M/S. DHARAM IMPEX,,SURAT vs. THE DY. CIT, CENTRAL CIRCLE-4,, SURAT

In the result, the appeal of the assessee for AY 2008-09 in ITA No

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपीलसं./It(Ss)A Nos.288 To 293/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2009-10 To 2014-15) (Physical Court Hearing) M/S Kangan Jewels Pvt. Ltd. Deputy Commissioner Of C/O 106, Saryu Chambers, Income-Tax, Central Circle-4, Vs. Jadakhadi Mahidharpura, Surat- Surat 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadck 2552 R अपीलाथ" / Appellant ""यथ" /Respondent आयकर अपीलसं./It(Ss)A Nos.306 To 311/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2008-09 To 2013-14) आयकर अपीलसं./Ita Nos.1579/Ahd/2017 ("नधा"रणवष" / Assessment Year: (2014-15) M/S Maniprabha Impex Pvt.Ltd. Deputy Commissioner Of C/O 106, Saryu Chambers, Income-Tax, Central Circle-4, Vs. Jadakhadi Mahidharpura, Surat- Surat 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaecm 6219 L अपीलाथ" /Appellant) ""यथ" /Respondent) आयकर अपीलसं./It(Ss)A Nos.312 To 317/Ahd/2017 ("नधा"रणवष" / Assessment Years: (2008-09 To 2013-14) आयकर अपीलसं./Ita Nos.1580/Ahd/2017 ("नधा"रणवष" / Assessment Year: (2014-15) M/S Dharam Impex Deputy Commissioner Of C/O 106, Saryu Chambers, Income-Tax, Central Circle-4, Vs. Jadakhadi Mahidharpura, Surat- Surat 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffd 2692 C अपीलाथ" /Appellant) ""यथ" /Respondent)

property discovered in the course of search which were not produced or not already disclosed or made known in the course of original assessment.' 22. The aforesaid principles would be equally applicable to proceedings initiated under Section 153C of the Act as Section 153C(1) of the Act expressly provides that once the AO has received "money, bullion, jewellery

HEMANT ISHWARLAL DESAI,SURAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1), SURAT

In the result, the appeal filed by the assessee is hereby ordered to be allowed

Bench: Shri Amarjit Singh, Jm & Shri O.P.Meena, Am Hemant Ishwarlal Desai Dy. Commissioner Of Income Tax Circle-3(1) 305-306, Mahima Heights, Nr. Shardayatan Aayakar Bhavan, Majura Gate, Surat. School, Chandani Chowk, Surat-395007. Pan/Gir No.Abkpd0745Q Appellant) .. Respondent) Assessee By Shri Rasesh Shah Revenue By Ms. Smitha V. Nair (Sr. Dr)

house at Mumbai and Pune was well in order. We thus in context of the issue under consideration set aside the order of the CIT and uphold the claim of deduction as was raised by the assessee. The Grounds of appeal Nos. 1 to 3 are allowed in terms of our aforesaid observations. The Ground of appeal No. 4 being

DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

property has been found as a consequence of the search, the same would also be taken into consideration. The requirement of assessment or reassessment under the said section has to be read in the context of Sections 132 or 132A of the Act, inasmuch as, in case nothing incriminating is found on account of such search or requisition, then

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

property has been found as a consequence of the search, the same would also be taken into consideration. The requirement of assessment or reassessment under the said section has to be read in the context of Sections 132 or 132A of the Act, inasmuch as, in case nothing incriminating is found on account of such search or requisition, then

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

property has been found as a consequence of the search, the same would also be taken into consideration. The requirement of assessment or reassessment under the said section has to be read in the context of Sections 132 or 132A of the Act, inasmuch as, in case nothing incriminating is found on account of such search or requisition, then

THE ACIT, CENTRAL CIRCLE-2,, SURAT vs. M/S. SRUSHTI CORPORATION,, SURAT

In the result, the appeal of the Revenue for A

Bench: Shri H.S.Sidhu & Shri O.P.Meena

153, T.P. No.48, F.P. No.7, Assistant Commissioner of Swapna Srushti Residency, Jiyav Income Tax-2 &9 Surat. Budiya Road, H.No.8, Bhestan, Surat [PAN: AAOFM 1919 J] अपीलाथ" Appellant ""थ"/Respondent िनधा"रतीकीओरसे /Assessee by Shri Rasesh Shah, CA, AR राज"कीओरसे /Revenue by Shri R.P. Rastogi, Sr. D.R सुनवाईकीतारीख/ Date of hearing : 19.07.2019 उद्घोषणाकीतारीख/Pronouncement on : 27.08.2019 आदेश

THE ITO, WARD-5(4),, SURAT vs. M/S. SRUSHTI CORPORATION,, SURAT

In the result, the appeal of the Revenue for A

Bench: Shri H.S.Sidhu & Shri O.P.Meena

153, T.P. No.48, F.P. No.7, Assistant Commissioner of Swapna Srushti Residency, Jiyav Income Tax-2 &9 Surat. Budiya Road, H.No.8, Bhestan, Surat [PAN: AAOFM 1919 J] अपीलाथ" Appellant ""थ"/Respondent िनधा"रतीकीओरसे /Assessee by Shri Rasesh Shah, CA, AR राज"कीओरसे /Revenue by Shri R.P. Rastogi, Sr. D.R सुनवाईकीतारीख/ Date of hearing : 19.07.2019 उद्घोषणाकीतारीख/Pronouncement on : 27.08.2019 आदेश

THE DCIT, CIRCLE-2(3),, SURAT vs. M/S. SRUSHTI CORPORATION,, SURAT

In the result, the appeal of the Revenue for A

Bench: Shri H.S.Sidhu & Shri O.P.Meena

153, T.P. No.48, F.P. No.7, Assistant Commissioner of Swapna Srushti Residency, Jiyav Income Tax-2 &9 Surat. Budiya Road, H.No.8, Bhestan, Surat [PAN: AAOFM 1919 J] अपीलाथ" Appellant ""थ"/Respondent िनधा"रतीकीओरसे /Assessee by Shri Rasesh Shah, CA, AR राज"कीओरसे /Revenue by Shri R.P. Rastogi, Sr. D.R सुनवाईकीतारीख/ Date of hearing : 19.07.2019 उद्घोषणाकीतारीख/Pronouncement on : 27.08.2019 आदेश

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -2(1)(1), SURAT vs. MANISH SUMATILAL SHAH, MUMBAI

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Hearing) A.C.I.T., Manish Sumatilal Shah, Circle- 2(1)(1), 401, 4Th Floor, South Ridge Road, Vs. Surat. Mumbai-400006. Pan No. Adrps 1088 E Appellant/ Respondent Respondent/ Assessee

properties, therefore, deduction under Section 54F of the Act is not allowable. The Assessing Officer asked the assessee to furnish reply on or before 18/11/2019. The Assessing Officer recorded that no reply has been received from the assessee, therefore, another opportunity to furnish reply to the show cause notice was given to the assessee by 26/11/2019. The Assessing Officer further

M/S. JAY KESAR BHAVANI DEVELOPERS PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-1(1)(3),, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.2102 To 2104/Ahd/2016 ("नधा"रणवष" / Assessment Years: (2010-11 To 2012-13) (Physical Court Hearing) M/S. Jay Kesar Bhavani Developers Vs. The Ito, Ward-1(1)(3), Pvt. Ltd., Surat. A-48, Kesar Kunj, Shri Bhulabhai Desai Marg, Laxmikant Ashram Road, Katargam, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcj6278P (Assessee) (Respondent) Assessee By Shri Sapnesh Seth, Ca Respondent By Shri J. K. Chandani, Sr. Dr Date Of Hearing 05/05/2022 13/07/2022 Date Of Pronouncement

153 of the Act. The Ld. Counsel did not furnish any evidence to demonstrate that the order under section 143(3) was passed beyond the statutory limit. The assessment order passed under section 143(3) of the Act dated 31.03.2013, was served on the assessee, on 03.04.2013, that does not mean that order was passed on 03.04.2013. The service

M/S. JAY KESAR BHAVANI DEVELOPERS PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-1(1)(3),, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.2102 To 2104/Ahd/2016 ("नधा"रणवष" / Assessment Years: (2010-11 To 2012-13) (Physical Court Hearing) M/S. Jay Kesar Bhavani Developers Vs. The Ito, Ward-1(1)(3), Pvt. Ltd., Surat. A-48, Kesar Kunj, Shri Bhulabhai Desai Marg, Laxmikant Ashram Road, Katargam, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcj6278P (Assessee) (Respondent) Assessee By Shri Sapnesh Seth, Ca Respondent By Shri J. K. Chandani, Sr. Dr Date Of Hearing 05/05/2022 13/07/2022 Date Of Pronouncement

153 of the Act. The Ld. Counsel did not furnish any evidence to demonstrate that the order under section 143(3) was passed beyond the statutory limit. The assessment order passed under section 143(3) of the Act dated 31.03.2013, was served on the assessee, on 03.04.2013, that does not mean that order was passed on 03.04.2013. The service

M/S. JAY KESAR BHAVANI DEVELOPERS PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-1(1)(3),, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.2102 To 2104/Ahd/2016 ("नधा"रणवष" / Assessment Years: (2010-11 To 2012-13) (Physical Court Hearing) M/S. Jay Kesar Bhavani Developers Vs. The Ito, Ward-1(1)(3), Pvt. Ltd., Surat. A-48, Kesar Kunj, Shri Bhulabhai Desai Marg, Laxmikant Ashram Road, Katargam, Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabcj6278P (Assessee) (Respondent) Assessee By Shri Sapnesh Seth, Ca Respondent By Shri J. K. Chandani, Sr. Dr Date Of Hearing 05/05/2022 13/07/2022 Date Of Pronouncement

153 of the Act. The Ld. Counsel did not furnish any evidence to demonstrate that the order under section 143(3) was passed beyond the statutory limit. The assessment order passed under section 143(3) of the Act dated 31.03.2013, was served on the assessee, on 03.04.2013, that does not mean that order was passed on 03.04.2013. The service

ACIT, VAPI CIRCLE., VAPI vs. SHRI ANAND JAYANTILAL KHARBHARI, VAPI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपील./Ita No.231/Srt/2020 ("नधा"रणवष" / Assessment Years: (2013-14) (Virtual Court Hearing) The Acit, Vapi Circle, Vs. Shri Anand Jayantilal Kharbhari, Vapi. 409, Tirupati Towrs, Gidc Char Rasta, Vapi- 396195. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ajqpk7929K (Assessee) (Respondent) Assessee By: Ms Poonam Joshi, Advocate Revenue By: Shri H. P. Meena, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 22/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 31/05/2022 आदेश / O R D E R Per Dr. A. L. Saini, Am: The Captioned Appeal Filed By The Revenue, Pertaining To Assessment Year 2013-14, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Valsad [In Short ‘Ld. Cit(A)’], In Appeal No. Itba/Apl/S/250/2020-21/1028054664(1) Dated 24.09.2020, Which In Turn Arises Out Of An Assessment Order Passed By Assessing Officer U/S 143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 30.03.2016. 2. Grounds Of Appeal Raised By The Revenue As Follows:

property, one was flat and one more shop which were used for own purpose and business only.” 6. However, assessing officer rejected the contention of the assessee and held that income from prevailing market rate of the house for letting out to Shri Manoj Shahu is at Rs.5,000/- per month that comes to Rs.60,000/-. Therefore, assessing officer disallowed

KIRIT BABUBHAI JHAVERI,SURAT vs. ACIT, CIRCLE-2(2), SURAT, SURAT

In the result, the appeal is allowed for statistical purposes, subject to the of cost of Rs

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.52/Srt/2024 Assessment Year: 2015-16 (Hybrid Hearing) Kirit Babubhai Jhaveri, Vs. Acit, 22, Zaveri Bungalow, Opp – Circle – 2(2), Meghna Park, City Light Road, Surat Surat – 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabpz4942P (Appellant) (Respondent)

section 250 of the Income-tax Act, 1961 (in short, 'the Act’) dated 13.11.2023 by the Commissioner of Income-tax (Appeals), [in short, “the CIT(A)”] for the assessment year (AY) 2015-16, which in turn arises out of assessment order passed by the Assessing Officer (in short, ‘AO’) u/s. 143(3) of the Act on 21.12.2017. 2. Grounds

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-2,, SURAT vs. SHRI RAMESHBHAI RAGHAVBHAI BHADANI, SURAT

In the result, summarized and concise ground No

Bench: Shri Pawan Singh, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./It(Ss)A Nos.25 &31/Srt/2021 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Deputy Commissioner Of Rameshbhai Raghavbhai Bhadani, Prop. Of M/S Rangeela Fashion, 14, Income-Tax, Central Circle-2, Room No. 505, 5Th Floor, Nirman Industrial Estate, A.K. Road, Fulpada, Surat Aaykar Bhawan, Majura Gate, Vs. Surat-395001. Deputy Commissioner Of Income- Rameshbai Raghavhai Bhadani Plot No.14-16, Nirman Tax, Central Circle-2, Room No.505, 5Th Floor, Aaykar Bhawan, Majura Industrial Estate, A./K. Road, Surat-395008 Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.45/Srt/2021 ("नधा"रणवष" / Assessment Year: (2014-15) Deputy Commissioner Of Shri Rameshbhai Raghavbhai Income-Tax, Circle-3, Room No. Bhadani, Prop. Of M/S Rangeela Vs. 505, 5Th Floor, Aaykar Bhawan, Fashion, 14, Nirman Industrial Majura Gate, Surat-395001. Estate, A.K. Road, Fulpada, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent)

153. 6. The reliance is placed on the following case laws of courts.  CIT vs. Uttarakhand Van Vikas Nigam [66 taxmann.com 87 (Utt. HC)  Rural Electrification Corporation Ltd. Vs. CIT [34 taxmann.com 197 (Del. HC) IT(SS)A Nos.25, 31, 45, 26 & 30/SRT/2021 A.Ys.13-14 & 14-15 Rameshbhai R Bhadani & Jayeshkumar D Mistry  A.B. Parikh

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-4,, SURAT vs. M/S. SHREE RAM DEVELOPERS,, SURAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Pawan Singh, Hon'Ble & Dr. Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.1841/Ahd/2016 िनधा"रण वष"/Assessment Year: 2006-07 The Deputy Commissioner Vs. M/S Shree Ram Developers, Of Income Tax, Central “Shrushti Row House”, Circle-2, Surat. Kosad, Surat 394 107. [Pan: Abkfs 4321 F] अपीलाथ" / Appellant ""थ"/Respondent िनधा"रतीकीओर से /Assessee By Shri Ashwin K.Parekh – Ca राज"कीओर से /Revenue By Shri Ritesh Mishra – Cit(Dr) सुनवाई की तारीख/ Date Of Hearing: 24.02.2021 उद्घोषणा की तारीख/Pronouncement On: 08.03.2021 आदेश /O R D E R Per Pawan Singh, Judicial Memeber: 1. This Appeal By Revenue Is Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-4, Surat Dated 11.04.2016 For Assessment Year (Ay) 2006-07. The Revenue Has Raised The Following Grounds Of Appeal: “[1] On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs.3,16,65,000/- Made On Account Of Unexplained Income U/S.69A Of The I.T. Act, 1961 In Spite Of The Fact That Shri Ankurbhai Babariya, One Of The Trustworthy Person Of Shri Jayantibhai Babariay, A Partner Of M/S Shree Ram Developers Had Explained That Seized Documents From His Premise Are Related To Shrusti Row House Maintained By Him Which Was Later On Also Admitted By Him In His Statement On Oath & This Project Was Developed By The Assessee Firm I.E. M/S Shree Ram Developers. Also, There Was No Denial That On Money Has Been Seized In The Shrusti Row House Project. [2] On The Facts & Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred To Held The Addition Of Rs.3,16,65,000/- Made On Account Of Dcit Vs. Shree Ram Developers /

property. A search action under section 132 of the Act was carried out at the premises of Shri Ankur Babariya at 20, Ram Krupa Society, Saroli Road, Puna Gaon, Surat on 17.07.2012. From his premises, certain papers in the form of ledger accounts were seized as Annexure –A/1, A/3 and A/5. Shri Ankurbhai Gordhanbhai Babariya was working with the partners

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -1, VAPI vs. M/S. KRIMPI DISTILLERY, NANI DAMAN

In the result, appeals in IT(SS)A Nos

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am करअपीलसं./It(Ss)A Nos.01To 06/Srt/2017& आयकरअपीलसं./Ita No.47/Srt/2017 "तया"ेयसं./Cross Objection Nos.02To 08/Srt/2018 [A/O In It(Ss)A Nos.01 To 06/Srt/2017 & Ita No.47/Srt/2017] (िनधा"रणवष" / Assessment Years: (2008-09 To 2013-14 & 2014-15) (Virtual Court Hearing) The Acit, Central Circle-1, Vs. Krimpi Distillery, Vapi. Plot No.34-37, Supreme Ind. Estate, Bhimpore, Nani Daman- 396210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaofm6580H अपीलाथ" /Applicant ""यथ"/Respondent/"तया"ेपक/Co- Objector

house where it is stored. There are five basic ingredients used in manufacture of alcoholic beverage viz: IMFL: (1) Rectified Spirit, (2) Extraneutral alcohol, (3) Malt Spirit, (4) Scotch Concentrate, (5) Demineralized Water. The assessing officer noted that demineralized water forms an important and the most basic part of alcoholic beverage viz: IMFL and is therefore an integral part

KHAREL VIBHAG VIVIDH KARYAKARI SAHKARI MANDLI LTD.,NA vs. ARIVS.THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE NAVSARI, NAVSARI

In the result, appeals filed by the assessees (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.173/Srt/2017 & 199/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) M/S.Maroli Bazar Vibhag Vividh Vs. The Income Tax Officer, Ks.M.L. Ward-2, Navsari. At & Post – Maroli Bazar, Tal-Jalalpore, Dist-Navsari. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam 1095 J (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.200/Srt/2018 & 201/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) Kharel Vibhag V.V.K.S.M. Ltd., Vs. The Deputy Commissioner Of Income At & Post – Kharel, Tax, Navsari. Navsari. & The Income Tax Officer, Ward-2, Navsari.

153 TAXMAN 363 (GUJ.). In this case the Hon`ble Court held that when business of assessee qua specified ITA No.173/SRT/2017 & 199/SRT/2018; ITA No.200 & 201/SRT/2018 for A.Ys. 2013-14 & 14-15 Maroli Bazar Vibhag Vividh K.S.M.Ltd., & Kharel Vighag V.V.K.S.M.Ltd. activities and activities other than specified activities is one and indivisible and there are common overhead expenses, income from specified activities

M/S. MAROLI BAZAR VIBHAG VIVIDH KARYAKARI SAHKARI MANDLI LTD.,,NA vs. ARIVS.DEPUTY COMMISSIONER OF INCOME TAX, NAVSARI CIRCLE , NAVSARI

In the result, appeals filed by the assessees (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.173/Srt/2017 & 199/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) M/S.Maroli Bazar Vibhag Vividh Vs. The Income Tax Officer, Ks.M.L. Ward-2, Navsari. At & Post – Maroli Bazar, Tal-Jalalpore, Dist-Navsari. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaam 1095 J (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.200/Srt/2018 & 201/Srt/2018 ("नधा"रणवष" / Assessment Years: (2013-14 & 2014-15) (Virtual Court Hearing) Kharel Vibhag V.V.K.S.M. Ltd., Vs. The Deputy Commissioner Of Income At & Post – Kharel, Tax, Navsari. Navsari. & The Income Tax Officer, Ward-2, Navsari.

153 TAXMAN 363 (GUJ.). In this case the Hon`ble Court held that when business of assessee qua specified ITA No.173/SRT/2017 & 199/SRT/2018; ITA No.200 & 201/SRT/2018 for A.Ys. 2013-14 & 14-15 Maroli Bazar Vibhag Vividh K.S.M.Ltd., & Kharel Vighag V.V.K.S.M.Ltd. activities and activities other than specified activities is one and indivisible and there are common overhead expenses, income from specified activities