THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. SH. HARESHBHAI MOHANBHAI SAKARIYA, SURAT

In the result, Revenue’s appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No.01/Srt/2021 (Ay 2010-11) It(Ss)A No.09/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) Deputy Commissioner Of Shri Dineshchandra D Income-Tax, Central Circle- Koradia, 3Room No.507, 5Th Floor, 9/10, Dayanand Society, Aayakar Bhawan, Majura B/H.Navyug College, Gate, Surat-395001 Rander Road, Surat Pan No: Acupk 3696 A Assistant Commissioner Of Vs Income-Tax, Central Circle-3, Room No.507, 5Th Floor, Aayakar Bhawan, Majura Gate, Surat-395001 Appellant / Revenue Respondent /Assessee

section 14A the assessee filed appeal before Ld. CIT(A). Before Ld. CIT(A) assessee filed detailed written submission as recorded in para- 8.2 of the order of Ld. CIT(A). Besides assessee’s other submission, submitted that disallowance made by Assessing Officer is erroneous that investment out of which exempt income earned were made out of own funds available

SHRI SABBIRBHAI DAWOODBHAI SHAIKH,SURAT vs. INCOME TAX OFFICER WARD-3(1)(4), SURAT

In the result, the ground No

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Shri Sabbirbhai Dawoodbhai Income Tax Officer, Ward- Shaikh, 3(1)(4), Anavil Business Vs 7/4539, Galemandi, Centre, Adajan, Surat- Lakkad Kot, 395009 Surat Pan : Aeqps 5688 Q Appellant / Assessee Respondent / Revenue

1. The learned C.I.T.(Appeals)-3,Surat has erred in deciding only one ground of appeal whereas the assessee had raised 11 grounds of appeal including illegal reopening the case of the assessee under section 147 of the Act. On the facts and in the circumstances of the case and as per law, the reopening of the case

INCOME TAX OFFICER, SURAT vs. THE SUTEX CO.OPERATIVE BANK LIMITED, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.780/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) The Ito, Vs. The Sutex Co-Operative Bank Ltd., Ward – 1(1)(1), 2Nd Floor, Bank Block, Surat Textile Surat Market, Ring Road, Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat2953Q (अपीलाथ" / Appellant) (""थ" / Respondent) Appellant By Shri Mukesh Jain, Sr. Dr Respondent By Shri Sapnesh Sheth, Ca Date Of Hearing 09/04/2025 Date Of Pronouncement 05/06/2025

section 250 of the Income-tax Act, 1961 (in short, ‘the Act’), dated 24.05.2024 by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short ‘CIT(A)’] for the Assessment Year (AY) 2016-17. 2. Grounds of appeal raised by the revenue are as under: “1. On the facts and circumstances of the case

SHRI VIJAY CHAMPAK PATEL,SURAT vs. THE INCOME TAX OFFICER, WARD-6(4), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.281/Ahd/2016 ("नधा"रणवष" / Assessment Year: 2011-12) Vijay Champak Patel, Vs. Income Tax Officer, Pachhlu Faliyu, Near Water Ward-6(4), Surat Tank, Bharthana, Vesu, Surat

section 54F of the Act. As such, the deduction of Rs.52,04,000/- claimed by the assessee u/s 54F is disallowed and added to the total income of 3 Vijay Champak Patel Assessment Year: 2011-12 the assessee. By claiming incorrect deduction, the assessee has furnished inaccurate particulars of his income, for which, penalty proceedings u/s. 271(1)(c) r.w.s

JAYSHRI GOPALLAL MAHARAJSHRINI SURAT SRUSTI TRUST,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

Section 12A(1)(b). In view of the above, the grounds of appeal are DISMISSED. 6. In the result, the appeal is dismissed. Order passed u/s 250 r.w.s. 251 of the Act.” 5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) disallowing

KHODIYAR MOTORS,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(3), SURAT

In the result, the appeal of the assessee is allowed

Bench: Shrisanjay Garg & Shri Bijayananda Prusethआयकरअपीलसं./Ita No.729/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Khodiyar Motors Vs. Dcit, 1-2-3, Green Park, Surat Circle - 2(3), Navsari Road, Unn-Sachin, Surat Surat - 394230 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaffk4882M (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रतीकीओरसे/Appellant By Shri P. M. Jagasheth, Ca राज"कीओरसे /Respondent By Shri Ajay Uke, Sr. Dr सुनवाई की तारीख/Date Of Hearing 14/08/2025 उद्घोषणा की तारीख/Date Of Pronouncement 11/11/2025

250 of the Income-tax Act, 1961 (in short, ‘the Act’) dated 28.05.2024 by the National Faceless Appeal Centre, Delhi/Commissioner of Income-tax (Appeals) [in short ‘CIT(A)’] for the assessment year (AY) 2013-14. 2. The grounds of appeal raised by the assessee are as under: “(1) On the facts and in the circumstances of the case as well

SANTOSH SINGH HUKAM SINGH KARNAWAT,SURAT vs. ITO, WARD 2(3)(8), SURAT

In the result, the appeal filed by the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

250 of the Income Tax Act, 1961 is bad with regards to the facts and circumstances of the case. 2. The learned Commissioner of Income Tax (Appeals) has erred in levying penalty u/s. 271(1)(c) of the Income Tax Act, 1961 on addition made of 5% of total purchase value to the tune of Rs. 43,83,431/- from

THE UDHNA CITIZEN CO OPP. BANK LIMITED ,NOW MERGE WITH KALUPUR COMMERCIAL CO.OP. BANK LTD,AHMEDABAD vs. I.T.O TDS -2 , SURAT

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

Bench: Shri Sanjay Gargshri Narendra Prasad Sinha

250 of the IT Act dt. 03/03/2025 towards the Appeal filed by the Assessee against the order passed u/s 201(1) r.w.s 201(1A) of the IT Act, 1961 for Asstt.Year 2013-14. 2. The Learned Addl./Jt. CIT(A)-1, Mumbai has erred in confirming the demand raised of Rs. 4,77,114 u/s 201 r.w.s

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

250 of the Income-tax Act, 1961 (in short, ‘the Act’), dated 31.12.2024, by the Commissioner of Income-tax (Appeal), Addl/JCIT(A) - 9, Mumbai [in short ‘CIT(A)’] for the Assessment Year (AY) 2023-24. 2. Grounds of appeal raised by the assessee are as under: “1. On the facts and circumstances of the case as well

BEGANI DYEING MILLS PVT.LTD.,,SURAT vs. THE PR.CIT., CIRCLE-1,, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.404/Srt/2019 िनधा"रण वष"/Assessment Year: 2012-13 M/S.Begani Dyeing Mills Pvt. Vs The Principal Ltd., Commissioner Of Income 11 To 15, Tara Industrial Estate, Tax-1, Surat. Opp. Gangdhi Kutir, Udhna Magdalla Road, Surat – 395007. [Pan: Aaacb 9634 L] अपीलाथ" / Appellant ""थ"/Respondent िनधा"रतीकीओर से /Assessee By Shri Rasesh Shah – Ar राज"कीओर से /Revenue By Shri S.T.Bidari – Cit(Dr) सुनवाई की तारीख/ Date Of Hearing: 22.03.2021 उद्घोषणा की तारीख/Pronouncement On: 22.03.2021 आदेश /O R D E R Per Pawan Singh: 1. This Appeal Filed By The Assessee Is Directed Against The Order Of Learned Principal Commissioner Of Income Tax, Surat-1, Surat Hereinafter Referred As “Ld. Pcit” , Passed Under Section 263 Dated 07.12.2018 For The A.Y.2012-13. The Assessee Raised The Following Grounds Of Appeal: “1. On The Facts & In Circumstances Of The Case As Well As Law On The Subject, The Learned Pr. Cit Has Erred In Passing The Order U/S . 263 By Invoking Of Section 263 Of The Act, Although The Assessment Order Passed U/S. 147 R.W.S 143(3) Of The I. T. Act, 1961 Was Neither Erroneous Nor Prejudicial To The Interest Of The Revenue.

250/-, thus, total disallowance worked out at Rs.2,35,039/- in assessment order dated 30.01.2015. The case was again reopened under section 147 of the Act on the issue of deduction of section 80IA of the Act. The AO after completing required formality and giving opportunity made disallowance of Rs.3,73,098/- under section 80IA of the Act in assessment

THE ACIT, CIRCLE-2,, BHARUCH vs. SHRI AMRUTLAL BABALDAS PATEL,, ANKLESHWAR

In the result, ground No. 2 of appeal raised by the revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) The Assistant Commissioner Of Shri Amrutlal Babaldas Patel, Income Tax, Circle-2, Vs I) A/96, Jalkamal Apartment, Bharuch. Near Manav Mandir, Gidc, Ankleshwar, Gujarat – 392002. Ii) 32, Surdhara Bunglow, Near Sai Hospital, Thaltej, Ahmedabad. Pan: Aebpp 2999 E Appellant/ Revenue Respondent/ Assessee Assessee By Shri Jimit Shah – Ca Revenue By Shri Sita Ram Meena – Sr.Dr 22/02/2022 Date Of Hearing 12/05/2022 Date Of Pronouncement Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. This Appeal By The Revenue Is Directed Against Order Of Ld. Commissioner Of Income Tax (Appeals)-3, Vadodara Dated 29.04.2016 For The A.Y. 2012-13. The Revenue Raised The Following Grounds Of Appeal: “1. On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(Appeals) Erred In Deleting The Disallowance Of Development Expenses Of Rs.1,79,19,550/- Without Appreciating That The Purported Expenditure Was On Account Of Contractual Payment To Four Related Parties. 1.1 The Ld. Cit(A) Erred In Not Appreciating That The Payment Of The Labour Expenses To The Contractors Were Held Up For Three Years Of Sale Of Land & Payment Was Made In The Calendar Year 2015 Only After The A.O. Sought Proof Of Payment. 1.2 The Ld. Cit(A) Erred In Not Appreciating The Fact That Contractors Of The Assessee Have Also Held Up Payment To Their Creditors For A Long Span Of Three Years, Which Is Not Acceptable On Any Surmise. Shri Amrutlal Babaldas Patel

section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the Revenue is directed against order of ld. Commissioner of Income Tax (Appeals)-3, Vadodara dated 29.04.2016 for the A.Y. 2012-13. The Revenue raised the following grounds of appeal: “1. On the facts and in the circumstances of the case

KIRTIKUMAR NAGINDAS SHAH,SURAT vs. INCOME TAX OFFICER, WARD 2(3)(6), SURAT

In the result, ground No.2 raised by the assessee is allowed

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.535/Srt/2023 Assessment Year: (2014-15) (Physical Hearing) Kiritkumar Nagindas Shah, Vs. The Ito, A-1103, Regent Residency, Near Ward – 2(3)(6), Saurabh Society, Pal, Surat Surat – 395009, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Anjps9031P (Appellant) (Respondent)

1,13,250 3. Dividend income 23 However, you have not furnished any separate account for expenses incurred for earring of exempt income. Hence, section 14 of the I.T. Act attracts in your case. Therefore, you are asked to furnish explanation as to why expenditure incurred of Rs.7,56,965/- for earning exempt income should not be disallowed