCOME TAX OFFICER, WARD - 3(3)(3), SURAT

In the result, appeal filed by the assessee is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.186/Srt/2023 "नधा"रण वष"/Assessment Year: (2017-18) (Virtual Hearing) Keshri Export, Vs. The Ito, 123, Gurunagar Society, Opp. Baroda Ward-3(3)(1), Prestige, Varachha Road, Surat. Surat – 395006. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfk3785D Assessee By Shri Hiren Vepari, Ca Respondent By Shri Milan Kamble, Sr. Dr 18/07/2023 Date Of Hearing Date Of Pronouncement 11/09/2023

condone the delay and admit the appeal for hearing. 10. Briefly stated, the relevant material facts are as follows. The assessee has filed his return of income on 30.09.2017, declaring total income of Rs.6,72,826/-. The return of income was processed u/s 143(1) of the Income Tax Act, 1961. Later on, the assessee`s case was selected

SUNILKUMAR ICHHUBHAI PATEL,SURAT vs. ITO, WARD-2(2)(4), SURAT

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

delayed by 177 days due to communication issues with his tax consultant regarding hearing notices for the appeal before the CIT(A). The AO made a best judgment assessment under section 144 of the Act, treating cash deposits and credits totaling Rs. 72,68,976/- as unexplained money under section 69A.", "held": "The Tribunal condoned

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

Section 50C of the Act for the alleged deemed Capital Gain, without appreciating the crucial and relevant evidences furnished to establish the maximum possible fair market value prevailing on the date of transfer of the land in question and hence, not justified. 2. On the facts and in the circumstances of the case as well in law, the learned

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

Section 50C of the Act for the alleged deemed Capital Gain, without appreciating the crucial and relevant evidences furnished to establish the maximum possible fair market value prevailing on the date of transfer of the land in question and hence, not justified. 2. On the facts and in the circumstances of the case as well in law, the learned

VIJAY NAGINBHAI PATEL,SURAT vs. INCOME TAX OFFICER, WARD-3(2)(4), SURAT

In the result, this appeal of assessee is dismissed

Bench: Shri Pawan Singh(Virtual Hearing) Vijay Naginbhai Patel, I.T.O., 52, Hari Har Society, Katargam Main Ward 3(2)(4), Vs. Road, Surat-395004. Surat. Pan No. Abrpp 3832 B Appellant/ Assessee Respondent/ Revenue

Section 50C of the Act. It was also noted that the assessee kept 25% share from the said land as a purchaser. The Assessing officer calculated the assessee’s 25% share as of Rs. 9,56,862/-. The assessee filed his reply and stated that the assessee has sold 75% of the land and 25% is kept for himself

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

72 ITR 194 wherein Shah, J (as His Lordship then was) held as follows: “The question again assumes that it was for the Income- Tax Officer to indicate the source of the income before the income could be held taxable and unless he did so, the assessee was entitled to succeed. That is not, in our judgment, the correct legal

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

delay of 166 days in filing appeal is condoned. Now adverting to the merit of the case. 5 Ashwinkumar Arban Co-Op Society Ltd. Vs Pr.CIT 6. We find that the assessment for A.Y. 2018-19 was completed on 01/02/2021 in accepting returned income. We find that the ld. Pr.CIT issued show cause notice under Section

VIPULBHAI VITTHALBHAI KAKADIA,SURAT vs. ITO, WARD 3(1)(5), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.543/Srt/2025 Assessment Year: 2010-11 (Hybrid Hearing) Vipulbhai Vitthalbhai Kakadia बनाम/ Income Tax Officer, 301, B/H Golden Point, Anmol Vs. Ward-3(1)(5), Complex Nana Varachha, Surat - 395001 Surat-395 006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aowpk 3567 Q (अपीलाथ"/Appellant) (""थ"/Respondent) "नधा"रतीक"ओरसे/Appellant By Shri P.M. Jagasheth, Ca राज"वक"ओरसे /Respondent By Shri Abhishek Gautam, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing 25/09/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 24/11/2025

condone the delay and admit the appeal for hearing. 6. Brief facts of the case are that as per the AIR information, the assessee transacted in the Commodity Exchange, but during the year did not file the return of income. The assessee was issued a letter seeking information, which was not responded to. Therefore, the case was re-opened

KISHOR RAMESHBHAI MEHTA,SURAT vs. ITO, WARD-1(5), BHARUCH

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.60/Srt/2025 Assessment Year: 2013-14 (Hybrid Hearing) Kishor Rameshbhai Mehta Vs. Ito, Prop. Of Aditya Infrastructure, Ward - 1(5), 139, Maher Nagar, Opp. Baps Bharuch Hospital, Adajan Gam Circle, Surat - 395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adepm 4458 R (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 10/11/2025

section 253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal of appeal before the Tribunal. In the affidavit, the assessee stated that his consultant had filed physical appeal on 29.04.2016 and mentioned communication address in Form 35 against the assessment order. The NFAC issued notices on e-mail

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

72 taxmann.com 127 (Kolkata – Tribunal). It was further submitted by the assessee that showcase notice issued u/s.263(1) of the Act is at page no.148 & 149 of the paper book and the said show-cause notice is restricted only to on account of two heads i.e. (i) Interest Payable on the loan received from Reliance Industries Limited, it was capitalized

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

72 taxmann.com 127 (Kolkata – Tribunal). It was further submitted by the assessee that showcase notice issued u/s.263(1) of the Act is at page no.148 & 149 of the paper book and the said show-cause notice is restricted only to on account of two heads i.e. (i) Interest Payable on the loan received from Reliance Industries Limited, it was capitalized

THE PUNA KUMBHARIA GROUP CO-OP FRUITS AND VEGE GROW SOCIETY LIMITED,SURAT vs. ACIT CIRCLE 3(2), SURAT

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.354 To 355/Srt/2025 Ays: (2017-18 & 2018-19) (Hybrid Hearing) The Puna Kumbharia Groud Co-Op. Vs. Acit, Fruits & Vege Grow Society Circle – 3(2), Limited, Surat Kela Yard Dumbhai, Puna Kumbhariya Road, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaap1147N (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms Namita Patel, Sr. Dr Date Of Hearing 27/08/2025 Date Of Pronouncement 29/08/2025

delay in filing appeal is condoned subject to the payment of cost of Rs.10,000/- (Rupees Ten Thousand only) by the appellant to the credit of the 3 ITA Nos.354 & 355/SRT/2025/AY 2017-18 & 2018-19 The Puna Kumbharia Group Co-op. Fruits & Vege Grow Soc. Ltd. ‘Prime Minister’s National Relief Fund’ within 3 weeks from receipt of this order

THE PUNA KUMBHARIA GROUP CO-OP FRUITS AND VEGE GROW SOCIETY LIMITED,SURAT vs. ACIT CIRCLE 3(2), SURAT

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.354 To 355/Srt/2025 Ays: (2017-18 & 2018-19) (Hybrid Hearing) The Puna Kumbharia Groud Co-Op. Vs. Acit, Fruits & Vege Grow Society Circle – 3(2), Limited, Surat Kela Yard Dumbhai, Puna Kumbhariya Road, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaap1147N (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms Namita Patel, Sr. Dr Date Of Hearing 27/08/2025 Date Of Pronouncement 29/08/2025

delay in filing appeal is condoned subject to the payment of cost of Rs.10,000/- (Rupees Ten Thousand only) by the appellant to the credit of the 3 ITA Nos.354 & 355/SRT/2025/AY 2017-18 & 2018-19 The Puna Kumbharia Group Co-op. Fruits & Vege Grow Soc. Ltd. ‘Prime Minister’s National Relief Fund’ within 3 weeks from receipt of this order

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, SURAT vs. M/S. KEJRIWAL INDUSTRIES LTD.,, SURAT

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri O.P.Meena

condone the delay in filing of appeal and allow the appeal to be proceeded with on merit. The Grounds of appeal raised by the Revenue read as under: 5. “[1] On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of DCIT, Circle-1(1)(2), Surat Vs. Kejriwal