PISTABEN RAJMAL JAIN,SURAT vs. DCIT, CIRCLE 1(3), SURAT

In the result, both the appeals filed by the assessee are dismissed

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 635 & 703/Srt/2025 A. Y. 2013-14 & 2014-15

Section 251(1)(a) of the Act effective from 01.10.2024. 6. It is therefore prayed that assessment framed u/s. 147 r.w.s. 144 may please be quashed and/or addition made by the assessing officer may please be deleted. 7. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal

PISTABEN RAJMAL JAIN,SURAT vs. DCIT, CIRCLE 1(3), SURAT

In the result, both the appeals filed by the assessee are dismissed

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 635 & 703/Srt/2025 A. Y. 2013-14 & 2014-15

Section 251(1)(a) of the Act effective from 01.10.2024. 6. It is therefore prayed that assessment framed u/s. 147 r.w.s. 144 may please be quashed and/or addition made by the assessing officer may please be deleted. 7. Appellant craves leave to add, alter or delete any ground(s) either before or in the course of hearing of the appeal

ARUN KUMAR GUPTA,KANPUR vs. THE ASSTT. COMMISSIONER OF INCOME TAX CIRCLE-3(2), SURAT, SURAT

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

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita No.9/Srt/2025 Assessment Year: 2012-13 (Hybrid Hearing) Arun Kumar Gupta Assistant Commissioner Of बनाम/ Flat No.316, Srishti Suyraj Income-Tax, Circle-3(2), Surat, 4Th Vs. Apartment, G.T. Road, Floor, Room No.410, Aayakar Ramadevi, Kanpur-208 007 Bhawan, Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Afapg 2389 D (अपीलाथ"/Appellant) (""थ" /Respondent)

section 251(1) of the Act w.e.f. October 1, 2024 which empowers the CIT(A) to set aside an assessment order u/s 144 of the Act and refer the case back to the AO for fresh assessment. Accordingly, the order passed u/s 144 of the Act was set aside to AO for fresh assessment after providing adequate opportunity of being

VANMALIBHAI MULJIBHAI PATEL L/H RANJANBEN DEEPAKBHAI PATEL,NA vs. ARIVS.ITO, WARD 5, NAVSARI

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.345/Srt/2025 Assessment Year: (2011-12) (Hybrid Hearing) Vanmalibhai Muljibhai Patel, Vs. Ito, L/H Of Ranjanben Deepakbhai Patel Ward - 5, 16, Shrinikunj Society, Ashabaug, Navsari Navsari - 396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abjpp3114G (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Ms. Jayshree Thakur, Sr. Dr Date Of Hearing 23/09/2025 Date Of Pronouncement 04/12/2025

251(1) of the Act wherein it is stipulated that in cases where an order was passed as a ‘best judgment’ assessment u/s 144 of the Act, the CIT(A) is vested with the authority to set aside such assessment and remand the matter to AO for fresh evaluation. He also referred to the decision of Hon’ble Supreme Court

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

section 251(1) of the Act wherein it is stipulated that in cases where an order was passed as a ‘best judgment’ assessment u/s 144 of the Act, the CIT(A) is vested with the authority to set aside such assessment and remand the matter to AO for fresh evaluation. Accordingly, he exercised the powers conferred upon him u/s 251

BALDEVRAJ JAMMURAM AHUJA,SURAT vs. INCOME TAX OFFICER, WARD 1(2)(1), SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.178/Srt/2017 ("नधा"रणवष" / Assessment Years: (2008-09) (Virtual Court Hearing) Baldevraj Jamnuram Ahuja, Vs. The Ito, Ward-1(2)(1), Shop No.B/4073, Millenium Tex Surat. Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aazpa7998J (Assessee) (Respondent) Assessee By : Ms Rushi Parekh, Ar Revenue By : Ms Anupama Singhla, Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing : 14/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 25/05/2022

section 147 of the Act, does not require interference, therefore we confirm the findings of ld CIT(A). 10. So far merit is concerned, we note that during the reassessment stage, the assessee did not file the evidence to the effect that he had paid the loan subsequently. The ld Counsel submitted that assessee has repaid the loan along with

SHRI GHANSHYAM DUNGARBHAI SUTARIYA,,SURAT vs. THE ACIT, CIRCLE-8,, SURAT

In the result, the appeal of the Assessee is dismissed

Bench: Shri H.S. Sidhu & Shri O.P. Meenaassessment Year: 2009-10 Ghanshyam Dungarbhai Sutaria, Vs. Acit, Circle-8, H.No. 1, 1St Floor, Sahaj Park Row Surat House, Hira Baug Circle, Vallabhacharya Road, Near Kailashdham Society, Ashwanikumar Road, Surat-395008 (Pan: Akkpp9318E) (Appellant) (Respondent)

251(1) of the Act for the benefit of telescoping of income/outgoings. The benefit of the telescoping was not given to the assessee as the assessee had not, filed any return of income. No balance sheet had been filed by the assessee to show the assets and liabilities. The income from the various sources earned by the assessee i.e., income

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

251 of the Act.” 5. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals) disallowing the claim of exemption under section 12A Jayshri Gopallal Maharajshrini Surat Srusti Trust vs. ITO (E) Asst. Year –2022-23 - 4– of the Act on account of delay in filing of Form 10B, along with return of income

M/S. RUCHI SAREES PVT. LTD.,SURAT vs. INCOME TAX OFFICER, WARD 2(1)(1), , SURAT

In the result, ground No. 1 of the appeal is also dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

251 (Gujarat) and in DCIT Vs Rohini Builders 256 ITR 230 (Guj). The Assessing officer further noted that the assessee sought cross examination of Shri Maheshbhai Tulshibhai Patel and Shri Ramesh Rangildas Mehta. The statements of both the persons were recorded by Assessing Officer by issuing summons under Section 131 of the Act on 21/08/2017 and 22/08/2017. After recording their

M/S. RUCHI SAREES PVT. LTD.,SURAT vs. INCOME TAX OFFICER, WARD 2(1)(1), , SURAT

In the result, ground No. 1 of the appeal is also dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

251 (Gujarat) and in DCIT Vs Rohini Builders 256 ITR 230 (Guj). The Assessing officer further noted that the assessee sought cross examination of Shri Maheshbhai Tulshibhai Patel and Shri Ramesh Rangildas Mehta. The statements of both the persons were recorded by Assessing Officer by issuing summons under Section 131 of the Act on 21/08/2017 and 22/08/2017. After recording their

M/S. RUCHI SAREES PVT. LTD.,SURAT vs. INCOME TAX OFFICER, WARD 2(1)(1), , SURAT

In the result, ground No. 1 of the appeal is also dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

251 (Gujarat) and in DCIT Vs Rohini Builders 256 ITR 230 (Guj). The Assessing officer further noted that the assessee sought cross examination of Shri Maheshbhai Tulshibhai Patel and Shri Ramesh Rangildas Mehta. The statements of both the persons were recorded by Assessing Officer by issuing summons under Section 131 of the Act on 21/08/2017 and 22/08/2017. After recording their

M/S. RUCHI SAREES PVT. LTD.,SURAT vs. INCOME TAX OFFICER, WARD 2(1)(1), , SURAT

In the result, ground No. 1 of the appeal is also dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

251 (Gujarat) and in DCIT Vs Rohini Builders 256 ITR 230 (Guj). The Assessing officer further noted that the assessee sought cross examination of Shri Maheshbhai Tulshibhai Patel and Shri Ramesh Rangildas Mehta. The statements of both the persons were recorded by Assessing Officer by issuing summons under Section 131 of the Act on 21/08/2017 and 22/08/2017. After recording their

MR. ROLHAN SANJAY PATEL,SURAT vs. INCOME TAX OFFICER, WARD - 1(3)(4), SURAT

Bench: Shri Pawan Singh(Virtual Hearing) Rohan Sanjay Patel, I.T.O., “Sanket” Bungalow, Ward 1(3)(4), Vs. Near Bungalow No. 122 Of Sarjan Surat. Society, Opposite Science Centre, City Light Road, Surat-395007. Pan No. Ascpp 8025 C Appellant/ Assessee Respondent/ Revenue

reassessment order passed by the ld. Assessing Officer and upheld by the ld. CIT(A) is against the facts of the case, bad in law, illegal and needs to be quashed. 2. On the facts of the case and in law, both the A.O. and ld. CIT(A) erred in appreciating the facts of the case, materials adduced and evidences

PRIME CO OPERATIVE BANK LTD,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), SURAT

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.19/Srt/2025 Assessment Year: 2013-14 (Hybrid Hearing) Prime Co-Operative Bank Ltd., Vs. Acit, Khatodra, Ring Road, Surat – Circle-1(1)(1), 395002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcp7117M (Appellant) (Respondent) Appellant By Shri Hiren Vepari, Ca Respondent By Shri Aashish Pophare, Cit-Dr Date Of Hearing 12/08/2025 Date Of Pronouncement 10/11/2025

reassessment order being passed by JAO instead of FAO, the order is required to be cancelled. (3) The SFT filers having made error in reporting the transactions under the wrong surrendered PAN should have not led to the addition in the hands of the appellant. ITA No.19/SRT/2025/AY 2013-14 Prime Co-op. Bank Ltd. (II) Reopening (1) The reopening

M D INDUSTRIES PVT LTD,SURAT vs. DCIT, CIRCLE -1, SURAT

In the result, Eight appeals of the Assessee are allowed for statistical purpose

Bench: Shri Sandeep Gosain & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.497 To 503 & 527/Srt/2019 "नधा"रण वष"/Assessment Years: 1999-2000 To 2005-06 & 2000-01 M/S.M.D.Industries Pvt. Ltd., V Deputy Commissioner Of B-5, Rangnagar Society, S Income Tax, Circle-1, Surat. Lambe Hanuman Road, Surat. . [Pan: Aabcm 6026 G] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Vijay Mehta – Ca & Mrs. Sneha M.Padhiar – Ca राज"वक"ओरसे /Revenue By Shri O.P.Singh – Cit-Dr सुनवाईकीतारीख/ Date Of Hearing: 04.12.2019 उ"घोषणाक"तार"ख/Pronouncement On: 06.12.2019 आदेश /O R D E R Per Sandeep Gosain, Jm: 1. This Eight Appeals By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Surat Dated 06.09.2007 & 28.10.2009 For The Assessment Years 1999- 2000 To 2005-06 & 2000-01 Respectively.

251 ITR 791, 798-799 (Cal)] (vii) J.M. Bhansali and Ors v. The State of Madras (21 STC 411) (viii) Cheminor Drugs Ltd. v. DCIT [105 ITD 613 (Hyd)] 16. We further pray before Your Honours that the reasons in delay of filing of this appeal is similar to those decided by the Hon'ble ITAT in earlier appeals

M D INDUSTRIES PVT LTD,SURAT vs. DCIT, CIRCLE -1, SURAT

In the result, Eight appeals of the Assessee are allowed for statistical purpose

Bench: Shri Sandeep Gosain & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.497 To 503 & 527/Srt/2019 "नधा"रण वष"/Assessment Years: 1999-2000 To 2005-06 & 2000-01 M/S.M.D.Industries Pvt. Ltd., V Deputy Commissioner Of B-5, Rangnagar Society, S Income Tax, Circle-1, Surat. Lambe Hanuman Road, Surat. . [Pan: Aabcm 6026 G] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Vijay Mehta – Ca & Mrs. Sneha M.Padhiar – Ca राज"वक"ओरसे /Revenue By Shri O.P.Singh – Cit-Dr सुनवाईकीतारीख/ Date Of Hearing: 04.12.2019 उ"घोषणाक"तार"ख/Pronouncement On: 06.12.2019 आदेश /O R D E R Per Sandeep Gosain, Jm: 1. This Eight Appeals By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Surat Dated 06.09.2007 & 28.10.2009 For The Assessment Years 1999- 2000 To 2005-06 & 2000-01 Respectively.

251 ITR 791, 798-799 (Cal)] (vii) J.M. Bhansali and Ors v. The State of Madras (21 STC 411) (viii) Cheminor Drugs Ltd. v. DCIT [105 ITD 613 (Hyd)] 16. We further pray before Your Honours that the reasons in delay of filing of this appeal is similar to those decided by the Hon'ble ITAT in earlier appeals

M D INDUSTRIES PVT LTD,SURAT vs. DCIT, CIRCLE -1, SURAT

In the result, Eight appeals of the Assessee are allowed for statistical purpose

Bench: Shri Sandeep Gosain & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.497 To 503 & 527/Srt/2019 "नधा"रण वष"/Assessment Years: 1999-2000 To 2005-06 & 2000-01 M/S.M.D.Industries Pvt. Ltd., V Deputy Commissioner Of B-5, Rangnagar Society, S Income Tax, Circle-1, Surat. Lambe Hanuman Road, Surat. . [Pan: Aabcm 6026 G] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Vijay Mehta – Ca & Mrs. Sneha M.Padhiar – Ca राज"वक"ओरसे /Revenue By Shri O.P.Singh – Cit-Dr सुनवाईकीतारीख/ Date Of Hearing: 04.12.2019 उ"घोषणाक"तार"ख/Pronouncement On: 06.12.2019 आदेश /O R D E R Per Sandeep Gosain, Jm: 1. This Eight Appeals By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Surat Dated 06.09.2007 & 28.10.2009 For The Assessment Years 1999- 2000 To 2005-06 & 2000-01 Respectively.

251 ITR 791, 798-799 (Cal)] (vii) J.M. Bhansali and Ors v. The State of Madras (21 STC 411) (viii) Cheminor Drugs Ltd. v. DCIT [105 ITD 613 (Hyd)] 16. We further pray before Your Honours that the reasons in delay of filing of this appeal is similar to those decided by the Hon'ble ITAT in earlier appeals

M D INDUSTRIES PVT LTD,SURAT vs. DCIT, CIRCLE -1, SURAT

In the result, Eight appeals of the Assessee are allowed for statistical purpose

Bench: Shri Sandeep Gosain & Shri O.P.Meenaआ.अ.सं./I.T.A No’S.497 To 503 & 527/Srt/2019 "नधा"रण वष"/Assessment Years: 1999-2000 To 2005-06 & 2000-01 M/S.M.D.Industries Pvt. Ltd., V Deputy Commissioner Of B-5, Rangnagar Society, S Income Tax, Circle-1, Surat. Lambe Hanuman Road, Surat. . [Pan: Aabcm 6026 G] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Vijay Mehta – Ca & Mrs. Sneha M.Padhiar – Ca राज"वक"ओरसे /Revenue By Shri O.P.Singh – Cit-Dr सुनवाईकीतारीख/ Date Of Hearing: 04.12.2019 उ"घोषणाक"तार"ख/Pronouncement On: 06.12.2019 आदेश /O R D E R Per Sandeep Gosain, Jm: 1. This Eight Appeals By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-1, Surat Dated 06.09.2007 & 28.10.2009 For The Assessment Years 1999- 2000 To 2005-06 & 2000-01 Respectively.

251 ITR 791, 798-799 (Cal)] (vii) J.M. Bhansali and Ors v. The State of Madras (21 STC 411) (viii) Cheminor Drugs Ltd. v. DCIT [105 ITD 613 (Hyd)] 16. We further pray before Your Honours that the reasons in delay of filing of this appeal is similar to those decided by the Hon'ble ITAT in earlier appeals