MAROLI BAZAAR VIBHAG VIVIDH KARYAKARI SAHKARI MANDLI LTD.,NA vs. ARIVS.THE INCOME TAX OFFICER, WARD-2, 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.

66 the Act (as it stood at the relevant time), there was a special machinery for determination of tax where total income of an assessee included income on which no tax is payable. However, the provisions of section 81(1) have been deleted from Chapter VII of the IT Act, 1961 w.e.f. 1-4-1968 and incorporated as section

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.

66 the Act (as it stood at the relevant time), there was a special machinery for determination of tax where total income of an assessee included income on which no tax is payable. However, the provisions of section 81(1) have been deleted from Chapter VII of the IT Act, 1961 w.e.f. 1-4-1968 and incorporated as section

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.

66 the Act (as it stood at the relevant time), there was a special machinery for determination of tax where total income of an assessee included income on which no tax is payable. However, the provisions of section 81(1) have been deleted from Chapter VII of the IT Act, 1961 w.e.f. 1-4-1968 and incorporated as section

AMRUT SAROVAR,SURAT vs. PR. COMMISIONER INCOME TAX(CENTRAL), SURAT

In the result the grounds of appeal raised by the assessee in all three assessment years are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

66,26,440 37,93,87,202 Administrative & Indirect Expenses 74,36,218 87,53,772 1,69,27,244 3,31,17,234 Total Expenses 23,61,92,190 11,27,58,562 6,35,53,684 41,25,04,436 Net Profit (Receipts – Expenses) 2,01,72,794 1

AMRUT SAROVAR,SURAT vs. PR. COMMISIONER INCOME TAX(CENTRAL), SURAT

In the result the grounds of appeal raised by the assessee in all three assessment years are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

66,26,440 37,93,87,202 Administrative & Indirect Expenses 74,36,218 87,53,772 1,69,27,244 3,31,17,234 Total Expenses 23,61,92,190 11,27,58,562 6,35,53,684 41,25,04,436 Net Profit (Receipts – Expenses) 2,01,72,794 1

AMRUT SAROVAR,SURAT vs. PR. COMMISIONER INCOME TAX(CENTRAL), SURAT

In the result the grounds of appeal raised by the assessee in all three assessment years are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

66,26,440 37,93,87,202 Administrative & Indirect Expenses 74,36,218 87,53,772 1,69,27,244 3,31,17,234 Total Expenses 23,61,92,190 11,27,58,562 6,35,53,684 41,25,04,436 Net Profit (Receipts – Expenses) 2,01,72,794 1

MICRO INKS PVT. LTD., ( FORMERLY KNOWN AS MICRO INKS LTD.),VAPI vs. THE INCOME TAX OFFICER, ( INTL. TAXN.), SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.2375/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 The Income Tax Officer, V Micro Inks Limited, (International Taxation), Surat. S. Bilakhia House, Muktanand Marg, Chala, Vapi – 396 191. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2707/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 Micro Inks Limited, V The Income Tax Officer, Bilakhia House, Muktanand S. (International Taxation), Marg, Chala, Vapi – 396 191. Surat. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Gopala Krishnan – Ca राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr सुनवाईकीतारीख/ Date Of Hearing: 06.02.2020 उ"घोषणाक"तार"ख/Pronouncement On: 14.02.2020

66,53,684 Standard Chartered Bank, UK UK interest 84,50,573 The Hongkong And Shanghai Hong Interest 31,73,181 Banking Corporation Ltd, Hong Kong Kong Total 3,76,67,052 2.2. The proceeds of the aforesaid loan has been utilized by the company for investment in the share capital of wholly owned subsidiaries outside India during the year

THE ITO, (INTERNATIONAL TAXATION),, SURAT vs. MICRO INKS LIMITED,, VAPI

In the result, appeal of the assessee is allowed

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.2375/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 The Income Tax Officer, V Micro Inks Limited, (International Taxation), Surat. S. Bilakhia House, Muktanand Marg, Chala, Vapi – 396 191. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.2707/Ahd/2014 "नधा"रण वष"/Assessment Year: 2012-13 Micro Inks Limited, V The Income Tax Officer, Bilakhia House, Muktanand S. (International Taxation), Marg, Chala, Vapi – 396 191. Surat. [Pan: Aaach 7063 F] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Gopala Krishnan – Ca राज"वक"ओरसे /Revenue By Mrs. Anupam Singla – Sr.Dr सुनवाईकीतारीख/ Date Of Hearing: 06.02.2020 उ"घोषणाक"तार"ख/Pronouncement On: 14.02.2020

66,53,684 Standard Chartered Bank, UK UK interest 84,50,573 The Hongkong And Shanghai Hong Interest 31,73,181 Banking Corporation Ltd, Hong Kong Kong Total 3,76,67,052 2.2. The proceeds of the aforesaid loan has been utilized by the company for investment in the share capital of wholly owned subsidiaries outside India during the year

DARSHINI AMIT SHARMA,DAMAN vs. INCOME TAX OFFICER, WARD, DAMAN, DAMAN

In the result, the appeal of the assessee is allowed

Housing\nSociety, Veera Desai Road,\nAndheri West, Mumbai,\nMaharashtra - 400053\nस्थायी लेखा सं./जीआइआर सं./PAN/GIR No. : BLHPS5706E\n(Appellant)\n(Respondent)\nअपीलार्थी ओर से / Appellant by : Shri Chetan Agrawal, AR\nप्रत्यर्थी की ओर से/Respondent by : Shri Ajay Uke, Sr. DR\nDate of Hearing\nDate of Pronouncement\n16/03/2026\n19/03/2026\nORDER\nThe present appeal has been filed by the assessee

SMT. NAYANABEN F. PATEL,SURAT vs. PR. COMMISSIONER OF INCOME TAX, SURAT-1, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) Smt. Nayanaben F. Patel, Pr.C.I.T. 1, Indraprashtha Society, Surat-1, Vs. Nr. Puna Patiya, Magob, Surat. Surat-395010. Pan: Bhrpp 4706 K Appellant Respondednt

property. The copy of notice under Section 143(2) dated 12/09/2018 is filed on record. The Assessing Officer during the assessment, issued notice under Section 142(1) dated 20/11/2018. In the said notice in question No. 4, the Assessing Officer raised the issue of long term capital gain and required copy of sale deed and copy of purchase deed

M/S. ASHADEEP DEVELOPERS,,NA vs. ARIVS.THE INCOME TAX OFFICER, WARD-1,, NAVSARI

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1337/Ahd/2016 िनधा"रण वष"/Assessment Year: 1999-2000 M/S. Ashadeep Developers, Income Tax Officer, Shyam Nagar-4, Near Ward-1, Navsari Seventh Day High School, Vijalpore, Navsari 396450 Pan: Aaaaa 9272 F अपीलाथ" Appellant ""यथ"/Respondent

Housing Society Ltd. [2009] 314 ITR 272 (Gujarat) (PB-124), Manjusha Estate Pvt. Ltd. v. ITO [2009] 314 ITR 263 (Gujarat) and ITO v. Agencies Rajasthan (P) Ltd. [ 2008] 117 (JP) 542(PB-136) contended that the AO did not have authority to refer the matter to DVO under section 131 (1)(d) of the Act on 06.08.1999 when

HITESHBHAI DAHYABHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

ASHOK DAHYABHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

NITABEN ASHOKBHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

KOKILABEN J. KHALASI,,SURAT vs. THE INCOME TAX OFFICER, WARD-4(2),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

BHAVNABEN HITESHBHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

DAHYABHAI BHAGABHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

SHRI JAMUBHAI KALYANBHAI PATEL,,SURAT vs. THE INCOME TAX OFFICER, WARD-3(2),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census

KAMUBHAI DAHYABHAI PATEL,,SURAT vs. INCOME TAX OFFICER, WARD-4(4),, SURAT

In the result, the corresponding ground of appeal is partly allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) िनधा"रणवष" S. आ.अ.सं./ अपीलाथ"/Appellant Vs ""थ"/Respondent / N.

66. Before us, the ld. Senior Counsel for assessee vehemently submitted that compensation received on acquisition would not be subject to capital gain, as the agriculture land is not a capital asset as not being situated in an area which comprised within the jurisdiction of any municipality having population of not less than 10000 as per last census