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

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time- line was also demonstrated in para 112 of the order with an illustration. In the present case

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

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

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

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

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

JASODADEVI RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WD.-2(2)(2), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

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

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

NAVINBHAI RATILAL IDRIA,SURAT vs. ITO, WARD 2(3)(4), SURAT

In the result, the appeal filed by the Assessee is hereby allowed

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

section 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2014-15. I.T.A No. 694//SRT/2025 Α.Υ. 2025-26 Navinbhai Ratilal Idria vs. ITO Page No 2 2. The registry has noted that there is a delay of 362 days in filing the above appeal. The assessee explained

SHRI HARSHADBHAI VALLABHBHAI PATEL,VALSAD vs. INCOME TAX OFFICER WARD-3, VALSAD

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

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.194/Srt/2017 & 356/Srt/2019 िनधा"रणवष"/Assessment Year:2009-10 & 2010-11 Shri Harshadbhai Vallabhai V. Income Tax Officer, Patel , Ward- 3, Valsad At & Post Tighra, Nava Falia, Via- Dungari Valsad 393 375 Pan: [Afspp 8443 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Rajesh M. Upadhyay, Itp िनधा"रतीक"ओरसे /Assessee By Mrs. Anupama Singla, Sr.D.R. राज"वक"ओरसे /Revenue By 09.12.2019 सुनवाईक"तारीख/ Date Of Hearing 10.12.2019 उ"ोषणाक"तारीख/Pronouncement On आदेश /O R D E R Per O. P. Meena, Am: 1. The Above Captioned Two Appeal By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals)- Valsad [In Short “The Cit(A)”] Dated 06.09.2017 & 20.05.2019 Pertaining To Assessment Year 2009-10 & 2010-11 Respectively, Which In Turn Has Arisen From The Separate Assessment Orders Passed Under Section 143 (3) Read With Section 147 Of Income Tax Act, 1961 (In Short ‘The Act’) By The Income Tax Officer, Ward- -3, Valsad (In Short “The Ao”).

section 148 of the Act. 16. Learned Counsel submitted that reopening of assessment has been made on the basis of cash deposits in bank account which cannot be basis for reopening of assessment as held in the case of Shri Ravindrasinh N Gohil v. ITO Wd-1(1) Bhavnagar [I.T.A.No. 33343&3344/AHD/2015 dated 04.09.2019 and Shri Bahadur Singh Sijwali

SHRI HARSHADBHAI VALLABHBHAI PATEL,VALSAD vs. INCOME TAX OFFICER WARD-2, VALSAD

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

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.194/Srt/2017 & 356/Srt/2019 िनधा"रणवष"/Assessment Year:2009-10 & 2010-11 Shri Harshadbhai Vallabhai V. Income Tax Officer, Patel , Ward- 3, Valsad At & Post Tighra, Nava Falia, Via- Dungari Valsad 393 375 Pan: [Afspp 8443 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Rajesh M. Upadhyay, Itp िनधा"रतीक"ओरसे /Assessee By Mrs. Anupama Singla, Sr.D.R. राज"वक"ओरसे /Revenue By 09.12.2019 सुनवाईक"तारीख/ Date Of Hearing 10.12.2019 उ"ोषणाक"तारीख/Pronouncement On आदेश /O R D E R Per O. P. Meena, Am: 1. The Above Captioned Two Appeal By The Assessee Are Directed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals)- Valsad [In Short “The Cit(A)”] Dated 06.09.2017 & 20.05.2019 Pertaining To Assessment Year 2009-10 & 2010-11 Respectively, Which In Turn Has Arisen From The Separate Assessment Orders Passed Under Section 143 (3) Read With Section 147 Of Income Tax Act, 1961 (In Short ‘The Act’) By The Income Tax Officer, Ward- -3, Valsad (In Short “The Ao”).

section 148 of the Act. 16. Learned Counsel submitted that reopening of assessment has been made on the basis of cash deposits in bank account which cannot be basis for reopening of assessment as held in the case of Shri Ravindrasinh N Gohil v. ITO Wd-1(1) Bhavnagar [I.T.A.No. 33343&3344/AHD/2015 dated 04.09.2019 and Shri Bahadur Singh Sijwali

GAURAVA MISHRA,RAIPUR vs. ITO, WARD 3(2)(8), SURAT

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.104/Srt/2025 Assessment Year: (2012-13) (Hybrid Hearing) Gaurav Mishra, Vs. Ito, Present Address: - Ward -3 (2)(8), 80, Bayshore Road, Unit No.28, Surat (Costa Del Sol), Singapore – 46992 Permanent Address: 605, Spathik Shilla, Sundar Nagar Purani Basti, So Raipur – 492001, C.G., India "थायीलेखासं./जीआइआरसं./Pan/Gir No: Amkpm6042J (Appellant) (Respondent) Appellant By Shri Veekass Sharma, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 04/09/2025 Date Of Pronouncement 17/11/2025

194/-. Various statutory and show notices were issued and served upon the assessee. The assessee has taken loans for purchase of the property, i.e., (i) Rs.9,34,833/- from IDBI Bank, (ii) Rs.5,00,000/- from father, (iii) Rs.2,50,000/- from self- funding and (iv) Rs.34,46,019/- from DBS Singapore account to ICICI Bank. The assessee failed