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.

undisclosed income of the block period that was assessed, section 153A of the Act seeks to assessee the total income for the assessment year, which is clear from the first proviso thereto which provides that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years. The second proviso

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, 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.

undisclosed income of the block period that was assessed, section 153A of the Act seeks to assessee the total income for the assessment year, which is clear from the first proviso thereto which provides that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years. The second proviso

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, 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.

undisclosed income of the block period that was assessed, section 153A of the Act seeks to assessee the total income for the assessment year, which is clear from the first proviso thereto which provides that the Assessing Officer shall assess or reassess the total income in respect of each assessment year falling within such six assessment years. The second proviso

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

undisclosed income in the hands of the company. In the present case, the assessee even has proved the source of source. therefore, the creditworthiness was also proved, consequently, no addition made u/s 68 of the Act can be said to be justified. The ratio laid down in Creative World Telefilms Ltd. (supra) by Hon'ble jurisdictional High Court squarely comes

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

undisclosed income in the hands of the company. In the present case, the assessee even has proved the source of source. therefore, the creditworthiness was also proved, consequently, no addition made u/s 68 of the Act can be said to be justified. The ratio laid down in Creative World Telefilms Ltd. (supra) by Hon'ble jurisdictional High Court squarely comes

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

income on\n31.03.2021 declaring total income of Rs. 32,47,260/-. Subsequently, a search\nand seizure action was conducted u/s. 132 of the Act in case of Kuberji Group\non 06.02.2020. The residential premises of Shri Naresh Bisheshwarlal Agrawal\n(assessee herein) was also covered during the search and seizure operation.\nVarious incriminating documents were found and seized, which indicated

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

u/s 69B towards purchase of land at block No.7 and 287\nKumbharia, (ii) Rs.5,94,15,000/- u/s 69A on account of on-money receipt of\nKuberji Crown and (iii) Rs.55,00,000/- u/s 69B for unaccounted payment for land\nat plot No. 224 at Kumbharia.\n44.1 Aggrieved by the order of AO, the assessee filed appeal before

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

undisclosed investment on purchase of\nvarious lands. The Assessing Officer has not examined the seller of land. There is no\nfinding of Assessing Officer whether the consideration paid by assessee was not in\naccordance with Jantri rate or less than the value determined by the Stamp Valuation\nAuthority. It is settled law that no addition on estimation basis

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

DAGINA JEWELLERS INDIA (P) LTD,SURAT vs. ACIT, CENTRAL CIRCLE-2, SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT vs. M/S. DAGINA JEWELLERS PVT. LTD., , SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

DAGINA JEWELLERS INDIA (P) LTD.,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,2, SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

DY. COMMISSIONER OF INCOME TAX, CENTRA CIR.2, SURAT vs. DAGINA JEWELLERS INDIA PVT. LTD., SURAT

In the result, grounds Nos

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

147 of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. 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 of convenience, the grounds as well as the facts narrated in ITA No.51/SRT/2022 for assessment

NYA INTERNATIONAL,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 1, SURAT

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.57/Srt/2022 "नधा"रणवष"/Assessment Year: (2012-13) (Physical Court Hearing) Nya International, Vs. The Pcit-1, Unit No.360, Plot No.239, Sez, Gidc Surat. Sachin, Suarat – 394230. (Assessee) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfn1681M

Undisclosed sources and may not be added back into the income of your Firm as Income from Other Sources after disallowing the deduction u/s 10AA of the Act. Please note that it's a time barring issue and due to limitation of time the reply should be submitted to this office on or before 28/12/2017

INCOME TAX OFFICER, WARD 2(3)(7), SURAT vs. SHRI ANIL PUKHRAJ JAIN, SURAT

In the result the ground No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.89/Srt/2017 िनधा"रण वष"/Assessment Year: (2008-09) (Physical Court Hearing) Income Tax Officer, Ward-2(3)(7), Anil Pukhraj Jain, Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206-2Nd Floor, Tulsi Building, Bhavan, Adajan, Surat-395009 Vs. Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. (Appellant) (Respondent)/ "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q ""या"ेप सं Cross Objection No.10/Srt/2021 (A/O Ita No.89/Srt/2017) िनधा"रण वष"/Assessment Year: (2008-09) Anil Pukhraj Jain, Income Tax Officer, Ward-2(3)(7), Room No.414, 4Th Floor, Aayakar Prop. Of Aakruti Stone, 206- 2Nd Floor, Tulsi Building, Vs. Bhavan, Adajan, Surat-395009 Somnath Mahadev Ni Sheri, Mahidharpura, Surat – 395009. Appellant/Co-Objector (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahapj8569Q िनधा"रती क" ओर से /Assessee By Shri Sapnesh R. Sheth, Ca राज"व क" ओर से /Respondent By Shri Ashok B. Koli, Cit-Dr सुनवाई क" तारीख/Date Of Hearing 23/12/2022 उ"ोषणा क" तारीख/Date Of Pronouncement 23/ 01/2023

reassessment proceedings under section 147/148 of the Act. During the assessment stage assessee did not file return of income in response to notice issued u/s 148 of the Act but he filed reply in the course of assessment proceedings stating to treat original return of income filed under section 139(1) of the Act, as the return of income field

ACIT, CIRCLE-3(3), SURAT vs. M/S. D P VEKARIYA, SURAT

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

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No. 172/Srt/2020 Assessment Year: (2009-10) (Physical Court Hearing) The Acit, Circle-3(3), Vs. M/S. D. P. Vekariya, Surat Skylark Shopping, B/H Kapodara Police Station, Varachha Road, Surat, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabfd 8442 Q (Revenue)/(Assessee) (Assessee)/(Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Abhishek Gautam, Sr. Dr 02/06/2022 Date Of Hearing 30/06/2022 Date Of Pronouncement

147 of the Income Tax Act, 1961 and hence I have reason to believe that income to such extent escaped assessment and therefore, it is hereby proposed for issue of notice u/s 148 of the Act, and as the case falls under Section 149(1)(b), approval may kindly be considered and accorded, as laid down under proviso to section

ALKESHKUMAR MAGANBHAI PATEL,BHARUCH vs. INCOME TAX OFFICER (ITO),WARD 1(1) BHARUCH, BHARUCH

In the result, the Appeal of the Assessee is dismissed

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Alkeshkumar Maganbhai Patel, Ito Ward 1(1), 30 Atmiya Nagar, Near Kgm Income Tax Office, Bharuch, Vidyalay Zadeshw Zadeshwar, Vs. Income-Tax Office, Hari Kunj, Bharuch-392011. Station Road, Bharuch-356069. Pan No. Bklpp 8435 L Appellant Respondent

undisclosed interest interest income income under under the the Income Tax Act, Act, 1961. 2. Despite notifying for hearing Despite notifying for hearing, neither anyone attended nor neither anyone attended nor any application for adjournmen any application for adjournment was filed before us and t was filed before us and therefore, we were of the opinion that the assessee