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

RAJLAXMI POLYMERS PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, SURAT

In the result the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Court Hearing) Vs Rajlaxmi Polymers Pvt Ltd, Income Tax Officer, 5024,World Trade Centre, Ward -2 (1)(1), Near Udhna Darwaja, Surat, Ring Road, Surat-395002 Pan : Aabcr 1210 M Assessee Revenue Assessee By Sh. Sapnesh Sheth Ca/Ar Revenue By Ms. Anupma Singla Sr Dr Date Of Hearing 17/12/2020 Date Of Pronouncement 21/12/2020

253 of Income-tax Act (Act) is directed against the order of the learned Commissioner of Income Tax (Appeals)-2, Surat, [in short “learned Commissioner (Appeals)”] dated 14.07.2016 pertaining to Assessment Years (AYs) 2010-11. 2. Brief facts of the case as gathered from the order of lower authorities are that the assessee is a company engaged in the business

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

disallowance of deduction of Rs.23,87,143/- as interest received u/s 80P(2)(d) of the I.T. Act. 2. It is therefore prayed that above addition made by assessing officer and confirmed by Commissioner of Income-tax (Appeals), NFAC may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before

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

disallowance of deduction of Rs.23,87,143/- as interest received u/s 80P(2)(d) of the I.T. Act. 2. It is therefore prayed that above addition made by assessing officer and confirmed by Commissioner of Income-tax (Appeals), NFAC may please be deleted. 3. Appellant craves leave to add, alter or delete any ground(s) either before

M/S. VIPUL PARK,TAPI vs. THE DCIT,CENT.CIR.-2, 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.1195/Ahd/2013 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Vipul Park, Vs. The Deputy Commissioner Of Andhar Wadi Road, Income Tax, Central Circle-2, Vyara, Dist. Tapi – 394 650. Surat. [Pan: Aalfm 3438 P] अपीलाथ" / Appellant ""यथ"/Respondent

2). This way, the Assessing Officer worked out excess profit shown in the 80IB(10) project @46.28% (in terms of percentage) and worked out the unreasonable profit in terms of quantum at Rs.28,76,770/-. The Assessing Officer has done this over and above the entire disallowance of deduction u/s.80IB(10) at Rs.39,69,791/-. The disallowance of unreasonable profit

THE ASSTT. COMMISSIONER OF INCOME TAX, VAPI CIRCLE,, VAPI vs. M/S. MITSU LIMITED,, DAMAN

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

disallowed the same on estimate basis without any justification. Hence, same are directed to be allowed. This ground of appeal is therefore, allowed. 8. Ground No. 5 & 6 : states that Ld. CIT (A) has erred in confirming the action of the AO in not considering the claim of the assessee that the entire receipt to the tune of Rs.23

M/S. MITSU PRIVATE LIMITED,,VAPI vs. THE ACIT, VAPI CIRCLE,, VAPI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

disallowed the same on estimate basis without any justification. Hence, same are directed to be allowed. This ground of appeal is therefore, allowed. 8. Ground No. 5 & 6 : states that Ld. CIT (A) has erred in confirming the action of the AO in not considering the claim of the assessee that the entire receipt to the tune of Rs.23

ITO, WARD-1(1)(3), SURAT vs. M/S. HI-CHOICE PROCESSORS P. LTD, SURAT

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.98/Srt/2020 "नधा"रण वष"/Assessment Year: (2012-13) (Physical Hearing) Income Tax Officer, M/S. Hi-Choice Processors Pvt. Ward-1(1)(3), Room No.113, Vs. Ltd., 264, Gidc, Sachin, Surat- Aaykar Bhavan, Majura Gate, Surat- 394230. 395002 (""थ" /Respondent) (अपीलाथ" /Appellant) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaach7062E िनधा"रती की ओर से /Appellant By Shri Ashok B. Koli, Cit(Dr) राज"व क" ओर से /Respondent By Shri Mehul Shah, Ca सुनवाई की तारीख/Date Of Hearing 31/03/2023 घोषणा की तारीख/Date Of Pronouncement 18/04/2023

Section 45- IA of the RBI Act, 1934. Further, on perusal of the Audit Report of these companies, it can be seen that they have followed all the RBI guidelines and prudential norms issued by RBI as certified by the auditors in the notes to accounts. It is to be appreciated that the status is “Active-Compliant” and not just

HI-TECH MARKETING,SURAT vs. INCOME TAX OFFICER WARD 3(1)(4), SURAT

In the result, the Ground no

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainihi-Tech Marketing, The Income – Tax Officer, 114, Belgium Tower, Old Ward -3(1)(4), Surat Linear Bus Stop, Station Road, Surat – 395 003. Vs Pan : Aabfh5705N Appellant Respondednt

253 of Income-tax Act is directed against the order of the ld. Commissioner of Income Tax (Appeals)-3, [in short “the CIT(A)”], Surat dated 08/06/2017, which in turn arises from assessment order dated 27/10/2015 passed under section (u/s.)143(3) r.w.s 147 of Income Tax Act [in short “the Act”] for the Assessment Year (AY) 2010- 11. 2

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

2. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty of Rs. 1,34,591/-under section 271(1)(c) of Income Tax Act, 1961 without passing speaking order. Ground 3. On the facts and circumstances of the case and law, 3 the Ld. CIT(A) failed to consider that

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

2. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty of Rs. 1,34,591/-under section 271(1)(c) of Income Tax Act, 1961 without passing speaking order. Ground 3. On the facts and circumstances of the case and law, 3 the Ld. CIT(A) failed to consider that

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

2. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty of Rs. 1,34,591/-under section 271(1)(c) of Income Tax Act, 1961 without passing speaking order. Ground 3. On the facts and circumstances of the case and law, 3 the Ld. CIT(A) failed to consider that

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

2. On the facts and circumstances of the case and law, the Ld. CIT(A) erred in confirming penalty of Rs. 1,34,591/-under section 271(1)(c) of Income Tax Act, 1961 without passing speaking order. Ground 3. On the facts and circumstances of the case and law, 3 the Ld. CIT(A) failed to consider that

BHOJALRAM URBAN CO OP CREDIT SOCIETY LTD.,SURAT vs. ITO, WARD 3(3)(1), SURAT

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

disallowance was not made in the\noriginal assessment order.\n3. It is therefore prayed that the above made by Assessing Officer and\nconfirmed by Commissioner of Income-tax (A0ppeals) may please be deleted.\n4. Appellant craves leave to add, alter or delete any ground(s) either before\nor in the course of hearing of the appeal\"\n3. At the outset

MADHVI AJITKUMAR RANKA ,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI

In the result, the appeal is allowed for statistical purposes

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.124/Srt/2025 Assessment Year: (2017-18) (Hybrid Hearing) Madhvi Ajitkumar Ranka, Vs. Acit, 88, Sunder Nagar, Jamalpore, Navsari Circle, Navsari – 396445 Navsari "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahfpr5791K (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 01/09/2025 Date Of Pronouncement 26/11/2025

2) Based on the facts of the case, both lower authorities erred in taxing the gifts to the tune of Rs.42,61,237/-which were received in earlier assessment years u/s 68 of the Act. ITA No.124/SRT/2025/AY 2017-18 Madhvi Ajitkumar Ranka 3) Based on the facts and circumstances of the case as well as law on the subject

YOGENDRARAJ U. SINGHVI,MUMBAI vs. INCOME TAX OFFICER, WARD-2(3)(8), SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.459/Srt/2023 (Ay 2007-08) (Hearing In Hybrid Mode) Yogendra Raj U Singhvi, Income Tax Officer-2(3)(8) Cts, 95/4/B-3-4/590, Aaykar Bhavan, Majura Gate, Vs Village Dindoshi, Surat-395001 Oberoi Garden City, Flat No. 3902, Floor C-Wing, Meter Exquisite, Mumbai. Pan : Anjps 9745 G अपीलाथ"/Appellant ""थ" /Respondent

section 143(3) rws 147 dated 09.03.2015 made addition of Rs. 7.15 Crore on account of bogus purchases, which was 100% of the disputed purchases. On appeal before ld CIT(A), the addition was restricted to 5% of entire turnover shown in the profit and loss account. However, on further appeal before, Tribunal the disallowances / additions were restricted

NY GREEN ENERGY PRIVATE LIMITED FORMELY KNOW AS SUNKON ENERGY PVT LTD,SURAT vs. DCIT CIRCLE 2(1)(1), SURAT

In the result, appeal of the assessee is allowed

Bench: MS SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)

2 115JAA Erroneously disallowed On the facts and circumstances of the eligible MAT credit case as well as law on the mater, the bought forward CIT(A) has erred in disallowing MAT credit bought forward as per section 115JAA(5) of the Act, which explicitly states that MAT credit is respect of brought forward tax credit shall be allowable

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

section 271(1)(c) of the Act. 17. The penalty levied u/s.271(1)(c) of the Act is based on the quantum addition of Rs.38,83,253/- treated as bogus purchases. In the quantum appeal, the Tribunal in ITA No.612/SRT/2025 (supra), decided above, has held that the purchases cannot be disallowed in entirety and restricted the addition