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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

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

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

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

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

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

253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing in 49,00,000 -1,,000,000 50,000,000 40,655,000 9,345,000 2028 Total(Rs) 504,960,000 4,960,000 500,000,000 446,330,000 53,670,000 11. On perusal of the aforesaid

SHRI PRAKASH F.SINGH,,VAPI vs. THE ITO, WARD-7,, VAPI

In the result, appeals of the Assessees (in ITA No

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.618/Srt/2018 (िनधा"रणवष" / Assessment Year: (2011-12) (Virtual Court Hearing) Prakash F Singh, The Income Tax Officer, V Ward-7, Room No.810, 8Th Floor, Rbl, 63/751, Chanod Colony, Gidc, S. Vapi-396195 Fortune Square-Ii, Vapi Daman Road, Chala, Vapi-396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Asnps 4835N (Assessee) (Respondent)

253 (Bombay), has held the same ratio. The summary of the judgment of the Hon`ble Bombay High Court, is reproduced below: “Summary: 160. From all the judgments we have quoted about the scope of penalty proceedings under section 271 (1)(c), read with section 274, of the IT Act, we gather the following: (a) Penalty under section 271(1

SHRI GUFRAN AHMED CHAUDHARI,,VALSAD vs. THE INCOME TAX OFFICER, VAPI WARD-1,, VAPI

In the result, appeals of the Assessees (in ITA No

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.618/Srt/2018 (िनधा"रणवष" / Assessment Year: (2011-12) (Virtual Court Hearing) Prakash F Singh, The Income Tax Officer, V Ward-7, Room No.810, 8Th Floor, Rbl, 63/751, Chanod Colony, Gidc, S. Vapi-396195 Fortune Square-Ii, Vapi Daman Road, Chala, Vapi-396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.:Asnps 4835N (Assessee) (Respondent)

253 (Bombay), has held the same ratio. The summary of the judgment of the Hon`ble Bombay High Court, is reproduced below: “Summary: 160. From all the judgments we have quoted about the scope of penalty proceedings under section 271 (1)(c), read with section 274, of the IT Act, we gather the following: (a) Penalty under section 271(1

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

disallowed if they are made in cash in the sums exceeding the amount specified under section 40A(3). We have earlier observed that rule 6DD has to be read along with S. D. Mineral Pvt. Ltd. v. JCIT-Circle-4 (OSD) Surat /I.T.A.No. 554/SRT/2019/A.Y. 09-10 Page 11 of 16 section 40A(3). The rule also contemplates payments made

S J P CONSTRUCTIONS PRIVATE LIMITED,SURAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(2), SURAT

In the result, ground No. 1 to 3 of the appeal are allowed for statistical purpose

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.430/Srt/2023 (Ay 2015-16) (Hearing In Physical Court) S J P Constructions Pvt. Ltd. Deputy Commissioner Of E-3300, Radhakrishna Textile Income Tax, Circle-2(1)(2) Vs Market, Ring Road, Surat- Surat, Aaykar Bhavan, 395002 Income Tax Colony, Pan No. Aajcs 4313 C Athwa, Surat-395001 अपीलाथ"/Appellant ""थ" /Respondent

D] General:-  The appellant reserve rights to add alter or delete any portion of this appeal before its conclusion.  This appeal is in time and may allowed in full.  A detailed paper book will be filed at the time of hearing.” 2. Brief facts of the case are that assessee is a company, engaged in the business of purchase, sales

MOULIMANI IMPEX PVT LTD,MUMBAI vs. INCOME TAX OFFICER -1(1)(3), SURAT, SURAT

In the result, appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Pruseth

D E R PER BIJAYANANDA PRUSETH, AM: These four appeals emanate from the orders dated 23.12.2024 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short “CIT(A)”], for the assessment years (AYs) 2009-10 to 2011-12. Since the facts are common and grounds of appeal are almost identical except variance of amounts, with

MOULIMANI IMPEX PVT LTD,MUMBAI vs. INCOME TAX OFFICER- 1(1)(3), SURAT, SURAT

In the result, appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Pruseth

D E R PER BIJAYANANDA PRUSETH, AM: These four appeals emanate from the orders dated 23.12.2024 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short “CIT(A)”], for the assessment years (AYs) 2009-10 to 2011-12. Since the facts are common and grounds of appeal are almost identical except variance of amounts, with

MOULIMANI IMPEX PVT LTD,MUMBAI vs. INCOME TAX OFFICER -1(1)(3), SURAT, SURAT

In the result, appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Pruseth

D E R PER BIJAYANANDA PRUSETH, AM: These four appeals emanate from the orders dated 23.12.2024 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short “CIT(A)”], for the assessment years (AYs) 2009-10 to 2011-12. Since the facts are common and grounds of appeal are almost identical except variance of amounts, with

MOULIMANI IMPEX PVT LTD,MUMBAI vs. INCOME TAX OFFICER- 1(1)(3), SURAT, SURAT

In the result, appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Pruseth

D E R PER BIJAYANANDA PRUSETH, AM: These four appeals emanate from the orders dated 23.12.2024 passed by the Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [in short “CIT(A)”], for the assessment years (AYs) 2009-10 to 2011-12. Since the facts are common and grounds of appeal are almost identical except variance of amounts, with

VIHAN VIBHAG CREDIT CO-OPERATIVE SOCIETY LTD.,SURAT vs. ITO, WARD 2(2)(5), SURAT

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.707/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Vihan Vibhag Credit Co-Operative Vs. Ito, Society Ltd., Ward – 2(2)(5), At & Po: Vihan, Tal – Kamrej, Surat Tapi – 394320, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabav5113F (Appellant) (Respondent) Appellant By Shri Akshay M. Modi, Ca Respondent By Ms Neerja Sharma, Sr. Dr Date Of Hearing 17/11/2025 Date Of Pronouncement 27/11/2025

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal of appeal before the Tribunal. The appellant submitted that Mr. Prativ Patel, tax consultant, was appointed to handle tax matter including filing return of income. The e-mail Id, i.e., hhhkabrawala@gmail.com of the earlier tax consultant was registered in the ITBA

M/S NILKANTH STONE INDUSTRIES, VALSAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, VALSAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.386/Srt/2018 "नधा"रण वष"/Assessment Year: 2014-15 M/S Nilkanth Stone Industries, Vs. The Principal Commissioner Shop No.A-1/2/3, Nilkanth Of Income Tax, Valsad. Residency, B/H Old Jakarta Nagar, Tithal Road, Valsad. [Pan: Aajfn 5653 K] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओर से /Assessee By Shri Surji Chheda - Ca राज"वक"ओर से /Revenue By Shri Ritesh Mishra – Cit-Dr सुनवाई की तारीख/ Date Of Hearing: 08.04.2021 उ"घोषणा क" तार"ख/Pronouncement On: 27.05.2021 आदेश /O R D E R Per Pawan Singh, Judicial Memeber: 1. This Appeal Under Section 253 Of Income-Tax Act (Act) By The Assessee Is Directed Against The Order Of Ld. Principal Commissioner Of Income Tax, Valsad Hereinafter Referred As “Ld. Pcit” Passed Under Section 263 Of Income-Tax Act (Act) Dated 27.03.2018, For The Assessment Year (Ay) 2014-15. The Assessee Vide His Application Dated 16.08.2018 Following Concise Grounds Of Appeal: “1. In The Facts & In The Circumstances Of The Case, The Learned Cit Has Erred In Initiation Of Proceedings U/S 263 Of The Income Tax Act, 1961 & Which Was Without Jurisdiction & The Cit Erred In Holding That The Assessment Order Was Erroneous & Prejudicial To The Interest Of Revenue On All Issues Discussed In Revision Order & Has Erred In Setting It Aside For Fresh

D E R PER PAWAN SINGH, JUDICIAL MEMEBER: 1. This appeal under section 253 of Income-tax Act (Act) by the assessee is directed against the order of ld. Principal Commissioner of Income Tax, Valsad hereinafter referred as “ld. PCIT” passed under section 263 of Income-tax Act (Act) dated 27.03.2018, for the assessment year (AY) 2014-15. The Assessee

PARAG NARESHBHAI MEHTA PROP. OF DEEKSHA TRADING ,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.

D E R PER DR. A. L. SAINI, AM: This is bunch of eight appeals, pertaining to Assessment Year (AY) 2013- 14, filed by the different assessees and Revenue, are directed against the separate orders passed by the Learned Commissioner of Income Tax (Appeals), Surat which in turn arise out of separate assessment orders passed by the Assessing Officer under

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.

D E R PER DR. A. L. SAINI, AM: This is bunch of eight appeals, pertaining to Assessment Year (AY) 2013- 14, filed by the different assessees and Revenue, are directed against the separate orders passed by the Learned Commissioner of Income Tax (Appeals), Surat which in turn arise out of separate assessment orders passed by the Assessing Officer under