BHARATBHAI NAGINBHAI PATEL,ANKLESHWAR vs. INCOME TAX OFFICER, WARD - 2(4), BHARUCH

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

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.393/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Bharatbhai Nagjibhai Patel, Vs. The Ito, 392, Nishal Faliu, Nava Haripura, Ward- 2(4), Sajod, Ankleshwar, Bharuch, Bharuch, Gujarat – 393020. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bpppp4227M (Appellant) (Respondent) Shri Ashutosh P. Nanavaty, Ca Appellant By Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 16/10/2023 Date Of Pronouncement 30/10/2023

u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 13.11.2019. 2. The appeal filed by the assessee, before the Tribunal, for Assessment Year 2012-13, is barred by limitation by 3 days. The Ld. Counsel for the assessee submitted that delay in filing the appeal before the Tribunal, is only three

BHAVIN ARUNBHAI PATEL,VALSAD vs. INCOME TAX OFFICER, WARD-1, VAPI

In the result, the appeal is allowed in the terms indicated above

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.456/Srt/2023 Assessment Year: (2011-12) (Physical Hearing) Bhavin Arunbhai Patel, Vs. The Ito, Parvassa Road, Mota Waghchhipa, Ward – 1, Kila Pardi, Valsad – 396001, Vapi Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Arypp2459F (Appellant) (Respondent)

147 after issuing notice u/s. 148 of the Act and passing the reassessment order. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming the action of assessing officer in making the addition of Rs.17,36,110/- on account of Rs.13,68,110/- as unexplained credit

MUKHTAR RAMZAN SHAIKH,VAPI vs. INCOME TAX OFFICER, WARD-6, VAPI, VAPI

In the result, assessee’s appeal in ITA No

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.628 & 629/Srt/2023 Assessment Years: (2010-11 & 2011-12) (Physical Hearing) Mukhtar Ramzan Shaikh Income Tax Officer, 303, Imran Mension, Opp. Vs. Ward-6, Vapi, Income Tax Office, Suman Auto, Godal Nagar, Room No.808, Fortune Saquare- Vapi-396191 Ii, Daman Road, Chala Vapi- 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Awlps 0991 F (अपीलाथ"/Appellant) (""थ" /Respondent)

condone the delay in both appeals of the assessee. 11. Now coming to assessee’s appeal in ITA No.628/SRT/2023, at the outset, Ld. Counsel for the assessee informs the Bench that assessee does not wish to press Ground No.1(in ITA No.628/SRT/2023), therefore, I dismiss ground No.1 raised by the assessee, as “not pressed”. 12. Now, I take ground

MUKHTAR RAMZAN SHAIKH,VAPI vs. INCOME TAX OFFICER, WARD-6, VAPI, VAPI

In the result, assessee’s appeal in ITA No

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita Nos.628 & 629/Srt/2023 Assessment Years: (2010-11 & 2011-12) (Physical Hearing) Mukhtar Ramzan Shaikh Income Tax Officer, 303, Imran Mension, Opp. Vs. Ward-6, Vapi, Income Tax Office, Suman Auto, Godal Nagar, Room No.808, Fortune Saquare- Vapi-396191 Ii, Daman Road, Chala Vapi- 396191 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Awlps 0991 F (अपीलाथ"/Appellant) (""थ" /Respondent)

condone the delay in both appeals of the assessee. 11. Now coming to assessee’s appeal in ITA No.628/SRT/2023, at the outset, Ld. Counsel for the assessee informs the Bench that assessee does not wish to press Ground No.1(in ITA No.628/SRT/2023), therefore, I dismiss ground No.1 raised by the assessee, as “not pressed”. 12. Now, I take ground

BACHRAJ CHHOTELAL MEHTA,SURAT vs. INCOME TAX OFFICER, WARD-2(3)(8), 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: 2008-2009 Bachraj Chhotelal Mehta, Ito Ward-2(3)(8), C-3, 3Rd Floor, Antwerp Park, 619, Aayakar Bhavan, Majura Apartment, Kansara Sheri, Vs. Gate, Mahidharpura, Surat-395001. Surat-395003. Pan No. Afrpm 7809 R Appellant Respondent

reassessment order passed u/s.147 is bad u/s.147 is bad-in-law; 6.0 On facts and circumstances of the case and in law, Ld. 6.0 On facts and circumstances of the case and in law, Ld. 6.0 On facts and circumstances of the case and in law, Ld. CIT(A) erred in confirming the addition of entire (100%) CIT(A) erred

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

147 of the Income 1961 (in short ‘the Act’) and issued notice u/s 148 of the Act on t ‘the Act’) and issued notice u/s 148 of the Act on t ‘the Act’) and issued notice u/s 148 of the Act on 31.03.2018. The reassessment was completed on 14.12.2019 31.03.2018. The reassessment was completed on 14.12.2019 31.03.2018. The reassessment

SAROJ TILAKRAJ JUNEJA,SURAT vs. DCIT CIRCLE-1(1)(1), SURAT

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

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1048/Srt/2024 Assessment Year: (2014-15) (Physical Hearing) Saroj Tilakraj Juneja, Vs. The Dcit, 3, Subhas Nagar Society, Ghod Dod Road, Circle - 1(1)(1), Surat - 395007 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abbpj5634M (Appellant) (Respondent) Appellant By Shri Kiran K. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 08/01/2025 Date Of Pronouncement 13/01/2025

reassessment proceedings by the Hon’ble Gujarat High Court for this particular year. 4. The appellant reserves right to add, alter and withdraw any grounds of appeal.” 3. The appeal filed by assessee is barred by 169 days in terms of provisions of section 253(3) of the Act. The learned Authorized Representative (ld. AR) filed an affidavit

DCIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

condone the delay in filing both these appeals and both these appeals, that is, (appeal by Revenue and Appeal by assessee) are admitted for hearing on merit. 4. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order for the sake

SHRI RAVJIBHAI BECHARBHAI DHAMELIYA,,SURAT vs. INCOME TAX OFFICER WARD-3(1(1), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

condone the delay in filing both these appeals and both these appeals, that is, (appeal by Revenue and Appeal by assessee) are admitted for hearing on merit. 4. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order for the sake

ACIT, CIRCLE-3(3), SURAT vs. SHRI RAVJIBHAI BECHARBHAI DHAMELIYA, SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

condone the delay in filing both these appeals and both these appeals, that is, (appeal by Revenue and Appeal by assessee) are admitted for hearing on merit. 4. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order for the sake

SHRI RAVJIBHAI B DHAMELIYA,SURAT vs. DCIT, CIRCLE-2(1)(2), SURAT

In the result, assessee`s appeal for both the assessment years, that is,

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

condone the delay in filing both these appeals and both these appeals, that is, (appeal by Revenue and Appeal by assessee) are admitted for hearing on merit. 4. Since, the issues involved in all the appeals are common and identical; therefore, these appeals have been heard together and are being disposed of by this consolidated order for the sake

PRAMODBHAI BALUBHAI PATEL,SURAT vs. INCOME TAX OFFICER WARD 3(1)(3), SURAT

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.622/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Pramodbhai Balubhai Patel, Vs. The Ito, D-204, Capital Status, Karan Park Ward- 3(1)(3), Road, Adajan, Surat – 395005. Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adppp8613C (Assessee) (Respondent)

condone the delay of thirty-one days and admit the appeal for adjudication. 8. Shri Rajesh Upadhyay, Learned Counsel for the assessee, at the outset, argued that ground no.5 raised by the assessee, in appeal memo, along with Form No.36, relates to legal issue, challenging the validity u/s 147/148 of the Act. Apart from this, the assessee has also raised

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

u/s 147 of the Act, the submission and the various decisions of the ITA Nos.552 & 882/SRT/2024 (A.Y.11-12) Rambilash R Jajoo & Sunita Jajoo Courts including those relied upon by the ld Counsel for the assessee. Before we proceed to adjudicate the issue relating to validity of reassessment proceedings, we would like to examine the reasons recorded by the assessing officer, which

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

condoned the delay and adjudicate of the issue. The appellant raised various grounds of appeal before the CIT(A), which are at pages 5 to 7 of the appellate order. The CIT(A) issued two notices for fixing the date of hearing on 16.08.2023 and 30.09.2024, but the assessee sought adjournment on both occasions. He referred to section

OM SAI STONE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(4), SURAT

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

condonation of delay. The main contention of ld. AR of assessee is that the delay is neither intentional nor deliberate therefore, they have not checked their e-mail and that as soon as they checked the e-mail, realised that the order has been passed by the ld. CIT(A) and that immediately filed appeal before the Tribunal. The Director

OM SAI STONE LIMITED,SURAT vs. INCOME TAX OFFICER, WARD- 2(1)(4), SURAT

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

condonation of delay. The main contention of ld. AR of assessee is that the delay is neither intentional nor deliberate therefore, they have not checked their e-mail and that as soon as they checked the e-mail, realised that the order has been passed by the ld. CIT(A) and that immediately filed appeal before the Tribunal. The Director

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)

condoned the delay of 34 days in filing the appeal. Thereafter, he has given his findings at para-6 to 8 of the appellate order. He observed that the AO passed his best judgment order u/s 144 of the Act and, ITA No.9/Srt/2024 A.Y 12-13 Arunkumar Gupta therefore, appellant did not have reasonable opportunity to present his case before

NARPATSINH PRABHATSINH SOLANKI,SURAT vs. ITO, WARD-1, SURAT

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

condone the delay in filling the present appeal\nand decide the appeal on merit.\n6.\nBrief facts of the case that the assessee has not filed his original return of\nincome for the A.Y. 2011-12. As per information available on records, the assessee\nhas made cash deposits of Rs.20,30,000/-during the year. To examine the source