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

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

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

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

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.

Sections 68 and 69 are not applicable for trading transactions like deposit of cash out of cash sales and excess closing stock. For that reliance can be placed on the judgment of Hon`ble Gujarat High Court in the case of Shilpa Dyeing & Printing Mills Ltd, Tax Appeal No. 290 of 2013, dated 04.04.2013. Therefore, we direct the Assessing Officer

URMILABEN THAKORDAS SOPARIWALA,SURAT vs. INCOME TAX OFFICER, SURAT

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

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-2013 Urmilaben Thakordas Ito Sopariwala, Aayakar Bhavan, Opp. New Civil 8/743, Hanuman Char Rasta, Vs. Hospital Majuragate, Gopipura, Surat-395001. Surat-395001. Pan No. Aprps 5313 J Appellant Respondent

reassessment was completed on 14.12.2019 wherein two additions wherein two additions were made by the Assessing Officer, were made by the Assessing Officer, firstly, for long term capital gain of Rs.29,40,658/ for long term capital gain of Rs.29,40,658/- and secondly and secondly, addition u/s 50C of the Act amounting to Rs.7,36,213/ the Act amounting