SHRIFAL IMPEX PVT. LTD.,,SURAT vs. INCOME TAX OFFICER, WARD - 2(1)(3), SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.190 To 191/Srt/2023 Assessment Year: (2011-12 To 2012-13) (Physical Hearing) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent) आयकर अपील सं./Ita No.250/Srt/2023 Assessment Year: (2014-15) Shrifal Impex Private Limited, Vs. The Ito, No.504, 5Th Floor, H. No.6/B/1739- Ward-2(1)(3), 1380, Parshwa Complex Thoba Sheri, Surat Mahidharpura, Surat – 395003. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaocs4409E (Appellant) (Respondent)

u/s 148 of the Act, there should be evidence on record or specific information received from outside agencies or gathered by the AO to demonstrate that there is a prima facie case of escapement of income. 7.4.20 In the instant case, it is an admitted fact that the AO received specific information from two Investigating Agencies .e. DRI and DDIT

ABHISHEK AGARWAL,NANI DAMAN vs. ITO, DAMAN WARD,, DAMAN

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr.Arjun Lal Saini, Hon'Bleआ.अ.सं./I.T.A No.97/Srt/2018 िनधा"रणवष"/Assessment Year: 2007-08 Abhishek Agarwal Vs. The Income Tax Officer, Radha Madhav Kunj, Opp. Gem Daman Ward, Daman. Plaza, College Road, Nani Daman. [Pan: Adxpa8893P अपीलाथ" /Assessee ""थ"/Respondent िनधा"रतीकीओरसे /Assessee By Shri Rasesh Shah, C.A. राज"कीओरसे /Revenue By Mrs. Anupama Singla – Sr. Dr सुनवाईकीतारीख/ Date Of Hearing: 14.10.2020 उद्घोषणाकीतारीख/Pronouncement On: 06.01.2022

section 147 of the Act. 13. At the cost of repetition, we also state that reassessment proceedings were initiated after the expiry of four years. We note that scrutiny assessment has been completed in the case of the assessee for the assessment year 2007-08, vide order u/s 143(3) r.w.s. 153A dated 24-12-2010 accepting the returned income

VIRAL LAVJIBHAI PATEL,SURAT vs. INCOME TAX OFFICER, WARD-3(3)(5), SURAT

In the result, assessee`s appeal is partly allowed in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.450/Srt/2023 Assessment Year: (2011-12) (Physical Hearing) Viral Lavjibhai Patel, Vs. Income Tax Officer, A-18, Naginawadi Society, Ward-3(3)(5), Surat, Aaykar Sumul Dairy Road, Bhawan, Majura Gate, Opp. Surat – 395004. New Civil Hospital, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Alvpp2897E (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 12/10/2023 Date Of Pronouncement 26/10/2023

reassessment proceedings, the findings of NFAC/ld CIT(A) are reproduced below: “17.0 Ground No.1: The ground is related to the technical issue of reopening. The appellant had submitted that the AO should not come to a conclusion of escapement of income only based on the non-filing of the return of income and cash deposits made in the bank account

THE AMROLI VIBHAG VIVIDH KARYAKARI SAHAKARI MANDLI LTD.,,SURAT vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(3),, SURAT

In the result ground No. 2 of the appeal is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

u/s 80P(2)(a)(i) and section 80P(2)(a)(iv) of the Act ought to be granted to the appellant.” 15. Brief facts of the case are that assessment was initially completed on 28.10.2011. Subsequently, the case was re-opened under section 147. Notice under section 148 dated 11.03.2015 was served upon the assessee. In response to notice under

THE AMROLI VIBHAG VIVIDH KARYAKARI SAHAKARI MANDLI LTD.,,SURAT vs. THE DCIT.,CIRCLE-2(3),, SURAT

In the result ground No. 2 of the appeal is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

u/s 80P(2)(a)(i) and section 80P(2)(a)(iv) of the Act ought to be granted to the appellant.” 15. Brief facts of the case are that assessment was initially completed on 28.10.2011. Subsequently, the case was re-opened under section 147. Notice under section 148 dated 11.03.2015 was served upon the assessee. In response to notice under

THE AMROLI VIBHAG VIVIDH KARYAKARI SAHAKARI MANDLI LTD.,,SURAT vs. THE DY.CIT.,CIRCLE-2(3),, SURAT

In the result ground No. 2 of the appeal is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

u/s 80P(2)(a)(i) and section 80P(2)(a)(iv) of the Act ought to be granted to the appellant.” 15. Brief facts of the case are that assessment was initially completed on 28.10.2011. Subsequently, the case was re-opened under section 147. Notice under section 148 dated 11.03.2015 was served upon the assessee. In response to notice under

THE AMROLI VIBHAG VIVIDH KARYAKARI SAHAKARI MANDLI LTD.,,SURAT vs. THE ACIT.,CIRCLE-6,, SURAT

In the result ground No. 2 of the appeal is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

u/s 80P(2)(a)(i) and section 80P(2)(a)(iv) of the Act ought to be granted to the appellant.” 15. Brief facts of the case are that assessment was initially completed on 28.10.2011. Subsequently, the case was re-opened under section 147. Notice under section 148 dated 11.03.2015 was served upon the assessee. In response to notice under

KANCHAN DEVI AGARWAL,SURAT vs. ITO, WARD 1(2)(1), SURAT

The appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Bijayananda Pruseth

147 r.w.s. 144B of the Act, which are invalid and bad in law ab initio. Appellant prays for quashing the same. 2. Without prejudice to above grounds of appeal, that on the facts and in the circumstances of the case as well as in law, the Id. CIT (A) has erred in upholding the addition

KANCHAN DEVI AGARWAL,SURAT vs. ITO, WARD 1(2)(1), SURAT

The appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Bijayananda Pruseth

147 r.w.s. 144B of the Act, which are invalid and bad in law ab initio. Appellant prays for quashing the same. 2. Without prejudice to above grounds of appeal, that on the facts and in the circumstances of the case as well as in law, the Id. CIT (A) has erred in upholding the addition

DESIGNER EXIM PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER, 1(1)(2), SURAT

In the result, this appeal of the assessee is allowed

Bench: Shri Pawan Singh(Physical Hearing) M/S Designer Exim Pvt. Ltd., I.T.O., D-1203, Panchsheel Heights, Opp.- Ward 1(1)(2), Vs. Pizza Hut, Mahavir Nagar, Kandivali Surat. West, Mumbai, Maharashtra-400067 Pan No. Aabcd 4298 H Appellant/ Assessee Respondent/ Revenue

u/s 148 of the Act. (c) The learned Assessing Officer failed to obtain sanction of the prescribed authority before issuing notice under section 148 of the Act. (d) The initiation of proceeding under section 147 of the Act and issuance of notice under section 148 is without jurisdiction, bad in law and contrary to the provisions

NAVINBHAI RATILAL IDRIA,SURAT vs. ITO, WARD 2(3)(4), SURAT

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Bijayananda Pruseth (Accountant Member)

147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2014-15. I.T.A No. 694//SRT/2025 Α.Υ. 2025-26 Navinbhai Ratilal Idria vs. ITO Page No 2 2. The registry has noted that there is a delay of 362 days in filing the above appeal. The assessee explained that the assessee

USMAN VALI PATEL,BHARUCH GUJARAT vs. WARD 1(2), INCOME TAX OFFICER, BHARUCH

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

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.183/Srt/2025 Assessment Year: (2011-12) (Hybrid Hearing) Usman Vali Patel, Vs. Ito, A-14 Assd Park, Near Khwaja Ward – 1(2), Township, Bharuch - 392001 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aykpp8165B (Appellant) (Respondent) Appellant By Shri Krutarth Desai, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 11/09/2025 Date Of Pronouncement 03/11/2025

reassessment deserves to be quashed and set aside. 2. The learned Assessing Officer has not complied with the mandatory requirements of section 143(2) and passed the order under section 143(3) r.w.s. 147 which is bad in law and therefore impugned order deserves to be quashed and set aside in the best interest of justice. ITA No.183/SRT/2025/AY.2011-12 Usman Vali

NA vs. ARI MALESAR BEHDIN ANJUMAN,NAVSARIVS.INCOME TAX OFFICER, EXEMPTION WARD, SURAT

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

Bench: Shri Sandeep Gosain, Hon'Ble & Shri O.P.Meena, Hon'Bleआ.अ.सं./I.T.A No.272/Srt/2018 "नधा"रण वष"/Assessment Year: 2013-14 Navsari Malesar Behdin Anjuman, V The Income Tax Officer, Agiary Street, Malesar, Navsari S Exemption Ward, Surat. Taluka, Navsari – 396 445. . [Pan: Aaatn 6124 C] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri H.R.Vepari – Ca राज"वक"ओरसे /Revenue By Shri O.P.Vaishav – Cit - Dr

147) 30-1-2013 Returns filed on 19-3-2013 •€€€€€€€€€€€€€€€€A.Y.2007-08 to 2009-10 •€€€€€€€€€€€€€€€€ A.Y.2006-07 and A.Y.2011-12 In the above case, application was made during the subsistence of the assessment proceedings, however, registration was granted subsequent to the conclusion of the assessment proceedings, the Hon'ble Tribunal held that relief u/s.11 cannot be denied if the registration was obtained during