M/S. PATEL AMBALAL HARGOVANDAS & CO.,,SURAT vs. THE DCIT, CENTRAL CIRCLE-2,, SURAT

In the results, appeal filed by Revenue (in IT(SS)A Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं/.It(Ss)A No.49/Srt/2022 Assessment Year: (2019-20) (Physical Hearing) The Acit, Central Circle-2, Vs. Rasikbhai Narottamdas Patel, Surat. Flat No.9-10, Mahavir Nagar Co.Op H.S. Ltd., Bldg-12, Nr. Gayatri Mandir, Udhna Magdalla Road, Surat – 395007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Adgpp4550M (Appellant) (Respondent) आयकर अपील सं/.It(Ss)A No.86/Srt/2022 Assessment Year: (2015-16) The Dcit, Central Circle-2, Vs. Ashish Karamshibhai Koshiya, Surat. 40, Jivandeep Soceity, Singanpor Road, Katargam, Surat, Gujarat – 395004. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aojpk1118G (Appellant) (Respondent) आयकर अपील सं/.Ita No.185/Srt/2022 Assessment Year: (2020-21) M/S. Patel Ambalal Hargovandas Vs. The Dcit, Central Circle-2 & Co., Surat. 5/725, Haripura, Bhavaniwad, Opp. Dhobi Sheri, Surat – 395003. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aadfp2517N (Appellant) (Respondent) Appellant By Shri Ashok B. Koli, Cit(Dr) Shri Vartik Choksi, Shri Biren Shah & Shri Respondent By Nitin Gheewala, Ar Date Of Hearing 26/04/2023 Date Of Pronouncement 26/05/2023 आदेश /O R D E R Per Bench:

section 148 had observed that the addition IT(SS)A.49 & 86/SRT/2022 & ITA.185/SRT/2022 Ashish K. Koshiya, Rasikbhai N. Patel & Patel A. Hargovandas & Co. was being made on protective measure. It is in the aforesaid background of fact, question of validity of initiation of reassessment proceedings had come up for consideration before the Tribunal. 24. The Tribunal firstly explained the concept

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)

reassessment proceeding can be initiated as provided under section 147. This again shows that full and true disclosure of income is a primary obligation of the assesee. It is clear that the proceedings can be initiated under section 271(1) only if the AO is satisfied in the course of any proceedings under that any person has concealed the particulars

NARESHKUMAR B. AGARWAL,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT

69B\nv) Unexplained money u/s 69A\nvi) Unexplained money u/s 69C\nvii) Unaccounted expenditure u/s 69C\nviii) Unexplained income u/s 69A\nix) Unexplained expenditure u/s 69C\nRs. 25,00,000/-\nRs. 3,18,750/-\nRs.1,08,11,000/-\nRs. 7,00,000/-\nRs.5,20,00,000/-\nRs.1,30,00,000/-\nRs. 1,39,400/-\nRs.6

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

69B towards purchase of land at block No.7 and 287\nKumbharia, (ii) Rs.5,94,15,000/- u/s 69A on account of on-money receipt of\nKuberji Crown and (iii) Rs.55,00,000/- u/s 69B for unaccounted payment for land\nat plot No. 224 at Kumbharia.\n44.1 Aggrieved by the order of AO, the assessee filed appeal before CIT(A),\nwho

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR - 4, SURAT vs. NARESHKUMAR B. AGARWAL, SURAT

69B towards purchase of land at block No.7 and 287\nKumbharia, (ii) Rs.5,94,15,000/- u/s 69A on account of on-money receipt of\nKuberji Crown and (iii) Rs.55,00,000/- u/s 69B for unaccounted payment for land\nat plot No. 224 at Kumbharia.\n44.1 Aggrieved by the order of AO, the assessee filed appeal before CIT(A),\nwho

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

DY. COMMISSIONER OF INCOME TAX, CC, VAPI vs. M/S. M POONAM DEVELOPERS, VALSAD

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

DY. COMMISSIONER OF INCOME TAX, CC, VAPI, VAPI vs. POONAM DEVELOPERS LLP, DADRA & NAGAR HAVELI (UT)

In the result, these Cross-Objections Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Court Hearing) Sl.

reassessed on 19.02.2016 for ASST. Year 2011-12 by the Department and a total addition of Rs.92,03,181/- had been made by the Department on account of unexplained investment and unexplained income, ITA Nos.284 to 286, 318 to 320/SRT/2022 & CO No.12 to 14/SRT/2022 M/s. M. Poonam Developers LLP & M. Poonam Developers against which your assessee did not prefer

SHRI ARVINDBHAI LALLUBHAI LAKHANKIYA,,SURAT vs. THE ACIT, CIRCLE-9,, SURAT

Bench: Shri Pawan Singh, Hon'Ble & Shri Arjun Lal Saini, Hon'Ble(Virtual Court Virtual Hearing) आ.अ.सं./I.T.A No.962/Ahd/2016; "नधा"रणवष"/Assessment Year: 2006-07 Shri Arvindbhai Lallubhai V Asst. Commissioner Of Lakhankiya, B-78, Hans Society, S Income Tax, Circle-9, Surat. Varchha Road, Surat. . [Pan: Aadpl 3819 P] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Ashwin Parekh – Ar राज"वक"ओरसे /Revenue By Mrs. Anupama Singla – Sr.Dr

reassessment. The AO after serving notice u/s.143(2) of the Act, issued a show cause notice dated 11.02.2014 asking assessee as to why the difference in value, declared by him and that of DVO should not be added to undisclosed investment. Shri ArvindbhaiLallubhaiLakhankiya Vs. ACIT, Circle-9, Surat/ ITA No.965/AHD/2016 for A.Y. 2006-07 The assessee filed detailed reply vide

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO,WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,SILVASSA vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, SILVASSA WARD , SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA, SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed

VIKAS AGARWAL,DADRA AND NAGAR HAVELI vs. ITO, WARD SILVASSA , SILVASSA

In the result, the appeal of the assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth

reassessment proceedings were initiated wrongly without considering the facts on the record. The CIT(A) forwarded submission of assessee to AO and obtained the remand report, which is at para 8.11 of the appellate order. He noted that AO issued notice as per the PAN data base and address of the bank for KYC verification. The CIT(A) also noticed