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)

2,06,000/- only. No other details such as balance sheet, bank statement etc were filed to substantiate his claim. In absence of any evidence, the amount of Rs. 14,85,000/- claimed to have been received from his wife Rasilaben, was considered as from undisclosed sources and was added to the income of the assessee. In addition to this

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)

reassessment order is void ab-initio and liable to be quashed. 9. That any other relief or reliefs as may be deemed fit on the facts on record, be granted.” 2. Facts of the case in brief are that assessee had not filed his return of income for AY 2013-14. The AO noticed from the details

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

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

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

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

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

2 of the appellate order. The CIT(A) reproduced the submission of the appellant, which is at pages 3 to 7 of the appellate order. The CIT(A) condoned the delay of 119 days and admitted the appeal for hearing on merit. The appellant challenged to re-opening notice and re- assessment proceedings before

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

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/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

2. The Hon'ble CIT(Appeals)-II, Surat was not justified in confirming the addition made of Rs. 26,00,000/- on account of unexplained cash credit under Section 68 of the Income Tax Act, 1961. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 3. The assessee vide application filed on 20/05/2022

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

2. The Hon'ble CIT(Appeals)-II, Surat was not justified in confirming the addition made of Rs. 26,00,000/- on account of unexplained cash credit under Section 68 of the Income Tax Act, 1961. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 3. The assessee vide application filed on 20/05/2022

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

2. The Hon'ble CIT(Appeals)-II, Surat was not justified in confirming the addition made of Rs. 26,00,000/- on account of unexplained cash credit under Section 68 of the Income Tax Act, 1961. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 3. The assessee vide application filed on 20/05/2022

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

2. The Hon'ble CIT(Appeals)-II, Surat was not justified in confirming the addition made of Rs. 26,00,000/- on account of unexplained cash credit under Section 68 of the Income Tax Act, 1961. 3. The appellant reserves the right to add, alter, amend or withdraw any grounds of appeal.” 3. The assessee vide application filed on 20/05/2022

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

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

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