DHANSUKHLAL MAGANLAL DHANGAR,NA vs. ARIVS.INCOME TAX OFFICER, WARD - 2, NAVSARI

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh(Physical Hearing) Dhansukhlal Maganlal Dhangar, I.T.O., Shantinagar Society, Ranifaliya, Ward-2, Vs. Vansda, Navsari-396580 (Gujarat) Navsari. Pan No. Acypd 0673 N Appellant/ Assessee Respondent/ Revenue

disallowance were filed by the assessee. The assessee during the course of assessment proceedings, explained all the facts regarding the alleged addition. The ld. AR of the assessee submits that as per clause (a) of sub-section (6) of Section 270A, the underreporting income or the purpose of this section shall not include the amount in respect of which

RAJESH C DALAL-HUF,SURAT vs. ADDL/JT/DEPUTY/ASST CIT/NATIONAL E- ASSESSMENT CENTER DELHI , DELHI

In the result, the grounds of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Rajesh C. Dalal-Huf, A.C.I.T., P-260, Old Gidc Estate, National E-Assessment Vs. Katargam, Surat-395004. Centre, Delhi. Pan: Aalhr 4363 J Appellant Respondednt

2,43,000/- on account of interest disallowances against income from house property. The Assessing Officer at the time of passing the assessment order initiated penalty for misrepresentation of fact under Section 270A

BHADRABALA DHIMANTRAI JOSHI,SURAT vs. ACIT CIRCLE-1(3), SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.126/Srt/2025 Assessment Year: 2017-18 (Hybrid Hearing) Bhadrabala Dhimantrai Joshi Assistant Commissioner Of बनाम/ 6Th Shree Nagar Society, Ghod Income-Tax, Circle-1(3), Surat, Vs. Dod Road, Surat-395 001 Anavil Business Centre, Adajan, Surat-395 007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aazpj 4561 G (अपीलाथ"/Appellant) (""थ" /Respondent) "नधा"रती क" ओर से /Appellant By Shri P.M. Jagasheth, Ca राज"व क" ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई क" तार"ख/Date Of Hearing 04/08/2025 उ"घोषणा क" तार"ख/Date Of Pronouncement 26/09/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act’) Dated 20.01.2025 By The National Faceless Appeal Centre, (Nfac), Delhi /Commissioner Of Income-Tax (Appeals) [In Short, The ‘Cit(A)’] For The Assessment Year (Ay) 2017- 18, Which In Turn Arises Out Of Assessment Order Passed By The Assessing Officer (In Short, ‘Ao’) U/S. 143(3) Of The Act On 03.12.2019. 2. Grounds Of Appeal Raised By The Assessee For The Appeal Are As Under: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Ld. Commissioner Of Income Tax (Appeals) Has Erred In Confirming The Action Of The Assessing Officer In Making Addition Of Rs.1,21,92,898/- On Account Of Alleged Disallowing Immunity Claimed U/S.2(14) Of Income-Tax Act, 1961 By Treating Again As Business Income, Which Ground Has Never Been Conveyed And/Or Initiated To Respond & Revealed Through Assessment Order Only. As No Opportunity Is Afforded Either Through Any Notice And/Or More

disallowing immunity claimed u/s.2(14) of Income-tax Act, 1961 by treating again as business income, which ground has never been conveyed and/or initiated to respond and revealed through Assessment order only. As no opportunity is afforded either through any notice and/or more ITA No.126/Srt/2025 A.Y 17-18 Bhadrabala D Joshi importantly under show cause notice about the said ground

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

section 40A(3A) of the Act, 1961. (disallowance in ground no.7 in ITA No.194/SRT/22 at Rs.38,000/- and Ground No.3 in ITA No.193/SRT/22 at Rs.11,88,236/- ) (iv) Ground No.1 raised by the assessee, in ITA No. 194/SRT/2022, and ground No. 2 raised by the assessee, in ITA No.193/SRT/2022, are as follows: “On the facts on the facts and circumstances

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

section 40A(3A) of the Act, 1961. (disallowance in ground no.7 in ITA No.194/SRT/22 at Rs.38,000/- and Ground No.3 in ITA No.193/SRT/22 at Rs.11,88,236/- ) (iv) Ground No.1 raised by the assessee, in ITA No. 194/SRT/2022, and ground No. 2 raised by the assessee, in ITA No.193/SRT/2022, are as follows: “On the facts on the facts and circumstances

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, WARD 5, , VAPI

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

section 40A(3A) of the Act, 1961. (disallowance in ground no.7 in ITA No.194/SRT/22 at Rs.38,000/- and Ground No.3 in ITA No.193/SRT/22 at Rs.11,88,236/- ) (iv) Ground No.1 raised by the assessee, in ITA No. 194/SRT/2022, and ground No. 2 raised by the assessee, in ITA No.193/SRT/2022, are as follows: “On the facts on the facts and circumstances

SHREE SAI ALANG HOUSE,SURAT vs. ITO, WARD 2(2)(1), SURAT

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.906/Srt/2024 (Ay 2022-23) (Physical Court Hearing) Shree Sai Alang House Income Tax Officer, Ward-2(2)(1), 13-15, Khodal Chhaya Society, Surat, Aaykar Bhawan, बनाम Surat Kamrej Road, Opp. Majura Gate, Vs Shyamdham Mandir, Surat-395 001 Surat-394 185 [Pan : Abefs 8896 D] अपीलाथ"/Appellant ""थ" /Respondent

270A of the Income Tax Act, 1961. 8. On the facts and in the circumstances of the case as well as the law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer in initiating penalty proceedings u/s 272A(1)(d) of the Income Tax Act, 1961. 2 Shree

VASUNDHARA VRIX VANWADI JAL SINCHN VIKAS SAHAKAI MANDLI LTD.,NA vs. ARIVS.THE ASSISTANT COMMISSIONER OF INCOME TAX , NAVSARI CIRCLE, NAVSARI

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

Bench: Shri Pawan Singh(Physical Hearing) Vasundhara Vrix Vanwadi A.C.I.T., Jalsinchnvikas Sahakari Mandli Ltd., Navsari Circle, Navsari, Vs. Room No. 302, 3Rd Floor, “Vrindavan Campus” At:Lachhakadi, Post-Gangpur, Tal. Vansada, Dist.- Income Tax Office, Navsari, Gujarat-396050. Charpool, Awabaug, Pan No. Aaajv 0058 M Navsari, Gujarat-396445. Appellant/ Assessee Respondent/ Revenue

disallowing the deduction claimed of Rs. 9,76,464/-. 2. On the facts and in the 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 the case and passed non-speaking order and hence the case may please be set aside and restored back

KALAMANDIR JEWELLERS LIMITED,SURAT vs. DCIT CIRCLE 1(1)(1), SURAT

In the result, appeal of the assessee is allowed

disallowed u/s 37 of the Act.\nPenalty proceedings u/s 270A(9) was also initiated by the AO for mis-reporting\nof income for ‘claim of expenditure not substantiated by any evidence'. The AO\nassessed the total income of Rs.22,34,09,411/- against the returned income of\nRs.22,15,57,940/-.\n4. Aggrieved by the order of AO, the assessee

MANISH BHOGILAL SHAH,MUMBAI vs. INCOME TAX OFFICER-3, NAVSARI, NAVSARI

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.687/Srt/2025 िनधा"रण वष" /Assessment Year : 2017-18 Manish Bhogilal Shah The Income Tax Officer-3 बनाम/ 6/B, Crown Mansion Navsari – 396 445 V/S. Ground Floor Forjeet Street, Cross Lane, Mumbai – 400 026 "थायी लेखा सं./Pan: Acqps 6699 F (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08 /12/2025 घोषणा की तारीख /Date Of Pronouncement: 27 /02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: Manish Bhogilal Shah Vs. Ito Asst. Year : 2017-18 2

270A and 272A(1)(d) of the Income Tax Act, 1961. 3. Ground 9. Appellant craves leave to add further grounds OR to amend OR alter the existing grounds of appeal on OR before the date of hearing. 4. Ground 1. On the facts and circumstances of the case and in law, the Ld CIT(A) erred in passing exparty

TAKHATSINH F DODIA,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, BHARUCH

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1071/Srt/2024 Assessment Year: (2017-18) (Physical Hearing) Takhatsinh F. Dodia, Vs. The Acit, 5, Guru Krupa Society, Opp – Utran Circle – 1, Health Centre, Utran, Surat - 394105 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Alnpd6029Q (Appellant) (Respondent) Appellant By Shri Karan Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 09/01/2025 Date Of Pronouncement 05/03/2025

Section 5 of the Act. 2. Whether on the facts and circumstances of the case, the Ld. Commissioner of Income-tax (Appeals) was justified in making the addition of Rs.28,12,500 under the head of income from other sources on presumption/belief that the Appellant may have other sources of income as he was short of funds for carrying

GUJARAT POLYSOL CHEMICALS LIMITED LIMITED,VAPI vs. THE ASST. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, VAPI, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

270A r.w.s.274 of the Income Tax Act, 1961 and request to grant stay on demand u/s 156 of the Income Tax Act, 1961. 5. On the facts and in the circumstances of the case as well as the law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer

DCIT, VAPI vs. GUJARART POLYSOL CHEMICAL LTD, VAPI

In the result, the appeal of assessee is partly allowed whereas appeal of Revenue is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.513 & 595/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Gujarat Polysol Chemicals Ltd. Assistant Commissioner Of 1, Plot No.1734, 3Rd Phase. Income Tax, Central Circle-1, Vs Gidc, Vapi-396195 Vapi, 8Th Floor, Fortune Square- Pan No. Aaacg 8908 Q Ii, Above Tbz, Chala-396191 अपीलाथ"/Appellant ""थ" /Respondent /Ita No.595/Srt/2023 (Ay 2018-19) Deputy Commissioner Of Gujarat Polysol Chemicals Ltd., Income Tax, Central Circle, I, Plot No.1734, 3Rd Phase, Gidc, Vs Vapi, 9Th Floor, Fortune Vapi-396195 Pan No.Aaacg 8908 Q Square-Ii, Daman Road, Chala, Vapi-396191 अपीलाथ"/Appellant ""थ" /Respondent

270A r.w.s.274 of the Income Tax Act, 1961 and request to grant stay on demand u/s 156 of the Income Tax Act, 1961. 5. On the facts and in the circumstances of the case as well as the law on the subject, the learned Commissioner of the Income Tax (Appeals) has erred in confirming the action of the Assessing Officer

MEGHNA ORGANIC,VALSAD vs. ITO, WARD-5, VAPI

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 151A of the Income Tax Act, 1961. 2. On the facts and in the circumstances of the case as well as the law on the subject, the learned Assessing Officer has erred in re-opening the assessment Meghna Organic Vs. ITO Asst. Year : 2018-19 - 2– u/s. 147 of the Income Tax Act, 1961 and issuing notice

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, SURAT, SURAT vs. SAHAJANAND MEDICAL TECHNOLOGIES LIMITED, SURAT

In the result, appeal of revenue is dismissed whereas CO of assessee is dismissed as infructuous

Bench: Ms. Suchitra R. Kammble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.364 & 366/Srt/2025 Ays: (2020-21 & 2018-19) (Physical Hearing) Dcit, Vs. Sahajanand Medical Technologies Central Circle – 4, Limited, Surat 221, C-Wing, Kanakia Atrium Andheri Kurla Road, Jb Nagar, Andheri East, Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs7694L (Appellant) (Respondent) Co. No.11/Srt/2025 (Ay 2018-19) [Arising Out Of Ita No.366/Srt/2025] Sahajanand Medical Technologies Vs. Dcit, Limited, Central Circle – 4, 221, C-Wing, Kanakia Atrium Andheri Surat Kurla Road, Jb Nagar, Andheri East, Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs7694L (Appellant) (Respondent) Appellant By Shri Rajesh C. Shah, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 28/08/2025 Date Of Pronouncement 19/09/2025

section 250 of the Income-tax Act, 1961 (in ITA No.364 & 366/SRT/2025/AY 2020-21 & 2018-19 & Co. No.11/SRT/2025/AY 2018-19 Sahajanand Medical Technologies Ltd. short, 'the Act’) dated 13.01.2025 and 17.01.2025 by the Commissioner of Income- tax (Appeals), NFAC, Delhi [in short, ‘CIT(A)’] for the assessment years (AYs) 2020-21 and 2018-19. With consent of the parties

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4, SURAT, SURAT vs. SAHAJANAND MEDICAL TECHNOLOGIES LIMITED, SURAT

In the result, appeal of revenue is dismissed whereas CO of assessee is dismissed as infructuous

Bench: Ms. Suchitra R. Kammble & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.364 & 366/Srt/2025 Ays: (2020-21 & 2018-19) (Physical Hearing) Dcit, Vs. Sahajanand Medical Technologies Central Circle – 4, Limited, Surat 221, C-Wing, Kanakia Atrium Andheri Kurla Road, Jb Nagar, Andheri East, Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs7694L (Appellant) (Respondent) Co. No.11/Srt/2025 (Ay 2018-19) [Arising Out Of Ita No.366/Srt/2025] Sahajanand Medical Technologies Vs. Dcit, Limited, Central Circle – 4, 221, C-Wing, Kanakia Atrium Andheri Surat Kurla Road, Jb Nagar, Andheri East, Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafcs7694L (Appellant) (Respondent) Appellant By Shri Rajesh C. Shah, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 28/08/2025 Date Of Pronouncement 19/09/2025

section 250 of the Income-tax Act, 1961 (in ITA No.364 & 366/SRT/2025/AY 2020-21 & 2018-19 & Co. No.11/SRT/2025/AY 2018-19 Sahajanand Medical Technologies Ltd. short, 'the Act’) dated 13.01.2025 and 17.01.2025 by the Commissioner of Income- tax (Appeals), NFAC, Delhi [in short, ‘CIT(A)’] for the assessment years (AYs) 2020-21 and 2018-19. With consent of the parties

JAYVADAN AMRATLAL RUGHNATHWALA,SURAT vs. PCIT-1, SURAT, SURAT

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.348/Srt/2025 Assessment Year: (2018-19) (Hybrid Hearing) Jayvadan Amratlal Rughnathwala, Vs. The Pcit - 1, 6/7, Khatodara Ind Service Society, Surat B/H Sub Jail Khatodara, Surat – 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpr4348L (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Ravinder Sindhu, Cit-Dr Date Of Hearing 26/08/2025 Date Of Pronouncement 19/11/2025

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Principal Commissioner of Income Tax, Valsad [in short, ‘ld. PCIT’], dated 22.01.2025 for assessment year (AY) 2018-19. 2. The grounds of appeal raised by the assessee are as under: “1. On the facts and in circumstances of the case as well