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

3 relates to interest disallowances. The Ld. AR for the assessee at the beginning of hearing apprised about the fact that order of Ld.CIT(A) is ex parte and that the assessee has raised a specific ground against such ex parte order passed by Ld.CIT(A). The Ld.AR for the assessee instead of showing reasonable cause for non-filing written

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

253 ITR 749 [2002] 121 Taxman 43 (Guj), we find no fault in the findings of Ld. CIT (A). Accordingly, same is upheld. Consequently, this ground is dismissed. 68. Ground No. 3 states that Ld. CIT (A) has erred in holding that expenditure incurred of Rs.1,43,200 on registration of trademark and reviewing the draft technology agreement was revenue

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

253 ITR 749 [2002] 121 Taxman 43 (Guj), we find no fault in the findings of Ld. CIT (A). Accordingly, same is upheld. Consequently, this ground is dismissed. 68. Ground No. 3 states that Ld. CIT (A) has erred in holding that expenditure incurred of Rs.1,43,200 on registration of trademark and reviewing the draft technology agreement was revenue

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

3) of Income Tax Act, 1961 (`the Act') on\n14.11.2019. The assessee has raised the following grounds of appeal:-\n\"1. On the facts and circumstances of the case as well as law on the subject,\nthe Commissioner of Income Tax(A), NFAC has erred in confirming the action\nof AO in adding interest income of Rs.15,494/- received from

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

253(3) of the Act. The assessee has filed an affidavit for condonation of delay in filing of appeal before the Tribunal. It has been stated that notices of hearing were issued to the wrong e-mail Id, i.e., ‘moulimaniImpexpl@gmail.com’ instead of ‘gandhi.himanshu92@yahoo.in’, which was mentioned in Form 35. The CIT(A) passed order on 23.12.2024 and due date

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

253(3) of the Act. The assessee has filed an affidavit for condonation of delay in filing of appeal before the Tribunal. It has been stated that notices of hearing were issued to the wrong e-mail Id, i.e., ‘moulimaniImpexpl@gmail.com’ instead of ‘gandhi.himanshu92@yahoo.in’, which was mentioned in Form 35. The CIT(A) passed order on 23.12.2024 and due date

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

253(3) of the Act. The assessee has filed an affidavit for condonation of delay in filing of appeal before the Tribunal. It has been stated that notices of hearing were issued to the wrong e-mail Id, i.e., ‘moulimaniImpexpl@gmail.com’ instead of ‘gandhi.himanshu92@yahoo.in’, which was mentioned in Form 35. The CIT(A) passed order on 23.12.2024 and due date

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

253(3) of the Act. The assessee has filed an affidavit for condonation of delay in filing of appeal before the Tribunal. It has been stated that notices of hearing were issued to the wrong e-mail Id, i.e., ‘moulimaniImpexpl@gmail.com’ instead of ‘gandhi.himanshu92@yahoo.in’, which was mentioned in Form 35. The CIT(A) passed order on 23.12.2024 and due date

MANGHARAM MOOLCHAND VERMA,SURAT vs. ITO, WARD-1(3)(3), SURAT

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

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकरअपीलसं./Ita No.765/Srt/2024 Assessment Year: (2015-16) (Hybrid Hearing) Mangharam Moolchand Verma Vs. Ito, 703, Smita Park, Sarela Wadi, Ward - 1(3)(3), Ghod Dod Road, Surat – 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abcpv1629D (Appellant) (Respondent) Appellant By Shri Mehul Shah, Ca Respondent By Ms. Jayashree Thakur, Sr. Dr Date Of Hearing 09/06/2025 Date Of Pronouncement 11/08/2025

disallowance made by the Assessing Officer and confirmed by CIT(A) may please be deleted. 4. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of the hearing of the appeal.” 3. The appeal filed by the assessee is barred by 42 days in terms of provisions of section 253

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

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing appeal before the Tribunal. In the affidavit, the assessee submitted that he had no knowledge of Income-tax law. He appointed Mr. Bhadresh Soni, tax consultant, who looked after his tax matter since past many years. His tax consultant informed him that refund

DHARMESH DAMJIBHAI PATOLIYA,SURAT vs. ITO, WARD2(2)(1), SURAT

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

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.487/Srt/2024 Assessment Year: (2014-15) (Hybrid Hearing) Dharmesh Damjibhai Patoliya Vs. Ito, 101 Gandamaya Apartment Ward – 2(2)(1), Matrukrupa Society, Kamrej Surat Charrasta Opp. Azim Hospital, Tal: Kamrej, Surat-395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahzpp1276F (Appellant) (Respondent) Appellant By Shri P.M. Jagasheth, Ca Respondent By Ms. Neerja Sharma, Sr. Dr Date Of Hearing 05/06/2025 Date Of Pronouncement 17/07/2025

disallowing of interest expenses u/s 40(a)(ia) of the Income-tax Act, 1961. ITA No.487/SRT/2024/AY.2014-15 Dharmesh D Patoliya 2. On the facts and circumstances of the case as well as law on the ssubject, the learned Commissioner of Income Tax (Appeals) has not considered the submission of the appellant and passed the order u/s 143(3

SANJAYBHAI DAMJIBHAI GOLAKIYA,SURAT vs. ITO, WARD-3(3)(1), SURAT

In the result, appeal of the appellant is allowed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.951/Srt/2024 Assessment Year: (2013-14) (Hybrid Hearing) Sanjaybhai Damjibhai Golakiya, Vs. The Assessment Unit, D-74, Vithalnagar Society, Hirabaug, Income-Tax Department, Varachha Road, Surat - 395006 Jurisdictional Ao: The Ito, Ward – 3(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Alopg2048R (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 18/03/2025 Date Of Pronouncement 06/05/2025

Section 253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing of appeal before the Tribunal. In the affidavit, it has been stated that the appellant filed appeal u/s 253(1) of the Act on 09.09.2024, vide ITA No.951/SRT/2024, against the order dated 15.02.2024, which was uploaded on the Income-tax e-filing

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

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

3. We have gone through the original grounds of appeal as well as additional grounds of appeal raised by the assessee, as noted above. We have observed that these grounds of appeal are repetitive in nature and most of the grounds are not really grounds of appeal but these are arguments for the main grievance of the assessee, therefore

EURO JEWELS,SURAT vs. DCIT, CIRCLE-1(1)(1), SURAT

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.236/Srt/2024 Assessment Year: (2012-13) (Physical Hearing) Euro Jewles, Vs. The Dcit, Plot No.258-A, Surat Special Economic Circle – 1(1)(1), Zone, Gidc Sachin, Surat - 394230 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bkipp5896G (Appellant) (Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 10/12/2024 Date Of Pronouncement 08/01/2025

section 253(3) of the Act. The learned Authorized Representative (Id. AR) submitted that the CIT(A) has passed order u/s 250 of the Act on 28.12.2023. The appeal before this Tribunal was required to be filed within 60 days, i.e. on or before 28.02.2024. However, the assessee filed the appeal on 29.02.2024. Therefore, there is a delay

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

KISHOR RAMESHBHAI MEHTA,SURAT vs. ITO, WARD-1(5), BHARUCH

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.60/Srt/2025 Assessment Year: 2013-14 (Hybrid Hearing) Kishor Rameshbhai Mehta Vs. Ito, Prop. Of Aditya Infrastructure, Ward - 1(5), 139, Maher Nagar, Opp. Baps Bharuch Hospital, Adajan Gam Circle, Surat - 395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adepm 4458 R (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 10/11/2025

disallowance of expenses on ad hoc basis. 10. On the facts and in circumstances of the case as well as law on the subject, the Learned Commissioner of Income Tax (Appeals) has not offered adequate opportunities to hear, hence, the case may please be set aside and restored back to the CIT(A) or AO for sake of the interest

DWARKESH & CO.,SURAT vs. ITO, WARD- 2(3)(1), SURAT

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

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.61/Srt/2025 Assessment Year: 2015-16 (Hybrid Hearing) Dwarkesh & Co. Income Tax Officer Ward-2(3)(1), बनाम/ 19, Radheyshyam Society, Surat, Aayakar Bhawan, Surat-395 Vs. Opp. Gopinath Complex, 001 Mota Varachha, Surat- 394 101 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aagfd 7120 G (अपीलाथ"/Appellant) (""थ" /Respondent)

section 253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. The assessee submitted that during the filing of appeal before CIT(A), his consultant had clearly mentioned the Email ID: ca.mihirthakkar@gmail.com for communication, however, during appellate proceedings before CIT(A), all notices for hearing were issued