KANCHAN DEVI AGARWAL,SURAT vs. ITO, WARD 1(2)(1), SURAT

The appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Bijayananda Pruseth

144B of the Act, which are invalid and bad in law ab initio. Appellant prays for quashing the same. 2. Without prejudice to above grounds of appeal, that on the facts and in the circumstances of the case as well as in law, the Id. CIT (A) has erred in upholding the addition

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)

reassessment proceeding and the assessment order passed under Section 147 read with Section 144B of the Act, is quashed.” I.T.A

TULSI JEWELLERS,NA vs. ARIVS.INCOME TAX OFFICER - WARD 5, NAVSARI

In the result assessee's appeal is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

reassessment order u/s 147 r.w.s 144B dated 11.05.2023 are quashed, being violative of the provisions contained in Sections 148A(d), 148 and 151(ii) of the Act. This

TULSI JEWELLERS,NA vs. ARIVS.INCOME TAX OFFICER, WARD 5, NAVSARI

In the result assessee's appeal is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

reassessment order u/s 147 r.w.s 144B dated 11.05.2023 are quashed, being violative of the provisions contained in Sections 148A(d), 148 and 151(ii) of the Act. This

INCOME TAX OFFICER, WARD-1(2)(1), SURAT, SURAT vs. DEEPESH VISHNU AGARWAL, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.833/Srt/2024

reassessment notices to travel back in time to their original date when such Notices were to be issued and then Section 149 of the Amended regime is to be applied at that point of time, and the Ld CIT(A) has not appreciated that TOLAas well as provisions of the Finance Act, 2021 is applicable simultaneously. v. On the facts

KAMAKSHI DIAMONDS PRIVATE LIMITED,SURAT vs. ITO WARD 1(1)(3), SURAT

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.994/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) Kamakshi Diamonds Pvt. Ltd. Income Tax Officer, Ward- बनाम/ Office No.203, 2Nd Floor 1(1)(3), Surat, Aaykar Bhawan, Vs. Panchratna Apartment, Majura Gate, Opp. New Civil Dalgrya Sheri, Mahindrapura, Hospital, Surat-395 001 Surat-395 003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaeck 0477 A (अपीलाथ"/Appellant) (""थ" /Respondent)

144B of the Act dated 30.05.2023. Grounds of appeal raised by the assessee are as under: “1. Whether on the facts and circumstances of the case, the notice issued by the learned Assessing Office under section 148 of the Act and the ITA No.994/SRT/2024/AY.16-17 Kamakshi Diamonds Pvt Ltd. consequential reassessment

AJAY KALISHCHANDRA BOHRA,DAMAN vs. PCIT, VALSAD

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 549/Srt/2024 (Ay 2017-18) (Physical Court Hearing) Ajay Kalishchandra Bohra Principal Commissioner Of Income- 1, Plot No.22B, Daman Industrial Tax, Valsad, 301, 3Rd Floor, Palak बनाम Estate, Somnath Road, Dabhel, Arcade, Shantinagar, Tithal Road, Vs Daman-396 215 Valsad-396 001 [Pan : Ackpb 2567 R] अपीलाथ"/Appellant ""थ" /Respondent

section 147 r.w.s. 144B of the Act dated 26.03.2022. The assessee has raised the following grounds of appeal: “1. The Ld. PCITE, Valsad has erred and was not just and proper on the facts of the case and I law in considering the assessment order dated 28.03.2022 passed u/s 147 r.w.s 144B as erroneous and prejudicial to the interest

VIVEK KHABIA,SURAT vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, ground No. 3 is allowed and ground No

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 1072/Srt/2024 (Ay 2018-19) (Physical Court Hearing) Vivek Khabia Income Tax Officer, Ward- H.No.1187-90-91, 1089, Office 2(3)(4), Surat, Aaykar Bhavan, बनाम No.411, New Dtc Gheekanta Majura Gate, Surat-395 001 Vs Road, Nr. Bhavani Vad Temple, Haripura, Surat-395 003 [Pan : Avspk 5724 E] अपीलाथ"/Appellant ""थ" /Respondent

section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) 24.03.2023. The assessee has raised the following grounds of appeal:- “The appellant prefers an appeal against an order passed by Ld. Commissioner of Income-tax (Appeals), National Faceless Assessment Centre, Delhi dated 30.08.2024 on following amongst other grounds, each of which are without prejudice

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

144B with a direction to the assessing officer as per para no. 8 of the revision order to pass fresh assessment order after taking into consideration, the issues as may be considered together with the issues discussed in order. 3. It is therefore prayed that above order passed by Pr. CIT u/s. 263 may please be quashed or set aside

TIRATHRAJ RAJMURAT MAURYA,SURAT vs. INCOME TAX OFFICER, WARD 1(2)(6), SURAT

In the result, all the three appeals filed by the assessee are stands allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

144B by the National Faceless Assessment Centre (NFAC) is without jurisdiction and bad in law, as the NFAC had no statutory authority to frame assessments in faceless mode prior to 29-03-2022. 2. It is submitted the notice u/s. 142(1) of the Act was issued by National Faceless Assessment Centre, Delhi

TIRATHRAJ RAJMURAT MAURYA,SURAT vs. INCOME TAX OFFICER, WARD 1(2)(6), SURAT

In the result, all the three appeals filed by the assessee are stands allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

144B by the National Faceless Assessment Centre (NFAC) is without jurisdiction and bad in law, as the NFAC had no statutory authority to frame assessments in faceless mode prior to 29-03-2022. 2. It is submitted the notice u/s. 142(1) of the Act was issued by National Faceless Assessment Centre, Delhi

TIRATHRAJ RAJMURAT MAURYA,SURAT vs. INCOME TAX OFFICER, WARD 1(2)(6), SURAT

In the result, all the three appeals filed by the assessee are stands allowed for statistical purposes

Bench: Shri Sandeep Gosain & Shri Om Prakash Kant

144B by the National Faceless Assessment Centre (NFAC) is without jurisdiction and bad in law, as the NFAC had no statutory authority to frame assessments in faceless mode prior to 29-03-2022. 2. It is submitted the notice u/s. 142(1) of the Act was issued by National Faceless Assessment Centre, Delhi

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Principal Commissioner of Income Tax, Valsad [in short, ‘ld. PCIT’], dated 16.03.2024 for assessment years (AYs) 2014-15 and 2015-16. Since facts of the cases and the grounds taken up in the appeals are similar except variation in the amount, these appeals were heard

WIND FINANCIAL SERVICES LLP,DAMAN & DIU vs. PCIT, VALSAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.501 & 502/Srt/2024 (Ays: 2014-15 & 2015-16) (Hybrid Hearing) Wind Financial Services Llp, Vs. The Pcit, [Formerly Known Wind Financial Valsad Services Pvt. Ltd.] Shop No.102/A, 436 Sq Feet Built Up, Dabhel, Daman & Diu, Valsad – 396215 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadfw6369H (Appellant) (Respondent) Appellant By Shri S. N. Divetia, Ar Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 12/03/2025 Date Of Pronouncement 21/05/2025 आदेश / O R D E R Per Bijayananda Pruseth, Am: These Appeals By The Assessee Emanate From The Orders Passed Under Section 263 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) By The Learned Principal Commissioner Of Income Tax, Valsad [In Short, ‘Ld. Pcit’], Dated 16.03.2024 For Assessment Years (Ays) 2014-15 & 2015-16. Since Facts Of The Cases & The Grounds Taken Up In The Appeals Are Similar Except Variation In The Amount, These Appeals Were Heard Together & A Common Order Is Passed For The Sake Of Convenience & Brevity. Ita No. 501/Srt/2024 Is Taken As The ‘Lead Case’.

section 263 of the Income-tax Act, 1961 (in short, ‘the Act’) by the learned Principal Commissioner of Income Tax, Valsad [in short, ‘ld. PCIT’], dated 16.03.2024 for assessment years (AYs) 2014-15 and 2015-16. Since facts of the cases and the grounds taken up in the appeals are similar except variation in the amount, these appeals were heard

VISHNUBHAI CHELABHAI PATEL,SURAT vs. PCIT, SURAT-1, SURAT, SURAT

In the result, ground of appeal raised by the assessee are allowed

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth(Physical Hearing) Vishnubhai Chelabhai Patel, Pr.C.I.T.,Surat-1, F-19, Divya Jyoti Apartment, Surat. Vs. Samul Dairy Road, Alkapuri, Surat-395008 (Gujarat) Pan No. Adipp 4007 B Appellant/ Assessee Respondent/ Revenue

144B of the I. T. Act, 1961 dated 16.03.2022 with a direction to the assessing officer to pass fresh assessment order after taking into consideration the issues as may have been already considered together with the issue covered u/s 263 of the I. T. Act. 4. It is therefore prayed that order passed by Pr. Commissioner of Income

TIRUPATI SHYAM ENTERPRISE,SURAT vs. DCIT, CIRCLE 1(1)(1), SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2015-2016 Tirupati Shyam Enterprise Nfac, Delhi Current F.P. No. 139 Orleaans, Near Jurisdiction: Dy. Cit Circle- Sosyo Circle Udhna Magadalla Vs. 1(1)(1), Road, Surat-395007. Aayakar Bhavan, Near Majura Gate, Opp. New Civil Hospital, Surat-395001. Pan No. Aagft 3570 Q Appellant Respondent

144B may kindly be quashed and/or the additions made by the assessing officer may please be deleted or the made by the assessing officer may please be deleted or the made by the assessing officer may please be deleted or the case may be set aside to the file of the CIT(A) with ase may be set aside

SAROJ TILAKRAJ JUNEJA,SURAT vs. DCIT CIRCLE-1(1)(1), SURAT

In the result, appeal of the assessee is allowed for statistical purpose

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1048/Srt/2024 Assessment Year: (2014-15) (Physical Hearing) Saroj Tilakraj Juneja, Vs. The Dcit, 3, Subhas Nagar Society, Ghod Dod Road, Circle - 1(1)(1), Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abbpj5634M (Appellant) (Respondent) Appellant By Shri Kiran K. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 08/01/2025 Date Of Pronouncement 13/01/2025

reassessment proceedings by the Hon’ble Gujarat High Court for this particular year. 4. The appellant reserves right to add, alter and withdraw any grounds of appeal.” 3. The appeal filed by assessee is barred by 169 days in terms of provisions of section 253(3) of the Act. The learned Authorized Representative (ld. AR) filed an affidavit

JAYVADAN RUGHNATHWALA,SURAT vs. ITO, WARD-1(2)(1), SURAT

Bench: Ms. Suchitra Kamble & Shri Bijayananda Pruseth Assessment Year 2018-19

144B of the Act may kindly be quashed and/or addition made by the assessing officer and confirmed by CIT(A) may please be deleted. 5. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal.” 3. Information was received from the Investigation Wing that M/s. S.K. Enterprises (Prop

INCOME TAX OFFICER, WARD-1(3)(1), SURAT, ADAJAN, SURAT vs. CHANDUBHAI JADAVBHAI KORAT, SURAT

In the result, the appeal of the revenue is dismissed

Bench: Dinesh Mohan Sinha & Shri Bijayananda Pruseth(Hybrid Hearing) Ito, Vs. Chandubhai Jadavbhai Korat, Ward – 1(3)(1), 5, Raghuvir Bungalow, City Light Surat Road, Bharthana, B.O. Umra, Surat – 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abqpk7796L (Appellant) (Respondent) Co No.36/Srt/2024 (Ay 2015-16) (Arising Out Of Ita No.720/Srt/2024) Chandubhai Jadavbhai Korat, Vs. Ito, 5, Raghuvir Bungalow, City Light Road, Ward – 1(3)(1), Bharthana, B.O. Umra, Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abqpk7796L (Appellant) (Respondent) Appellant By Shri Mukesh Jain, Cit-Dr Respondent By Shri Rasesh Shah, Ca Date Of Hearing 02/09/2025 Date Of Pronouncement 21/11/2025

144B of the Act by making addition of Rs.5,53,36,885/-. 7. Aggrieved by the aforesaid assessment order, assessee preferred appeal before CIT(A). The CIT(A) deleted the addition treating the sale transactions of Rs.5,53,36,885/- in the impugned penny scrip stock as genuine transactions. He allowed the appeal of the assessee. 8. Aggrieved