SUMITLAL,SURAT vs. ITO, SURAT

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

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Sumitlal, Ito 101-B/2, Sanskrut Flats Umra, Aayakar Bhavan, Bharthana, Vs. Surat-395007. Surat-395007 Pan No. Acxpl 1238 Q Appellant Respondent

unexplained investment under section 69 of the Act. 2. That while sustaining the impugned addition Ld CIT(Appeals), NFAC, Delhi has erred in law in ignoring the ITA No. 545/SRT/2025 2 Sumitlal fact as well law that tran fact as well law that transaction of mutual fund investment saction of mutual fund investment Rs. 2624315/ Rs. 2624315/-. 3. That That

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

investment on purchase of\nvarious lands. The Assessing Officer has not examined the seller of land. There is no\nfinding of Assessing Officer whether the consideration paid by assessee was not in\naccordance with Jantri rate or less than the value determined by the Stamp Valuation\nAuthority. It is settled law that no addition on estimation basis can be made

INCOME TAX OFFICER, ANAVIL BUSINESS CENTRE, ADAJAN vs. ABHISHEK NAVNIT DOSHI , MAHIDHARPURA

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

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2014-2015 Ito, Abhishek Navnit Doshi, 405, Income Tax Office, Anavil 204/205, 2Nd Floor, 6/1911-12, Business Centre, Hazira Road, Vs. Jin Shanti Bldg. Mahidharpura, Adajan, Surat-395003. Surat-395009. Pan No. Afhpd 0064 M Appellant Respondent

reassessment proceedings, the assessee furnished audit reports, bank statements, export invoices, purchase bills, bank statements, export invoices, purchase bills, bank statements, export invoices, purchase bills, sales registers, and ledger accounts, asserting that all payments sales registers, and ledger accounts, asserting that all payments sales registers, and ledger accounts, asserting that all payments had been effected through recognised banking channels

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:

investments etc. and therefore, ld CIT(A) held that no addition could be made only on the basis of the paper found which, does not give specific information including the actual amount of expenditure. The assessing officer has added three zeros which does not have any basis. Even adding two zeros to the said figures does not give correct picture

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT vs. SHRI JIGNESH MAHESH AMIN, SURAT

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) A.C.I.T., Shri Jignesh Mahesh Amin, Central Circle-3, 418, Royal Trading Tower, Nr. Vs. Surat. Ratan Cinema, Salabatpura, Surat-395003. Pan No. Aajpa 2349 H Appellant/ Assessee Respondent/ Revenue

unexplained investment, 2 ACIT Vs Jignesh Amin completely ignoring the surrounding circumstances and principles of preponderance of probability. (vii) It is, therefore, prayed that the order the Ld. CIT(A)-4, Surat may be set aside and that of the AO may be restored to the above extent. (viii) The appellant craves leave to add, alter, amend and/or withdraw

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

investment or expenditure in this year and hence,\nthe ground is dismissed.\n58.\nIn the result, assessee's appeal IT(SS)A No.26/SRT/2023 is partly allowed.\nITA No.163/SRT/2023 and ITA No.136/SRT/2023 (A.Y 2013-14)\n59.\nFirst, we shall take up revenue's appeal in ITA No.163/Srt/2023 for A.Y\n2013-14. The facts of the case in brief are that assessee

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

VALLABHBHAI DUDABHAI CHHATRALA,SURAT vs. ITO, WARD-3(3) (1), SURAT

In the result, the grounds of appeal raised by the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblevallabhbhai Dudabhai Chhatrala, The Income Tax Officer, Vs. 6, Prabhu Darshan Soc. Nr. Ward-3(3)(5), Dhameliya Nagar, Current Jurisdiction, Varacha Road, Ward-3(3)(1), Rajhans Point, Surat-395006. Surat-395006. [Pan : Aeepc8550 M] (Appellant) .. (Respondent) Appellant By : Shri Mehul Shah, Ar Respondent By: Shri Ajay Uke, Sr. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 17.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

unexplained investment in the land. The Hon’ble Gujarat High Court in PCIT Vs Ganesh Plantation Ltd (supra) held that when the assessing officer initiated reassessment

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

Unexplained money u/s 69A\nii) Unexplained expenditure u/s 69C\niii) Unexplained income u/s 69A\niv) Unaccounted investment u/s 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

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.

investment of Rs.74,14,878.80 in the books of the assessee in comparison to the quantity and value of stocks held by him. Sir, your assessee was 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

YOGENDRAKUMAR RAMAVTAR AGARWAL,SURAT vs. ITO, WARD-1(2)(1), SURAT

In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for In the result, the appeal of the assessee is partly allowed for stati...

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Yogendrakumar Ramavtar Ito, Ward-1(2)(5), Agarwal, Surat Current Jurisdiction: 2053-Mahaveer Textile Market, Vs. Ito, Ward 1(2)(1), Ring Road, Textile Area, Aayakar Bhavan, Near Majura Surat-395002. Gate, Opp. New Civil Hospital, Surat-395001 Pan No. Aarpa 7623 C Appellant Respondent

unexplained investment u/s. 69 of the I.T. Act. investment u/s. 69 of the I.T. Act. 4. It is therefore prayed that above assessment framed 4. It is therefore prayed that above assessment framed 4. It is therefore prayed that above assessment framed u/s. 147 may kindly be quashed and/or the u/s. 147 may kindly be quashed and/or the additions additions

SURESHBHAI RAGHUBHAI THORAT,VALSAD vs. ITO, WARD-7, VAPI

In the result, the appeal of the assessee is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.426/Srt/2024 (Assessment Year: 2017-18) (Physical Hearing) Sureshbhai Raghubhai Thorat, Vs. The Ito, Siddharth Villa, At Post Ozar, Ward – 7, Mota Pondha B.O., Valsad – Vapi 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acapt3507F (Appellant) (Respondent) Appellant By None Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 02/01/2025 Date Of Pronouncement 03/01/2025

reassessment proceedings u/s 147 r.w.s. 144 of the Act on the basis of invalid notice issued u/s 148 of the Act. 4) The ld. CIT(A) has erred in law and on facts in upholding, without adjudication, the action of ld. ITO of completing the assessment u/s 144 of the Act in defiance principles of natural justice, equity and fairness

RAJRANI KISHANLAL PAHWA,SURAT vs. ITO, WARD 1(2)(1), SURAT

In the result, the appeal of the assessee for AY 2009-10 is partly allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

reassessment proceedings, the Assessing Officer noticed cash and cheque deposits aggregating to Rs.4,59,682/- in the undisclosed bank account, and Fixed Deposit Receipts (FDRs) amounting to Rs.43,40,000/- along with interest of Rs.3,30,484/-, aggregating to Rs.46,70,484/-, which were not disclosed in the return of income. The Assessing Officer also observed that a part