DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

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

13. Similarly, under section 132A of the Act, the authorizing authority would acquire the jurisdiction to authorize an officer to requisition books of account or other documents or assets which have been taken into custody by an officer or authority under any law and thereafter to proceed to deal with the assets provided in the manner provided under sections

INCOME TAX OFFICER, SURAT vs. SATYAM EDUCATIONAL TRUST, SILVASA

In the result, ground of appeal raised by the revenue in this appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

U/s 13(3) of the Act, by incurring expenditure of Rs. 7,786/- on the celebration of chairperson’s birthday, which was clear infringement of the provision of Section 13(1)(c)(ii) of the Act. 2. The appellant craves leave to add, amend, delete or modify grounds of appeal before the finalization of appeal.” 11. Brief facts

INCOME TAX OFFICER, SURAT vs. SATYAM EDUCATIONAL TRUST, SILVASA

In the result, ground of appeal raised by the revenue in this appeal is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

U/s 13(3) of the Act, by incurring expenditure of Rs. 7,786/- on the celebration of chairperson’s birthday, which was clear infringement of the provision of Section 13(1)(c)(ii) of the Act. 2. The appellant craves leave to add, amend, delete or modify grounds of appeal before the finalization of appeal.” 11. Brief facts

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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

SHRIFAL IMPEX PRIVATE LIMITED,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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

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)

147 of the IT Act and notice u/s. 148 of the Act was issued to the assessee on 30/03/2019. In response to notice u/s. 148 of the Act the assessee filed its return of income on 26/04/2019 declaring total income at Rs.2,09,220/-. The assessee was provided copy of reasons recorded for reopening of case vide letter dated 25/05/2019

MAHOTSAV CREATION PVT. LTD.,SURAT vs. PR. COMMISSION OF INCOME TAX, -1,, SURAT

In the result, Both the appeals filed by the assessee are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.49 & 50/Srt/2021 Assessment Years: (2010-11 & 2011-12) (Virtual Court Hearing) Mahotsav Creation Pvt. Ltd., Vs. Principal Commissioner Of 101-102, 1St Floor, Sakar Textile Income-Tax-1, Aayakar Bhawan, Market, Ring Road, Surat-395002. Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaecm2394Q (Appellant) (Respondent) Assessee By Shri Hardik Vora, Advocate Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 28/06/2022 22/08/2022 Date Of Pronouncement

13. Taking note of the aforesaid dictum of law laid down by the Hon’ble Apex Court, let us examine whether order passed by the assessing officer under section 147 r.w.s. 143(3) of the Act, dated 21.12.2017 is erroneous and prejudicial to the interest of revenue. The learned Counsel invited our attention towards reasons recorded by the Assessing Officer

MAHOTSAV CREATION PVT. LTD.,SURAT vs. PR. COMMISSION OF INCOME TAX, -1,, SURAT

In the result, Both the appeals filed by the assessee are allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.49 & 50/Srt/2021 Assessment Years: (2010-11 & 2011-12) (Virtual Court Hearing) Mahotsav Creation Pvt. Ltd., Vs. Principal Commissioner Of 101-102, 1St Floor, Sakar Textile Income-Tax-1, Aayakar Bhawan, Market, Ring Road, Surat-395002. Majura Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaecm2394Q (Appellant) (Respondent) Assessee By Shri Hardik Vora, Advocate Respondent By Shri H. P. Meena, Cit(Dr) Date Of Hearing 28/06/2022 22/08/2022 Date Of Pronouncement

13. Taking note of the aforesaid dictum of law laid down by the Hon’ble Apex Court, let us examine whether order passed by the assessing officer under section 147 r.w.s. 143(3) of the Act, dated 21.12.2017 is erroneous and prejudicial to the interest of revenue. The learned Counsel invited our attention towards reasons recorded by the Assessing Officer

ITO, WARD-2(3)(2), SURAT, SURAT vs. KISHOR BHANUBHAI ASODARIA, SURAT

In the result, the appeal filed by the Revenue is hereby dismissed

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

13-08-2025 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Revenue as against the appellate order dated 30.09.2024 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the reassessment order passed under section 147 of the Income

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.

u/s 142(1) of the Act, the assessee has attended and furnished details before the assessing officer. 8. In assessee`s case, the information were gathered by the assessing officer from the DDIT (Inv.), Mumbai, that a search and seizure action under section 132 of the Act, 1961 was conducted on 03.10.2013 by the DGIT (Inv.), Mumbai on group concerns

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.

u/s 142(1) of the Act, the assessee has attended and furnished details before the assessing officer. 8. In assessee`s case, the information were gathered by the assessing officer from the DDIT (Inv.), Mumbai, that a search and seizure action under section 132 of the Act, 1961 was conducted on 03.10.2013 by the DGIT (Inv.), Mumbai on group concerns

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.

u/s 142(1) of the Act, the assessee has attended and furnished details before the assessing officer. 8. In assessee`s case, the information were gathered by the assessing officer from the DDIT (Inv.), Mumbai, that a search and seizure action under section 132 of the Act, 1961 was conducted on 03.10.2013 by the DGIT (Inv.), Mumbai on group concerns

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.

u/s 142(1) of the Act, the assessee has attended and furnished details before the assessing officer. 8. In assessee`s case, the information were gathered by the assessing officer from the DDIT (Inv.), Mumbai, that a search and seizure action under section 132 of the Act, 1961 was conducted on 03.10.2013 by the DGIT (Inv.), Mumbai on group concerns

ASST. COMMISSIONER OF INCOME TAX, CC-3, SURAT vs. M/S. ANTIQUE EXIM PVT. LTD., , SURAT

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपीलसं./Ita No.431 &440/Srt/2022 (िनधा"रणवष" / Assessment Year: (2012-13) (Physical Court Hearing)

147 of the Income Tax Act, 1961 (in short ‘the Act’). 2. At the outset, we note that appeal filed by the assessee in the case of M/s Nobal Jewels Pvt. Ltd. in ITA No.350/SRT/2022 for A.Y. 2017-18 is barred by limitation by one day. The Ld. Counsel for the assessee has explained that actually

MARUDHAR DIAMOND PVT LTD,SURAT vs. DEPUTY COMMISSIONER OF INCOME TAX, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपीलसं./Ita No.431 &440/Srt/2022 (िनधा"रणवष" / Assessment Year: (2012-13) (Physical Court Hearing)

147 of the Income Tax Act, 1961 (in short ‘the Act’). 2. At the outset, we note that appeal filed by the assessee in the case of M/s Nobal Jewels Pvt. Ltd. in ITA No.350/SRT/2022 for A.Y. 2017-18 is barred by limitation by one day. The Ld. Counsel for the assessee has explained that actually

NOBAL JEWELS PVT LTD,SURAT vs. DY. COMMISSIONER OF INCOME TAX, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपीलसं./Ita No.431 &440/Srt/2022 (िनधा"रणवष" / Assessment Year: (2012-13) (Physical Court Hearing)

147 of the Income Tax Act, 1961 (in short ‘the Act’). 2. At the outset, we note that appeal filed by the assessee in the case of M/s Nobal Jewels Pvt. Ltd. in ITA No.350/SRT/2022 for A.Y. 2017-18 is barred by limitation by one day. The Ld. Counsel for the assessee has explained that actually

ASST. COMMISSIONER CENTRAL CIRCLE -3, SURAT vs. M/S. NOBAL JEWELS PVT. LTD, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपीलसं./Ita No.431 &440/Srt/2022 (िनधा"रणवष" / Assessment Year: (2012-13) (Physical Court Hearing)

147 of the Income Tax Act, 1961 (in short ‘the Act’). 2. At the outset, we note that appeal filed by the assessee in the case of M/s Nobal Jewels Pvt. Ltd. in ITA No.350/SRT/2022 for A.Y. 2017-18 is barred by limitation by one day. The Ld. Counsel for the assessee has explained that actually

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIR.-3, SURAT vs. MARUDHAR DIAMOND PVT LTD, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकर अपीलसं./Ita No.431 &440/Srt/2022 (िनधा"रणवष" / Assessment Year: (2012-13) (Physical Court Hearing)

147 of the Income Tax Act, 1961 (in short ‘the Act’). 2. At the outset, we note that appeal filed by the assessee in the case of M/s Nobal Jewels Pvt. Ltd. in ITA No.350/SRT/2022 for A.Y. 2017-18 is barred by limitation by one day. The Ld. Counsel for the assessee has explained that actually