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 or recomputation exceeds the tax on total income determined on the basis of regular assessment. Grounds of appeal raised in the appeal against the additions/disallowances made in the assessment order passed under section 14(3) which continue in the assessment order passed under section 143(3) read with section 147 of the Act. 6. On the facts

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 or recomputation exceeds the tax on total income determined on the basis of regular assessment. Grounds of appeal raised in the appeal against the additions/disallowances made in the assessment order passed under section 14(3) which continue in the assessment order passed under section 143(3) read with section 147 of the Act. 6. On the facts

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 or recomputation exceeds the tax on total income determined on the basis of regular assessment. Grounds of appeal raised in the appeal against the additions/disallowances made in the assessment order passed under section 14(3) which continue in the assessment order passed under section 143(3) read with section 147 of the Act. 6. On the facts

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 or recomputation exceeds the tax on total income determined on the basis of regular assessment. Grounds of appeal raised in the appeal against the additions/disallowances made in the assessment order passed under section 14(3) which continue in the assessment order passed under section 143(3) read with section 147 of the Act. 6. On the facts

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 or recomputation exceeds the tax on total income determined on the basis of regular assessment. Grounds of appeal raised in the appeal against the additions/disallowances made in the assessment order passed under section 14(3) which continue in the assessment order passed under section 143(3) read with section 147 of the Act. 6. On the facts

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

reassessment under section 147 could not be made after the expiry of four years from the end of the assessment year viz. after 31 March 2011 unless there has been any failure on part of the appellant to disclose fully and truly all material facts necessary for the assessment. 3.On the facts and in the circumstances of the case

ENVIRO TECHNOLOGY LTD.,,ANKLESHWAR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, BHARUCH CIRCLE-2,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

reassessment under section 147 could not be made after the expiry of four years from the end of the assessment year viz. after 31 March 2011 unless there has been any failure on part of the appellant to disclose fully and truly all material facts necessary for the assessment. 3.On the facts and in the circumstances of the case

ENVIRO TECHNOLOGY LIMITED,,ANKLESHWAR vs. THE ACIT.,BHARUCH CIRCLE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Bharuch Enviro Deputy Commissioner Of Infrastructure Ltd.117-118, Income Tax, Bharuch Vs Gidc Estate-393002 Circle, Pan : Aaacb 8075 F Assessee / Appellant Revenue /Respondent

reassessment under section 147 could not be made after the expiry of four years from the end of the assessment year viz. after 31 March 2011 unless there has been any failure on part of the appellant to disclose fully and truly all material facts necessary for the assessment. 3.On the facts and in the circumstances of the case

SHRI RATILAL KHUSHALDAS MALI,,NA vs. ARIVS.THE ACIT, NAVSARI CIRCLE,, NAVSARI

In the result, the appeal of the assessee for A

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1637,2123,2125,2127/Ahd/2014 िनधा"रण वष"/Assessment Year:1994-95,1995-96,1996-97 & 1997-98 Shri Ratilal Khushaldas Mali, Assistant Commissioner Of बनाम Opp. Hanuman Temple, Mota Income Tax, Navsari Vs. Bazar, Navsari Circle- Navsari Pan: [Adbpm 3081 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Hiren R. Vepari, Ca िनधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By Mrs. Anupama Singla, Sr.(Dr) सुनवाई क" तारीख/ Date Of Hearing: 04.12.2019 उ"ोषणा क" तारीख/Pronouncement On 11.12.2019

reassessment notice before the Commissioner (Appeals) and in fact, the assessee did so for availing that opportunity. [Para 7]. 11. In view of above discussion, we held that the reopening of assessment ground is s not maintainable at this stage as already stands decided and cannot be re-visited, nor there is any anomaly in following the due procedure, hence

SHRI RATILAL KHUSHALDAS MALI,,NA vs. ARIVS.THE ACIT, NAVSARI CIRCLE,, NAVSARI

In the result, the appeal of the assessee for A

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1637,2123,2125,2127/Ahd/2014 िनधा"रण वष"/Assessment Year:1994-95,1995-96,1996-97 & 1997-98 Shri Ratilal Khushaldas Mali, Assistant Commissioner Of बनाम Opp. Hanuman Temple, Mota Income Tax, Navsari Vs. Bazar, Navsari Circle- Navsari Pan: [Adbpm 3081 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Hiren R. Vepari, Ca िनधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By Mrs. Anupama Singla, Sr.(Dr) सुनवाई क" तारीख/ Date Of Hearing: 04.12.2019 उ"ोषणा क" तारीख/Pronouncement On 11.12.2019

reassessment notice before the Commissioner (Appeals) and in fact, the assessee did so for availing that opportunity. [Para 7]. 11. In view of above discussion, we held that the reopening of assessment ground is s not maintainable at this stage as already stands decided and cannot be re-visited, nor there is any anomaly in following the due procedure, hence

SHRI RATILAL KHUSHALDAS MALI,,NA vs. ARIVS.THE ACIT, NAVSARI CIRCLE,, NAVSARI

In the result, the appeal of the assessee for A

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1637,2123,2125,2127/Ahd/2014 िनधा"रण वष"/Assessment Year:1994-95,1995-96,1996-97 & 1997-98 Shri Ratilal Khushaldas Mali, Assistant Commissioner Of बनाम Opp. Hanuman Temple, Mota Income Tax, Navsari Vs. Bazar, Navsari Circle- Navsari Pan: [Adbpm 3081 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Hiren R. Vepari, Ca िनधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By Mrs. Anupama Singla, Sr.(Dr) सुनवाई क" तारीख/ Date Of Hearing: 04.12.2019 उ"ोषणा क" तारीख/Pronouncement On 11.12.2019

reassessment notice before the Commissioner (Appeals) and in fact, the assessee did so for availing that opportunity. [Para 7]. 11. In view of above discussion, we held that the reopening of assessment ground is s not maintainable at this stage as already stands decided and cannot be re-visited, nor there is any anomaly in following the due procedure, hence

SHRI RATILAL KHUSHALDAS MALI,,NA vs. ARIVS.THE ACIT, NAVSARI CIRCLE,, NAVSARI

In the result, the appeal of the assessee for A

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.1637,2123,2125,2127/Ahd/2014 िनधा"रण वष"/Assessment Year:1994-95,1995-96,1996-97 & 1997-98 Shri Ratilal Khushaldas Mali, Assistant Commissioner Of बनाम Opp. Hanuman Temple, Mota Income Tax, Navsari Vs. Bazar, Navsari Circle- Navsari Pan: [Adbpm 3081 F] अपीलाथ" Appellant ""यथ"/Respondent Shri Hiren R. Vepari, Ca िनधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By Mrs. Anupama Singla, Sr.(Dr) सुनवाई क" तारीख/ Date Of Hearing: 04.12.2019 उ"ोषणा क" तारीख/Pronouncement On 11.12.2019

reassessment notice before the Commissioner (Appeals) and in fact, the assessee did so for availing that opportunity. [Para 7]. 11. In view of above discussion, we held that the reopening of assessment ground is s not maintainable at this stage as already stands decided and cannot be re-visited, nor there is any anomaly in following the due procedure, hence

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

234B of the Act is also wrong and unjustified. Appellant prays for deleting the same. 6. At the outset, Shri Ramesh Malpani, ld.AR of the assessee submitted the notice u/s 148 of the Act issued by the Assessing Officer was time barred. The Ld. AR submitted that the initial notice u/s 148 of the Act was issued on 28.06.2021, which

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

234B of the Act is also wrong and unjustified. Appellant prays for deleting the same. 6. At the outset, Shri Ramesh Malpani, ld.AR of the assessee submitted the notice u/s 148 of the Act issued by the Assessing Officer was time barred. The Ld. AR submitted that the initial notice u/s 148 of the Act was issued on 28.06.2021, which

MANISH BHOGILAL SHAH,MUMBAI vs. INCOME TAX OFFICER-3, NAVSARI, NAVSARI

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.687/Srt/2025 िनधा"रण वष" /Assessment Year : 2017-18 Manish Bhogilal Shah The Income Tax Officer-3 बनाम/ 6/B, Crown Mansion Navsari – 396 445 V/S. Ground Floor Forjeet Street, Cross Lane, Mumbai – 400 026 "थायी लेखा सं./Pan: Acqps 6699 F (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Himanshu Gandhi, Ca Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08 /12/2025 घोषणा की तारीख /Date Of Pronouncement: 27 /02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 27/12/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal: Manish Bhogilal Shah Vs. Ito Asst. Year : 2017-18 2

234B, 234C and 234D of the Income Tax Act, 1961. 2. Ground 8. On the facts and circumstances of the case and in law, the Ld.CIT(A) erred in confirming invocation of penalty provisions under Section 271AAC, 270A and 272A(1)(d) of the Income Tax Act, 1961. 3. Ground 9. Appellant craves leave to add further grounds

M/S. SHANGRILA LATEX INDUSTRIES LIMITED,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX - 4, SURAT

In the result, appeal filed by the assessees is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.38/Srt/2017 Assessment Year: (2006-07) (Physical Court Hearing) Shangrila Latex Industries Limited, Vs. The Acit, Circle-4, C/O. B.M. Parekh & Co., 203, 2Nd Surat. Floor, Navjivan Society, Bldg. No. 03, Lamington Road, Mumbai-400008. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaics1479E (Appellant) (Respondent) Assessee By Shri Sanjay S. Kapadia, Ca Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 01/07/2022 28/09/2022 Date Of Pronouncement

section 143(3) r.w.s 147 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 31.03.2014. 2. Grounds of appeal raised by the assessee are as follows: “1. On the facts and circumstances of the case and in law, the ld. CIT(A) has erred in confirming the addition of Rs.3,63,65,889/- on account

JAYENDRASINH BHIKHUBHAI SOLANKI,SILVASSA vs. INCOME TAX OFFICER- SILVASSA, SILVASSA

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Pawan Singh, Jidicial Member & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1244/Srt/2024 Assessment Year: (2011-12) (Hybrid Processing Hearing) Jayendrasinh Bhikhubhai Solanki बनाम/ Income Tax Officer, Silvassa Ward, 37/3, Trimurti Bhavan, High School Vs. Income Tax Office, Vee Bee Mall, Faliya, Naroli, Silvassa-396 230 Near Civil Court, Tokarkhada, Silvassa -396 230 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Angps 4011 C (अपीलाथ"/Appellant) (""थ" /Respondent)

reassessment proceeding under section 147 of Income Tax Act, 1961. 3. On the facts and circumstances of the case and law, the Ld. CIT(A) failed to consider that no other addition is permissible, if no addition made on basis of reasons recorded for reopening. 4. On the facts and circumstances of the case and law, the Ld.CIT(A) erred

DESIGNER EXIM PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER, 1(1)(2), SURAT

In the result, this appeal of the assessee is allowed

Bench: Shri Pawan Singh(Physical Hearing) M/S Designer Exim Pvt. Ltd., I.T.O., D-1203, Panchsheel Heights, Opp.- Ward 1(1)(2), Vs. Pizza Hut, Mahavir Nagar, Kandivali Surat. West, Mumbai, Maharashtra-400067 Pan No. Aabcd 4298 H Appellant/ Assessee Respondent/ Revenue

234B, 234C and 234D of the Act. 6. The appellant crave leave to add, amend, alter and / or vary any of the grounds of appeal before or at the time of hearing.” 2. Brief facts of the case are that the assessee is a company, engaged in export of fabric and dress material, filed its return of income on 29/09/2012

GANI MOHAMMAD POPAT,SURAT vs. ITO, WARD-3, VAPI

In the result, grounds No

Bench: Shri Pawan Singh(Virtual Hearing) Popat Yasin Abdulganibhai, I.T.O., Son & L/H Of Late Gani Mohammad Ward-3, Vs. Popat, Vapi. Bombay Market, Zanda Chowk, Near S.T. Bus Depot, Vapi. Pan No. Akvpp 0747 J Appellant/ Assessee Respondent/ Revenue

234B of the Act. 12. The learned CIT(A) erred in fact and in law in confirming the action of the Id. AO in initiating penalty u/s 271(1)(c) of the Act. 13. Your appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 2. Initially