VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

VIRAJ SHIRISHKUMAR MODI,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CC-1, SURAT, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.631 To 637/Srt/2023 Assessment Years: (2012-13 To 2018-19) (Physical Hearing) Viraj Shirishkumar Modi, Vs. The Dcit, 5, Dwarkadhish Society, Palanpur Patia, Central Circle – 1, Rander Road, Surat – 395009. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bdbpm7942L (Appellant) (Respondent) Shri Bipin Jariwala, Advocate Appellant By Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 21/11/2023 Date Of Pronouncement 21/11/2023

142(1) of the Act. Accordingly, the penalty imposed is restricted to Rs.10,000/- as against Rs.20,000/- levied by the AO. Ground No.1 is partly allowed.” 6. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. ITA Nos.631 to 637/SRT/2023 Viraj Shirishkumar Modi 7. Shri Bipin Jariwala, Learned Counsel for the assessee

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

142(1) dated 30.01.2021 issued to the assessee. 5. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has partly allowed the appeal of the assessee. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. 6. Shri P. M. Jagasheth, Learned Counsel

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

142(1) dated 30.01.2021 issued to the assessee. 5. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has partly allowed the appeal of the assessee. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. 6. Shri P. M. Jagasheth, Learned Counsel

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

142(1) dated 30.01.2021 issued to the assessee. 5. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has partly allowed the appeal of the assessee. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. 6. Shri P. M. Jagasheth, Learned Counsel

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

142(1) dated 30.01.2021 issued to the assessee. 5. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has partly allowed the appeal of the assessee. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. 6. Shri P. M. Jagasheth, Learned Counsel

RAMABHAI KANJIBHAI PATEL,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 2, SURAT

In the result, appeals filed by assessee (in ITA Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.106 To 110/Srt/2023 Assessment Years: (2013-14 To 2017-18) (Physical Hearing) Ramabhai Kanjibhai Patel, Vs. The Dcit, At-Surajpuja, Po-Surajpura, Ta-Palanpur, Central Circle-2, Palanpur-385001. Surat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aefpp4997J (Assessee) (Respondent)

142(1) dated 30.01.2021 issued to the assessee. 5. Aggrieved by the order of Assessing Officer, the assessee carried the matter in appeal before the Ld. CIT(A), who has partly allowed the appeal of the assessee. Aggrieved by the order of Ld. CIT(A), the assessee is in further appeal before us. 6. Shri P. M. Jagasheth, Learned Counsel

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. Since facts are same, with consent of the parties, both appeals were heard together and a common order is passed for the sake of convenience and brevity. The quantum appeal in ITA No.612/SRT/2025 is treated as “lead” case. 1 ITA Nos.612 & 613/SRT/2025/AY 2007-08 Meenaxi Gems Pvt. Ltd. 2. The grounds of appeal

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. Since facts are same, with consent of the parties, both appeals were heard together and a common order is passed for the sake of convenience and brevity. The quantum appeal in ITA No.612/SRT/2025 is treated as “lead” case. 1 ITA Nos.612 & 613/SRT/2025/AY 2007-08 Meenaxi Gems Pvt. Ltd. 2. The grounds of appeal

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

penalty proceedings u/s 271(1)(c ) of the Act.” 4. First, we shall adjudicate the Summarized and concise grounds of appeal raised by the assessee, in lead case in ITA No.195/SRT/2022, where books of accounts of assessee were rejected by the Assessing Officer u/s 145(3) of the Act. The summarized and concise ground No.1 is reproduced below for ready

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

penalty proceedings u/s 271(1)(c ) of the Act.” 4. First, we shall adjudicate the Summarized and concise grounds of appeal raised by the assessee, in lead case in ITA No.195/SRT/2022, where books of accounts of assessee were rejected by the Assessing Officer u/s 145(3) of the Act. The summarized and concise ground No.1 is reproduced below for ready

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

penalty proceedings u/s 271(1)(c ) of the Act.” 4. First, we shall adjudicate the Summarized and concise grounds of appeal raised by the assessee, in lead case in ITA No.195/SRT/2022, where books of accounts of assessee were rejected by the Assessing Officer u/s 145(3) of the Act. The summarized and concise ground No.1 is reproduced below for ready

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

271/-.\n9. Aggrieved by the order of AO, the assessee filed appeal before the CIT(A). The CIT(A) has reproduced submission of the assessee in para 6.2 of the appellate order. Before CIT(A), the assessee submitted that he had not received cash from Dr. Laxmichand and Shri Trilokchand Kamdar of Rs.1,54,89,000/- and Rs.2

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

271/-.\n9.\nAggrieved by the order of AO, the assessee filed appeal before the\nCIT(A). The CIT(A) has reproduced submission of the assessee in para 6.2 of\nthe appellate order. Before CIT(A), the assessee submitted that he had not\nreceived cash from Dr. Laxmichand and Shri Trilokchand Kamdar of\nRs.1,54,89,000/- and Rs.2

RAJENDRAPRASAD BABULAL KHETAN,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIR. - 4, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.142/Srt/2023 (Assessment Year: 2017-18) (Physical Hearing) Rajendraprasad Babulal Khetan, Vs. The Acit, E-2-1101, Capital Greens, Vesu Central Circle-4, – Bharthana, Surat – 395007. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abqpk8161R (Appellant) (Respondent) आयकर अपील (खोज और ज"ती) सं./It(Ss)A Nos.32/Srt/2023 (Assessment Year: 2017-18) Rajendraprasad Babulal Khetan, Vs. The Acit, E-2-1101, Capital Greens, Vesu Central Circle-4, – Bharthana, Surat – 395007. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abqpk8161R (Appellant) (Respondent)

142(1) of the Act alongwith questionnaire was issued through ITBA system which was duly served upon the assessee. By this notice, the assessee was requested to furnish the details as per the requirement of the questionnaire. In response to the above notices/questionnaire, the assessee has furnished his reply through e-proceeding. 7. During the course of search