ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. ASSTT. COMMISSIONER OF INCOME TAX., BHARUCH

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

204/- while computing eligible profits for the purpose of deduction under section 80IA on the ground that the appellant is not entitled to deduction under section 80IA. ITA 2018/Ahd/2014 Enviro Technology Ltd. Vs ACIT &7Ors. appeals The appellant craves, to consider each of the above grounds of appeal without prejudice to each other and craves leave to add, alter, delete

M/S SUMILON INDUSTRIES PVT. LTD.,SURAT vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX - 1, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.87/Srt/2022 ("नधा"रणवष" / Assessment Year: (2017-18) (Physical Court Hearing) M/S Sumilon Industries Pvt. Principal Commissioner Of Ltd. 6-121-A, Vairagini Wadi, Income-Tax-1, Aaykar Bhavan, Vs. Delhi Gate, Surat-395003 Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadcs3567 L (Appellant) (Respondent) िनधा"रती की ओर से /Assessee By : Shri Mukund Bakshi, C.A राज"व क" ओर से /Respondent By: Shri Ashok B. Koli, Cit-D.R

disallowance under section 14A could not be made. In the process tribunal relied on the decision of Division Bench of Punjab and Haryana High Court in the case of CIT v. Winsome Textile Industries Ltd. [2009] 319 ITR 204

PRAGATI GLASS PVT. LTD.,,BHARUCH vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1 , BHARUCH

In the result, ground No. 4 is allowed

Bench: Shri Pawan Singh () & Dr. Arjun Lal Saini () Assessment Year: 2013-14 Pragati Glass Private Limited, Asst. Commissioner Of Income Tax, Kharach, Kosamba (R.S), District Vs. Cir. 1, Bharuch-394120 Station Road, Bharuch-392001. Pan No. Aabcp 7377 H Appellant Respondent

section 14A. The Ld. AR of the assessee submits that during the relevant period for assessment year under consideration the assessee has not earned any exempt income. The Assessing Officer made disallowance by taking view and the assessee has made investment of Rs.1.69 crores and incurred expenses interest expenses of Rs.2.93 crores. The Ld. AR submits that reserve and surplus

SACH ELECTRO MECH PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(1)(2),, SURAT

In the result ground No. 4 of the appeal is allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr Arjun Lal Saini, Hon'Ble(Virtual Court - Virtual Hearing) आ.अ.सं./I.T.A No.262/Ahd/2017 "नधा"रण वष"/Assessment Year: 2013-14 Sach Electro Mech Pvt. Ltd., V The Income Tax Officer, C/2, Maheshwari Apartment, S Ward-2(1)(2), Surat. Timaliyawad, Nanpura, . Surat – 395 001. [Pan: Aaics 8963 M] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Manish J.Shah – Ar राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr

disallowance under Section 14A of the Act 6 Sach Electro Mech Pvt. Ltd., Vs. ITO, Ward-2(1)(2), Surat ITA No.262/AHD/2017 for A.Y. 2013-14 when no dividend income had been earned by the Assessee in the relevant AY? The Court referred to the decision of this Court in Maxopp Investment Ltd's. case (supra) and to the decision

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

204 ITR 856/[1994] 72 Taxman 223 (Ker.), the Kerala High Court has held as under: '4. The effect of Section 80AB is that, for the purpose of computing the deduction under Section 80L, the amount of income of that nature as computed in accordance with the provisions of the Act shall alone be deemed to be the amount

BALMUKUND M VAISHNAV,SURAT vs. INCOME TAX OFFICER, WARD-2(3)(7), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.204/Srt/2019 Assessment Year: (2013-14) (Physical Hearing) The Ito, Ward-2(3)(7), Vs. Balmukund M. Vaishnav, Surat. 5B/1054, Ramnanth Mahadev Ni Sheri, Haripura, Surat – 395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aokpv5065Q (Appellant) (Respondent) आयकर अपील सं./Ita No.205/Srt/2019 Assessment Year: (2013-14) Balmukund M. Vaishnav, Vs. The Ito, Ward-2(3)(7), 5B/1054, Ramnanth Mahadev Ni Surat. Sheri, Haripura, Surat – 395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aokpv5065Q (Appellant) (Respondent)

section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 23.03.2016. ITA Nos. 204 &205/SRT/2019 Balmukund M. Vaishnav 2. Since, the issue involved in these cross appeals are common and identical; therefore, these appeals have been clubbed and heard together and a consolidated order is being passed for the sake of convenience and brevity

AALIDHRA TEXFAB PRIVATE LIMITED,SURAT vs. CPC CURRENT JURISDICTION- DCIT,CIRCLE 1(1)(1),SURAT, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri T. R. Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.153/Srt/2025 Assessment Year: (2023-24) (Hybrid Hearing) Aalidhara Texfab Pvt. Ltd., Vs. Cpc, 2, Functional Estate, New Industrial Current Jurisdiction: Estate, Road No.6, Udhna, Surat – Dcit, Circle – 1(1)(1), 394210, Gujarat Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aasca8215E (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/07/2025 Date Of Pronouncement 19/08/2025

204. 5. On the other hand, learned Senior Departmental Representative (ld. Sr. DR) of the revenue relied on the orders of CPC and CIT(A). 6. We have heard both the parties and perused the materials available on record. We have also deliberated upon the decision relied upon by the ld. AR. The AO-CPC processed the return filed

MUKESH ARVINDLAL VAKHARIA,SURAT vs. ITO, WARD 2(3)(3), SURAT

Appeal is partly allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.491/Srt/2019 "नधा"रण वष"/Assessment Year: (2014-15) (Physical Hearing) Mukesh Arvindlal Vakharia, Vs. The Ito, Ward-2(3)(3), C/O Arvind Silk Mills, Om Baug, Ashvini Surat. Kumar Road, Surat - 395006. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpv1682L

204 (Mumbai - Trib.) held that where Assessing Officer rejected assessee's claim for deduction under section 54F of the Act, on ground that at time of sale of capital asset, assessee was owner of more than one residential house properties, in view of fact that one residential property was co-jointly owned in name of assessee and his wife

ITO, WARD-3(2)(4), SURAT vs. LATE KHUSHMANBHAI CHNDUBHAI PATEL-HUF, L/H. JIGISHA PATEL, SURAT

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) I.T.O. Late Khushmanbhai Chandubhai Patel Ward-3(2)(4), (Huf), Vs. Surat. L/H Jigisha Patel, Opp. Nityanandeshwar Mahadev Temple, Nanived, Katargam, Surat-395004. Pan : Aaihp 4025 L Appellant Respondednt

Section 54F of the Act of Rs. 12,04,120/- and remaining amount of Rs. 42,07,647/- ( 54,11,928 – 1,204,120) was disallowed

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

Section 263 of the Act, as the same was directly or indirectly was a part of issue in appeal before CIT(A). 10. The reply of assessee was not accepted by the ld. Pr.CIT. The ld. Pr.CIT held that the Assessing Officer has disallowed the concept of mutuality as claimed by assessee, therefore, he was duty bound to disallow certain

MAHESHBHAI DAHYABHAI AHIR,SURAT vs. ITO, WARD-2(3)(1), SURAT

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

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

204/- the Assessing Officer applied the provisions of Section 44AD of the Act and estimated the net profit @ 8% of the total contractual receipts and added the same as undisclosed income of the assessee. However, with respect to rental receipts amounting to Rs. 1,20,71,394/- on renting out of Plant and Machinery, the Assessing Officer treated the entire

ITO (EXEMPTION), WARD, SURAT vs. GUJARAT HIRA BOURSE, SURAT

In the result, appeals filed by the Revenue (in ITA No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

disallowance is called for. 24. Now, we deal with the alternative argument of the ld Counsel, in respect of principle of mutuality. It is submitted by ld Counsel that a development of infrastructure project of gem and jewellery Park is being carried out from the funds of its members only and there is complete identity between contributor and participator

ITO (EXEMPTION) WARD, SURAT vs. GUJARAT HIRA BOURSE, SURAT

In the result, appeals filed by the Revenue (in ITA No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

disallowance is called for. 24. Now, we deal with the alternative argument of the ld Counsel, in respect of principle of mutuality. It is submitted by ld Counsel that a development of infrastructure project of gem and jewellery Park is being carried out from the funds of its members only and there is complete identity between contributor and participator