ASST. COMMISSIONER OF INCOME TAX, CC-2, SURAT vs. AALIDHAARA TEXTOOL ENGINEERS PVT. LTD, SURAT

In the result, the grounds of appeal raised by Revenue are partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

133(6) to Dudhiben ITA Nos. 226/SRT/2023 & 288/SRT/2022/AYs.2017-18 & 2018-19 ACIT vs. Aalidhar Textool Engineers Pvt. Ltd. Ambalal Gondalia Education Foundation Trust, for seeking copy of registration under section 80G. The Assessing Officer noted that Dudhiben Ambalal Gondalia Education Foundation Trust was received and they furnished a copy of registration under section 80G. The other two trust has not furnished

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, SURAT vs. M/S AALIDHAR TEXTOOL ENGINEERS PVT. LTD., SURAT

In the result, the grounds of appeal raised by Revenue are partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

133(6) to Dudhiben ITA Nos. 226/SRT/2023 & 288/SRT/2022/AYs.2017-18 & 2018-19 ACIT vs. Aalidhar Textool Engineers Pvt. Ltd. Ambalal Gondalia Education Foundation Trust, for seeking copy of registration under section 80G. The Assessing Officer noted that Dudhiben Ambalal Gondalia Education Foundation Trust was received and they furnished a copy of registration under section 80G. The other two trust has not furnished

M/S. S.D. MINERALS PVT.LTD.,SURAT vs. THE JT.CIT.,(OSD)CIRCLE-4,, SURAT

In the result, the appeal of the assessee stands allowed

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.554/Srt/2019 िनधा"रण वष"/Assessment Year:2009-10 M/S. S.D. Minerals Pvt. Ltd., Joint Commissioner Of 3009, World Trade Centre, Income-Tax Circle –4 Ring Road Surat 395002 (Osd)Surat Pan: Aakcs 3533 K अपीलाथ" Appellant ""यथ"/Respondent

section 133(6) of the Act and obtained the Ledger copy of account of certain parties, in which five parties reflected that they had received cash payment in excess of Rs.20 000, in a day aggregating to Rs. 81,47,100. Therefore, the assessee was asked to show cause as to why the same should not be disallowed

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, SURAT vs. SMT. FALGUNI SANDIPKUMAR NAIK, SURAT

Appeal of the Revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A Nos. 19, 20 & Ita 659/Srt/2018 (Assessment Years: 2012-13, 2013-14 & 2014-15) (Hearing In Physical Court)

disallowance expenditure. On the objection of Assessing Officer that he has received information from Investigation Wing wherein that the proprietor of Veer Corporation namely Chetankumar K Shah is engaged in the business of providing accommodation entry and the same is treated as non-genuine. The assessee submitted that in response to notice under Section 133

VISHWAS BUILDERS,OPERA PALACE vs. ACIT, CIR 2(2), SURAT, MAJURAGATE, 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: 2017-2018 Vishwas Builders, Acit, Cir 2(2), Laskana Kholvad Road, Aaykar Bhavan, Gujarat-395004. Vs. Majuragate, Surat-395001. Pan No. Aakfv 9174 A Appellant Respondent

section 269SS of the Act, and appropriate proceedings could be initiated in of the Act, and appropriate proceedings could be initiated in of the Act, and appropriate proceedings could be initiated in accordance with law. accordance with law. Vishwas Builders 5 3. On appeal, the learned Commissioner of Income the learned Commissioner of Income the learned Commissioner of Income

ACIT, CIRCLE-3(2), SURAT vs. M/S. RAJLAXMI INFRA, SURAT

In the result, this ground of appeal is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.163/Srt/2020 (Ay 2013-14) (Hearing In Physical Court) Assistant Commissioner Of M/S Rajlaxmi Infra Income-Tax, Circle-3(2), Room 64, Rajlaxmi Height, Vs No.410, Aayakar Bhawan, Singanpore Cosway Road, Majura Gate, Opp. Shradhhadeep Soc, Surat-395001 Surat-395004 Pan No. Aaofr 1095 C ""थ" /Respondent अपीलाथ"/Appellant

disallowing purchase only on the ground that party did not file any evidence in response to notice under section 133

THE AMROLI VIBHAG VIVIDH KARYAKARI SAHKARI M LTD.,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE - 2(3), SURAT

In the result, ground no.3 raised by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.672/Srt/2023 Assessment Year: (2017-18) (Hybrid Hearing) The Amroli Vibhag Vividh Vs. The Dcit, Karyakari Sahkari M. Ltd., Circle – 2(3), Utran Amroli, Taluka Choryasi, Surat Surat – 394105. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat3043M (Appellant) (Respondent) Appellant By Shri Mehul K. Patel, Ar Shri Vinod Kumar, Sr. Dr Respondent By 18/12/2023 Date Of Hearing Date Of Pronouncement 21/12/2023

disallowance to the tune of Rs.78,02,133/- stating that assessee has claimed the deduction under section 80P of the Act. On appeal

MURTUJA HUSAINBHAI HIRANI,NA vs. ARIVS.INCOME TAX OFFICER, WARD - 3, , NAVSARI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.196/Srt/2023 "नधा"रण वष"/Assessment Year: (2014-15) (Physical Hearing) Murtuja Hussainbhai Hirani, Vs. The Ito, Ward-3, Prop. Of R. K. Bullion, Navsari Shop No.5, Pranav Chamber Madhumati, Navsari – 396445, Gujarat. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aciph3680D Appellant By Shri Rasesh Shah, Ca Respondent By Shri Vinod Kumar, Sr. Dr 09/06/2023 Date Of Hearing Date Of Pronouncement 26/06/2023

disallowance can be made. We note that assessee`s case under consideration relates to assessment year 2014-15, where purchase in cash to the extent of Rs.20,000/- is allowed. We have gone through the assessee`s paper book and noted that each cash payment against each cash purchase, does not exceed Rs.20,000/-. Therefore, we note that cash purchase

SHREE DURGA SYNTEX PRIVATE LIMITED,SURAT vs. ACIT, CIRCLE-4, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) D.C.I.T. M/S Shree Durga Syntex Pvt. Ltd., Circle-2(1)(2), Block No. 129 & 175, Plot No. Z&E, R.S. Vs. Room No. 205, Aayakar No. 120, Tal: Jolva-394305, Dist- Surat. Bhavan, Majura Gate, Pan: Aabcd 8894 P Surat. Appellant Respondednt M/S Shree Durga Syntex Pvt. Ltd., A.C.I.T. Block No. 129 & 175, Plot No. Circle-4, Vs. Z&E, Jolva Rs No. 120 & 120/1, Surat. Surat-394305. Pan: Aabcd 8894 P Appellant Respondednt

Section 133(6), they confirmed the payment of brokerage made by assessee. The assessee was also asked to furnish name of broker through whom purchase of polyster chips and the name of broker through whom sales of yarn/grey fabric was made. The assessee vide his reply dated 14/3/2014 submitted that for selling of its product, technical services were also expected

DCIT, CIRCLE-2(1)(2), SURAT vs. M/S. SHREE DURGA SYNTEX PVT. LTD, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) D.C.I.T. M/S Shree Durga Syntex Pvt. Ltd., Circle-2(1)(2), Block No. 129 & 175, Plot No. Z&E, R.S. Vs. Room No. 205, Aayakar No. 120, Tal: Jolva-394305, Dist- Surat. Bhavan, Majura Gate, Pan: Aabcd 8894 P Surat. Appellant Respondednt M/S Shree Durga Syntex Pvt. Ltd., A.C.I.T. Block No. 129 & 175, Plot No. Circle-4, Vs. Z&E, Jolva Rs No. 120 & 120/1, Surat. Surat-394305. Pan: Aabcd 8894 P Appellant Respondednt

Section 133(6), they confirmed the payment of brokerage made by assessee. The assessee was also asked to furnish name of broker through whom purchase of polyster chips and the name of broker through whom sales of yarn/grey fabric was made. The assessee vide his reply dated 14/3/2014 submitted that for selling of its product, technical services were also expected

NIRALKUMAR K. SHAH,VALSAD vs. ITO, WARD-6,, VAPI

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

Bench: Shri Pawan Singh(Virtual Hearing) Niralkumar K Shah, I.T.O., B-001, Sharddha Co.Op Hsg. Soc., Ward-6, Vs. Gunan Road, Ta-Pardi, Valsad. Vapi. M. No. 9913800836 E Mail-Parinshahca@Gmail.Com Pan No. Bvjps 2700 J Appellant/ Assessee Respondent/ Revenue

disallowed such commission payment by observing that no services were rendered by these persons. The Assessing Officer also noted that he issued notice under Section 133

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. GUJARAT POLYSOL CHEMICALS LIMITED, VAPI

In the result, all the appeals filed by the revenue\nstands dismissed

section 133(6) of the Act, wherein all suppliers have\nconfirmed their supplies and Sunil Patel in his affidavit by\nextracted in a statement during the search proceedings as\nclarified that he was under pressure and has no experience of\nworking in manufacturing industry and made a statement under\nmisconception of cash discounting on purchase; and по\nevidence of investment

SIDDHI VINAYAK KNOTS & PRINTERS PVT. LTD.,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, all the appeals of the assessee are allowed and appeals of revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A Nos. 40, 41, 42, 43 & 115/Srt/2021 (Assessment Years 2010-11 To 2014-15) (Physical Hearing) Siddhi Vinayak Knots & Prints D.C.I.T., Pvt. Ltd., Central Circle-2, Vs. A-26, Central Park, Gidc, Surat. Pandesara, Surat-394221. Pan No. Aamcs 4421 L Appellant/ Assessee Respondent/ Revenue

Section 133(6) were duly complied. The Assessing Officer issued show cause notice for disallowance of purchases. The assessee filed

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT vs. SIDDHI VINAYAK KNOTS & PRINTERS PVT. LTD., SURAT

In the result, all the appeals of the assessee are allowed and appeals of revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A Nos. 40, 41, 42, 43 & 115/Srt/2021 (Assessment Years 2010-11 To 2014-15) (Physical Hearing) Siddhi Vinayak Knots & Prints D.C.I.T., Pvt. Ltd., Central Circle-2, Vs. A-26, Central Park, Gidc, Surat. Pandesara, Surat-394221. Pan No. Aamcs 4421 L Appellant/ Assessee Respondent/ Revenue

Section 133(6) were duly complied. The Assessing Officer issued show cause notice for disallowance of purchases. The assessee filed

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1, BHARUCH vs. SALYA INDIA PRIVATE LIMITED, BHARUCH

In the result, the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.438/Srt/2018 (Ay 2010-11) (Hearing In Physical Court) Assistant Commissioner Of Salya India Pvt. Ltd. Income Tax, Circle-1, Ayan Apartment, Limda Vs Bharuch, 1St Floor, Hari Falia, At & P.O Kamboli, Kunj, Income Tax Office, Bharuch Pan No. Aalcs 7799 C Above Bank Of Baroda Building, Station Road, Bharuch अपीलाथ"/Appellant ""यथ" /Respondent

section 133(6) of the Act. The lender furnished required details of loan e.g. confirmation, ledger account, return of income, audited financial statement, bank statement. Though, the Assessing Officer reported contrary that required details were not furnished. The Ld. CIT(A) after considering the 15 Salya India Pvt.Ltd. confirmation audited financial statement, ledger account, return of income of lender

DHAWANI NAINESH PASTAGIA,SURAT vs. INCOME TAX OFFICER WARD 1(3)(6), SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh(Physical Hearing) Dhwani Nainesh Pastagia, I.T.O., 55, Mitrali Co-Op Housing Society, Anand Ward-1(3)(6), Vs. Mahal Road, Adajan, Surat-395009. Surat. Pan No. Arzpp 3649 Q Appellant/ Assessee Respondent/ Revenue

Section 133(6) returned unserved from some of the person and some replies not received. The Assessing Officer by taking a view that the assessee failed to furnish complete details and in absence of evidence, the commission was treated as doubtful and disallowed

GUJARAT POLYSOL CHEMICALS LIMITED LIMITED,VAPI vs. THE ASST. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, VAPI, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

section 133(6). 4. The Assessing Officer recorded that SVNIT furnished its report. The report of SVNIT is scanned by assessing officer at page-87 of assessment order. In the assessment order, SVNIT reported that assessee’s input / output ratio of material consumed about the finished goods were theoretically correct subject to the process normally employed by the assessee-company

DCIT, VAPI vs. GUJARART POLYSOL CHEMICAL LTD, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

section 133(6). 4. The Assessing Officer recorded that SVNIT furnished its report. The report of SVNIT is scanned by assessing officer at page-87 of assessment order. In the assessment order, SVNIT reported that assessee’s input / output ratio of material consumed about the finished goods were theoretically correct subject to the process normally employed by the assessee-company

ITO, WARD-3(3)(3), SURAT vs. M/S. M D HOUSE BUILD, SURAT

In the result, appeal of the Revenue is dismissed

section 133(6) of the Act, the Assessing Officer issued detailed show cause notice. The Assessing Officer recorded that no reply was furnished by assessee till the finalization of assessment order. The Assessing Officer completed the assessment on the basis of materials available on record. On the basis of ledger, the Assessing Officer made the addition of Rs.2.74 crores