INCOME TAX OFFICER, WARD-2(3)(8), SURAT vs. MAHAVEER SHANTILAL JAIN, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.453/Srt/2019 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) The Ito, Vs. Mahaveer Shantilal Jain, Ward-2(3)(8), Prop. M/S Mukesh Diamonds, 1St Surat. Office No.401, Floor, H.No.5/1171/72/73/1090, New Dtc, Hath Falia, Haripura, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqupj6439L Appellant By Shri Ritesh Mishra, Cit(Dr) Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 08/09/2023 Date Of Pronouncement 25/09/2023

b) of sub- section (4) of section 120 to exercise or perform all or any of the powers and functions conferred on, or assigned to, an assessing officer under this Act. In the instant case, the order of assessment was challenged on several grounds and, particularly, on the ground that no notice under section

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

4 are\ndismissed.\n40.\nGround Nos. 5 to 8 of the Revenue are in respect of unaccounted\npayment for purchase of property plot no. 224 at Kumbharia for\nRs.23,38,04,101/-. These grounds are similar to the grounds raised by the\nrevenue in IT(SS)A No.41/SRT/2023 (AY 2017-18) decided above by us in this\norder. In view

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

In the result, assessee's appeal is allowed

reassessment proceedings, if the twin\nconditions prescribed under Section 147 of the Act are satisfied.\n23. In fact, in three recent judgments; the Hon'ble Gujarat High Court has upheld\nthe reopening on similar facts. The case is squarely covered against the assessee by\nthese judgments which are:\n•\nYogendrakumar Gupta vs. ITO 366 ITR 186 (Guj)\n•\nPeass Industrial

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

reassessment proceedings, if the twin conditions prescribed under Section 147 of the Act are satisfied. 23. In fact, in three recent judgments; the Hon'ble Gujarat High Court has upheld the reopening on similar facts. The case is squarely covered against the assessee by these judgments which are: • Yogendrakumar Gupta vs. ITO 366 ITR 186 (Guj) • Peass Industrial Engineers

HITESH DAHYABHAI PATEL,NA vs. ARIVS.ITO (INT. TAX.), SURAT, ADAJAN

In the result, the appeals filed the Assessee are allowed for statistical purpose

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

reassessment orders passed under section 147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2011-12 & 2012-13. I.T.A Nos. 120 & 121/SRT/2025 A.Ys. 2011-12 & 2012-13 Page No 2 Hitesh Dahyabhai Patel vs. ITO (Int. Tax.) 2. Ld. Counsel Shri Rasesh Shah appearing for the assessee submitted that

HITESH DAHYABHAI PATEL,NA vs. ARIVS.ITO (INT. TAX.), SURAT, ADAJAN

In the result, the appeals filed the Assessee are allowed for statistical purpose

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

reassessment orders passed under section 147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2011-12 & 2012-13. I.T.A Nos. 120 & 121/SRT/2025 A.Ys. 2011-12 & 2012-13 Page No 2 Hitesh Dahyabhai Patel vs. ITO (Int. Tax.) 2. Ld. Counsel Shri Rasesh Shah appearing for the assessee submitted that

DY. COMMISSIONER OF INCOME TAX, CENTRA CIR.2, SURAT vs. DAGINA JEWELLERS INDIA PVT. LTD., SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT vs. M/S. DAGINA JEWELLERS PVT. LTD., , SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

DAGINA JEWELLERS INDIA (P) LTD.,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,2, SURAT

In the result, grounds Nos

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

b) Summarized and Concise ground of appeals for ITA No.30/SRT/2022, AY.2017-18(assessee’s appeal) are as follows: (i) Ground no.1: Not pressed by the assessee. (ii) Ground No.2: CIT(A) erred in assuming addition on account of excess stock found during the survey proceedings to the extent of Rs.4,67,19,066/- as discussed in para

NARESHKUMAR B. AGARWAL,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT

4,70,808/-\nRs.14,33,84,721/-\n60.\nAggrieved by the order of AO, assessee filed appeal before CIT(A) who\nvide order dated 30.12.2022 enhanced the first and second additions of\nRs.25,00,000/- and Rs.3,18,750/- to Rs.45,00,000/- and Rs.6,16,250/-\nrespectively. The addition of Rs.1,08,11,000/- was restricted to Rs.14