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

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

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

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

SANJAY SIVABHAGWAN KEYAL,SURAT vs. ITO, WARD-2(3)(4), SURAT

In the result, the appeal of the assessee is dismissed

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Sanjay Sivabhagwan Keyal Ito, Ward – 2(3)(4), Flat No.304, 3Rd Floor, Room No.613, Vatika Township, Near Model, Vs. Aaaykar Bhavan, Township, Parvat Patia Majura Gate, Surat - 395010. Surat - 395002. Pan No. Adspk 6097N Appellant Respondent

u/s. 144 r.w.s. 147 may be quashed and / or addition made by the assessing officer may please be ed and / or addition made by the assessing officer may please be ed and / or addition made by the assessing officer may please be deleted.” 2. Briefly stated, the facts of the case, as emerging from the the facts of the case

TULSI JEWELLERS,NA vs. ARIVS.INCOME TAX OFFICER, WARD 5, NAVSARI

In the result assessee's appeal is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

80. In Ashish Agarwal (supra), this court directed that Section 148 notices which were challenged before various High Courts “shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section 148-A(b).”Further, this

TULSI JEWELLERS,NA vs. ARIVS.INCOME TAX OFFICER - WARD 5, NAVSARI

In the result assessee's appeal is allowed

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.946 & 947/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Tulsi Jewellers Income Tax Officer, Ward-5, बनाम/ 7-8, Saibaba Complex Navsari, 204, 2Nd Floor, Income Vs. Gauaarbag, Nr Lmp School Tax Office, Charpool, Awabaug, Chikhli Roa Bilimora, Tal: Navsari-396 445 Gandevi-396 321 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aakft 8368 G (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ashish Pophare, Cit-Dr & Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 29/08/2025

80. In Ashish Agarwal (supra), this court directed that Section 148 notices which were challenged before various High Courts “shall be deemed to have been issued under section 148-A of the Income-tax Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of Section 148-A(b).”Further, this

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

In the result, assessee's appeal is allowed

section 147 of the Act. It is well settled that an assessee can raise\na legal ground at any stage of proceedings as held by the Apex Court in the\ncase of CIT v/s. Varas International reported in 284 ITR 80(SC) and\nNational Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC).\nKeeping in view

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

section 147 of the Act. It is well settled that an assessee can raise a legal ground at any stage of proceedings as held by the Apex Court in the case of CIT v/s. Varas International reported in 284 ITR 80(SC) and National Thermal Power Co Ltd. v/s CIT reported in 229 ITR 383 (SC). Keeping in view

JHONSON ELECTRIC COMPANY LIMITED,,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(1)(3),, VADODARA

Bench: Shri Pawan Singh, Hon'Ble & Shri Arjun Lal Saini, Hon'Bleआ.अ.सं./I.T.A No.754/Ahd/2017 "नधा"रणवष"/Assessment Year: 2008-09 Jhonson Electric Company Vs. The Income Tax Officer, Limited, Ward-1(1)(3), Vadodara – 390007. C/O. C.K.Pithawala Bhimpore, Post: Dumas Dist: Surat. [Pan: Aaacj 4908 P अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Sh. Saurabh Soparkar With Sh. Mayur K. Swadia Ars. राज"वक"ओरसे /Revenue By Mrs. Anupama Singla – Sr. Dr सुनवाई की तारीख/ Date Of Hearing: 23.09.2020 उ"घोषणा क" तार"ख/Pronouncement On: 22.10.2020 आदेश /O R D E R Per Pawan Singh, Jm: 1. This Appeal By The Assessee Is Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-1, Vadodara Dated 17.01.2017 For The Assessment Year 2008-09. 2. Grounds Raised By The Assessee Read As Under: The Learned Commissioner Of Income Tax (Appeals) Has Erred In Facts “1. & In Law In Treating Long Term Capital Gain As Short Term Capital Gain. 2. Your Appellant Craves The Right To Add To Or Alter, Amend, Substitute, Delete Or Modify All Or Any Of The Above Grounds Of Appeal.”

reassessment. The AO also issued show cause notice on 17.02.2015 requiring the assessee to show cause as to why stamp value of Rs.4.6 Crores be not treated as sale consideration for the purpose of computation of capital gain and further addition of Rs.2.6 Crore should not be made as per the provision of section 50C. The assessee Johnson Electric

MOHANBHAI RAGHAVBHAI BELADIYA,SURAT vs. INCOME TAX OFFICER, WARD - 3(2)(5), SURAT

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

Bench: Shri Dr. A. L. Sainiआयकर अपील सं./Ita No.359/Srt/2023 Assessment Year: (2012-13) (Physical Hearing) Mohanbhai Raghavbhai Beladiya, Vs. The Ito, 41-42, Vishnu Nagar Society – 1, Ward-3(2)(5), Ankur Char Rasta, A. K. Road, Surat Surat – 395008. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aospb9227J (Assessee) (Respondent)

147 of the Income Tax Act, 1961 were initiated in assessee`s case for A.Y. 2012-13 by issuing notice u/s 148 of the Income Tax Act, 1961 to the assessee on 31/03/2019 after obtaining necessary approval from competent authorities requesting him to deliver his return of income within 30 days from the receipt of the notice. 5. In response

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

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 आदेश

VANMALIBHAI MULJIBHAI PATEL L/H RANJANBEN DEEPAKBHAI PATEL,NA vs. ARIVS.ITO, WARD 5, NAVSARI

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.345/Srt/2025 Assessment Year: (2011-12) (Hybrid Hearing) Vanmalibhai Muljibhai Patel, Vs. Ito, L/H Of Ranjanben Deepakbhai Patel Ward - 5, 16, Shrinikunj Society, Ashabaug, Navsari Navsari - 396445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abjpp3114G (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Suresh K. Kabra, Ca Respondent By Ms. Jayshree Thakur, Sr. Dr Date Of Hearing 23/09/2025 Date Of Pronouncement 04/12/2025

147 of the Act by computing total income of Rs.25,61,553/-. Penalty proceedings u/s 271(1)(c) r.w.s. 274 of the Act was also separately initiated. 4. Aggrieved by the order of AO, the assessee filed appeal before the CIT(A). The appellant raised various grounds of appeal before the CIT(A), which are at pages

SHRI CHAMPAKBHAI D. PATEL,BARDOLI vs. COMMISSIONER OF INCOME TAX (IT & TP), AHMEDABAD

In the result, appeal filed by the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.15/Srt/2023 Assessment Year: (2013-14) (Physical Hearing) M/S. Champakbhai D. Patel, Vs. The Cit(It & Tp), Mota Sardar Chowk, Bardoli, Ahmedabad Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Atlpp0997K (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Shri S. M. Keshkamat, Cit(Dr) Respondent By Date Of Hearing 13/09/2023 Date Of Pronouncement 25/09/2023

147 of the Act and in response to notice under section 148 of the Act, the assessee filed the return of income. During the reassessment proceedings, the assessee submitted bank statement, confirmation of parties and also submitted the reply of the notice issued by the Assessing Officer under section 142(1) of the Act. Therefore, assessing officer made adequate enquiry

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

80,49,899 – 4,26,19,740).\nRather, the addition was restricted to Rs. 4,26,19,740/-.\n1.20 The appellant relies on the decision of Hon'ble Surat Tribunal in the case of Shree\nKuberji Associates / Shree Kuberji Leisure & Infraspace LLP wherein in this particular\ngroup, margin of 13 % profit was upheld vide IT (SS) A No. 28/29/30/31/34/35/SRT

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

80,49,899 – 4,26,19,740).\nRather, the addition was restricted to Rs. 4,26,19,740/-.\n1.20 The appellant relies on the decision of Hon'ble Surat Tribunal in the case of Shree\nKuberji Associates / Shree Kuberji Leisure & Infraspace LLP wherein in this particular\ngroup, margin of 13 % profit was upheld vide IT (SS) A No. 28/29/30/31/34/35/SRT

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

80,49,899 – 4,26,19,740).\nRather, the addition was restricted to Rs. 4,26,19,740/-.\n1.20 The appellant relies on the decision of Hon'ble Surat Tribunal in the case of Shree\nKuberji Associates / Shree Kuberji Leisure & Infraspace LLP wherein in this particular\ngroup, margin of 13 % profit was upheld vide IT (SS) A No. 28/29/30/31/34/35/SRT