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 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year 2010-11 and 173 pages for assessment year 2011-12. The necessary facts

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 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year 2010-11 and 173 pages for assessment year 2011-12. The necessary facts

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 147/148 is valid for both the assessment years, 2010-11 and 2011-12. 18. We heard both sides in detail and also perused the records of the case including the paper book filed by the assesses running in to 223 pages for assessment year 2010-11 and 173 pages for assessment year 2011-12. The necessary facts

RAJLAXMI POLYMERS PVT. LTD.,,SURAT vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, SURAT

In the result the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Virtual Court Hearing) Vs Rajlaxmi Polymers Pvt Ltd, Income Tax Officer, 5024,World Trade Centre, Ward -2 (1)(1), Near Udhna Darwaja, Surat, Ring Road, Surat-395002 Pan : Aabcr 1210 M Assessee Revenue Assessee By Sh. Sapnesh Sheth Ca/Ar Revenue By Ms. Anupma Singla Sr Dr Date Of Hearing 17/12/2020 Date Of Pronouncement 21/12/2020

253 of Income-tax Act (Act) is directed against the order of the learned Commissioner of Income Tax (Appeals)-2, Surat, [in short “learned Commissioner (Appeals)”] dated 14.07.2016 pertaining to Assessment Years (AYs) 2010-11. 2. Brief facts of the case as gathered from the order of lower authorities are that the assessee is a company engaged in the business

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) Vs. The Acit, Radha Madhav Eco-Industrial Park, Central Circle - 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp - Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District - Valsad – 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp - Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District - Valsad - 396191, Gujarat स्थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. In the affidavit, the assessee stated that CIT(A) has passed order u/s 250 of the Act on 15.09.2023. However, the assessee filed the appeal on 29.06.2024. Therefore, there is a delay of 63 days. The assessee submitted

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. In the affidavit, the assessee stated that CIT(A) has passed order u/s 250 of the Act on 15.09.2023. However, the assessee filed the appeal on 29.06.2024. Therefore, there is a delay of 63 days. The assessee submitted

ACIT, CENTRAL CIRCLE, VAPI vs. RADHA MADHAV ECO INDUSTRIAL PARK, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. In the affidavit, the assessee stated that CIT(A) has passed order u/s 250 of the Act on 15.09.2023. However, the assessee filed the appeal on 29.06.2024. Therefore, there is a delay of 63 days. The assessee submitted

RADHA MADHAV ECO-INDUSTRIAL PARK,VALSAD vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. In the affidavit, the assessee stated that CIT(A) has passed order u/s 250 of the Act on 15.09.2023. However, the assessee filed the appeal on 29.06.2024. Therefore, there is a delay of 63 days. The assessee submitted

RADHA MADHAV ECO-INDUSTRIAL PARK,VAPI vs. ACIT, CENTARL CIRCLE-1, VAPI, VAPI

In the result, appeal of the assessee is partly allowed and appeal of revenue is dismissed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.762/Srt/2023 Assessment Year: (2021-22) (Hybrid Hearing) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.41/Srt/2024 Assessment Year: (2021-22) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita Nos.625/Srt/2024 Assessment Year: (2018-19) The Acit, Vs. Radha Madhav Eco-Industrial Park, Central Circle – 1, Village Degam, Opp – Padmavati Vapi Logistics, Nasik Road, Degam, Tal – Vapi, District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent) आयकर अपील सं./Ita No.632/Srt/2024 Assessment Year: (2018-19) Radha Madhav Eco-Industrial Park, Vs. The Acit, Village Degam, Opp – Padmavati Central Circle – 1, Logistics, Nasik Road, Degam, Tal – Vapi, Vapi District – Valsad – 396191, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaofr2845L (Appellant) (Respondent)

253(3) of the Act. The assessee has filed an affidavit giving reasons for delay in filing the appeal before the Tribunal. In the affidavit, the assessee stated that CIT(A) has passed order u/s 250 of the Act on 15.09.2023. However, the assessee filed the appeal on 29.06.2024. Therefore, there is a delay of 63 days. The assessee submitted

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

section 271(1)(c) of the Act. Since facts are same, with consent of the parties, both appeals were heard together and a common order is passed for the sake of convenience and brevity. The quantum appeal in ITA No.612/SRT/2025 is treated as “lead” case. 1 ITA Nos.612 & 613/SRT/2025/AY 2007-08 Meenaxi Gems Pvt. Ltd. 2. The grounds of appeal

MEENAXI GEMS PVT LTD,SURAT vs. INCOME TAX OFFICER, WD-1(1)(4), SURAT, SURAT

In the result, the appeal of the assessee in ITA No

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

section 271(1)(c) of the Act. Since facts are same, with consent of the parties, both appeals were heard together and a common order is passed for the sake of convenience and brevity. The quantum appeal in ITA No.612/SRT/2025 is treated as “lead” case. 1 ITA Nos.612 & 613/SRT/2025/AY 2007-08 Meenaxi Gems Pvt. Ltd. 2. The grounds of appeal

VIJAYKUMAR GAMANLAL MODI, HUF,SURAT vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

SANMUKHLAL NANUBHAI MODI HUF,SURAT vs. INCOME TAX OFFICER, WARD-1, BARDOLI, SURAT

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

NITIN KUMAR GAMANLAL MODI HUF,SURAT vs. INCOME TAX OFFICER, WARD-1,, BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

GAMANLAL NANUBHAI MODI HUF,SURAT vs. INCOME TAX OFFICER, WARD-1, , BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

MADHUBEN DILIPBHAI MODI,SURAT vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

ANILKUMAR GAMANLAL MODI, HUF,SURAT vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value

JIGNESHKUMAR S. MODI HUF,SURAT vs. INCOME TAX OFFICER, WARD-1, BARDOLI, BARDOLI

In the result, the appeal of the assessee is allowed

147 wherein long term capital gain amounting to Rs. 10,92,200/- has been brought to tax in the hands of the assessee for A.Y 2012-13. The assessee, along with co-owners, had sold a piece of land for a total sale consideration of Rs. 97,35,000/-. Given that the Stamp Duty Authority has adopted the Jantri Value