RUPAL DEVANG NAIK ,NA vs. ARIVS.ITO, WARD-4, NAVSARI

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

reassessment. Since, assessee's share in the property is only\n12.5% and after allowing deduction of cost of acquisition, the income does not\nexceed basis exemption

NYA INTERNATIONAL,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 1, SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.57/Srt/2022 "नधा"रणवष"/Assessment Year: (2012-13) (Physical Court Hearing) Nya International, Vs. The Pcit-1, Unit No.360, Plot No.239, Sez, Gidc Surat. Sachin, Suarat – 394230. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfn1681M

reassessment proceedings, the assessee submitted its reply in respect of these two issues viz: first is undisclosed bank account of ING Vysya Bank and second is deduction / exemption

REKHABEN JITENDRAKUMAR JAIN,AHURA NAGAR SOCIETY vs. PCIT, AAYAKAR BHAVAN

In the result, the appeal of the assessee stands allowed

Bench: S/Shri Sanjay Garg & Bijayananda Prusethassessment Year : 2013-14 Rekhaben Jitendrakumar Jain, The Pr.Commissioner Of 255-257, Ahura Nagar Society Vs Income Tax-1 Adajan. Surat. Pan : Adypj 6066 G (Applicant) (Responent) : Assessee By Shri Rasesh Shah, Ca : Shri Ashish Pophara, Cit-Dr Revenue By सुनवाई क" तार"ख/Date Of Hearing : 05/03/2025 घोषणा क" तार"ख /Date Of Pronouncement: 03/06/2025 आदेश/O R D E R Per Sanjay Garg

reassessment order was passed on 23.3.2022 by the AO, assessing the income of the assessee at Rs.9,03,830/-. The ld.Pr.CIT noted that assesses had traded in the scrip INDINFO with the trade value of Rs.1,08,44,623/- and claimed exempted

INCOME TAX OFFICER, SURAT vs. ILESH B PONKIA, SURAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

exemption u/s. 10(38) of the Act and made addition of Rs.84,90,075/- under section 69 of the Act. 6. On appeal, Ld. CIT(A) deleted the addition treating the transaction as genuine transaction. On further appeal before this Tribunal, the Ld. Counsel for the assessee submitted that the reassessment

VIRAL LAVJIBHAI PATEL,SURAT vs. INCOME TAX OFFICER, WARD-3(3)(5), SURAT

In the result, assessee`s appeal is partly allowed in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.450/Srt/2023 Assessment Year: (2011-12) (Physical Hearing) Viral Lavjibhai Patel, Vs. Income Tax Officer, A-18, Naginawadi Society, Ward-3(3)(5), Surat, Aaykar Sumul Dairy Road, Bhawan, Majura Gate, Opp. Surat – 395004. New Civil Hospital, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Alvpp2897E (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 12/10/2023 Date Of Pronouncement 26/10/2023

reassessment proceedings, the findings of NFAC/ld CIT(A) are reproduced below: “17.0 Ground No.1: The ground is related to the technical issue of reopening. The appellant had submitted that the AO should not come to a conclusion of escapement of income only based on the non-filing of the return of income and cash deposits made in the bank account

JAYSHRI GOPALLAL MAHARAJSHRINI SURAT SRUSTI TRUST,SURAT vs. ITO, EXEMPTION WARD, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

exemption merely on bar of limitation in furnishing audit report in Form no. 10B. Jayshri Gopallal Maharajshrini Surat Srusti Trust vs. ITO (E) Asst. Year –2022-23 - 5– 9. In the case of Associated Chambers of Commerce and Industry of India vs. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 510 (Delhi)/[2024] 300 Taxman 410 (Delhi

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

exempt LTCG as unexplained cash credit u/s 68 of the I.T. Act,1961 without acknowledging the submission of the assessee. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming action of Assessing Office in making addition of Rs.3,406/- as unexplained expenditure

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

In the result, assessee's appeal is allowed

exempt\nLTCG as unexplained cash credit u/s 68 of the I.T. Act,1961 without\nacknowledging the submission of the assessee.\n4. On the facts and circumstances of the case as well as law on the\nsubject, the learned CIT(A) has erred in confirming action of Assessing\nOffice in making addition of Rs.3,406/- as unexplained expenditure u/s\n69C

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. DY. COMMISSIONER OF INCOME TAX,BHARUCH CIRCLE,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

BHARUCH ENVIRO INFRASTRUCTURE LIMITED,,ANKLESHWAR vs. THE DY.CIT,BHARUCH CIRCLE,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. ADDL.CIT,BHARUCH CIRCLE,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. DY. COMMISSIONER OF INCOME TAX,BHARUCH CIRCLE,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. DY. COMMISSIONER OF INCOME TAX,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

BHARUCH ENVIRO INFRASTRUCTURE LTD.,,ANKLESHWAR vs. ACIT,BHARUCH CIRCLE,, BHARUCH

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

reassessment has to be based on fulfilment of certain per-condition and if the concept of ‘change of opinion’ is removed as contemplated on behalf of department, then in the garb of reopening the assessment, review would take place. One must treat the concept of Bharuch Enviro Infrastructure Ltd. Vs DCIT ‘change of opinion’ as an in-built test check

ITO, WARD-2(3)(2), SURAT, SURAT vs. KISHOR BHANUBHAI ASODARIA, SURAT

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

reassessment order passed under section 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2015-16. 2. Brief Facts of the case are the assessee is an individual filed his return of income for the asst. year 2015-16 declaring taxable income of Rs.3

VIJAYBHAI MALABHAI BHARWAD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CIR.,-1(2), SURAT

In the result, ground no.2 raised by the assessee in ITA

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर(खोज-और-ज"ती)अपील सं/It(Ss)A Nos.23 & 24/Srt/2021 (Assessment Years: 2012-13 & 2013-14) (Physical Hearing) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 3, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.118/Srt/2021 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Acit, B-58, Chandramani Apartment, Circle -1(2), Udhana Magdalla Road, Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.121/Srt/2021 (Assessment Year: 2014-15) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 2, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर(खोज-और-ज"ती)अपील सं It(Ss)A Nos.90/Srt/2022 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Dcit, B-58, Chandramani Apartment, Central Circle – 3, Udhana Magdalla Road, Surat. Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent)

reassess the income of the other person in accordance with the provision of section 153A of the Act. The Assessing Officer has duly recorded the satisfaction for issuing the notice u/s 153C of the Act. Further, it is not the contention of the assessee that the Assessing Officer has not recorded the satisfaction in the assessee's case

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,2, SURAT vs. VIJAYBHAI MALABHAI BHARWAD, SURAT

In the result, ground no.2 raised by the assessee in ITA

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर(खोज-और-ज"ती)अपील सं/It(Ss)A Nos.23 & 24/Srt/2021 (Assessment Years: 2012-13 & 2013-14) (Physical Hearing) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 3, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.118/Srt/2021 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Acit, B-58, Chandramani Apartment, Circle -1(2), Udhana Magdalla Road, Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर अपील सं./Ita No.121/Srt/2021 (Assessment Year: 2014-15) The Dcit, Vs. Vijaybhai Malabhai Bharwad, Central Circle – 2, B-58, Chandramani Apartment, Surat. Udhana Magdalla Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent) आयकर(खोज-और-ज"ती)अपील सं It(Ss)A Nos.90/Srt/2022 (Assessment Year: 2014-15) Vijaybhai Malabhai Bharwad, Vs. The Dcit, B-58, Chandramani Apartment, Central Circle – 3, Udhana Magdalla Road, Surat. Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aclpv4173C (Appellant) (Respondent)

reassess the income of the other person in accordance with the provision of section 153A of the Act. The Assessing Officer has duly recorded the satisfaction for issuing the notice u/s 153C of the Act. Further, it is not the contention of the assessee that the Assessing Officer has not recorded the satisfaction in the assessee's case

DIVYABEN PRAFULCHANDRA PARMAR,SURAT vs. INCOME TAX OFFICER, WARD 1(3)(1), SURAT

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.73/Srt/2023 (Assessment Year: 2014-15) (Physical Hearing) Divyaben Prafulchand Parmar, Vs. The Ito, Ward-1(3)(1), 1-2, Harikrishna Niwas, B/H Braham Surat. Kumari Ashram, Bhatar Road, Surat – 395017. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acbpp9559Q (Appellant) (Respondent)

reassessment proceeding for A.Y. 2016-17 is also going on, at present, in my case. A SMS was received somewhere in January 2023, from the department that notice/letter/communication have been served on portal which requires e- compliance from my side. At that time, my consultant has looked in to the portal under my ID and Password. At that time