AMRUT SAROVAR,SURAT vs. PR. COMMISIONER INCOME TAX(CENTRAL), SURAT

In the result the grounds of appeal raised by the assessee in all three assessment years are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

68 and other provisions of the Act. The AO has not examined the payment of interest in cash and sources of cash payment made for purchase of land in village Kathore is also not examined either in the hand of firm or partners. Further arrangement regarding use of partners land and its related expenses of conversion of agriculture

AMRUT SAROVAR,SURAT vs. PR. COMMISIONER INCOME TAX(CENTRAL), SURAT

In the result the grounds of appeal raised by the assessee in all three assessment years are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

68 and other provisions of the Act. The AO has not examined the payment of interest in cash and sources of cash payment made for purchase of land in village Kathore is also not examined either in the hand of firm or partners. Further arrangement regarding use of partners land and its related expenses of conversion of agriculture

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 4 SURAT, SURAT vs. KISHORKUMAR DHIRAJLAL KATHROTIYA, SURAT

In the result the appeal filed by the Revenue in ITA No

sections": [ "143(3)", "153A", "147", "133A", "69C", "68", "115BBE", "69A", "292C" ], "issues": "Dispute over additions made by the AO for alleged

SATYAM TEXTILE PARK,SURAT vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), SURAT

In the result the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

68 to 69 of the act. The ld. PCIT also noted that the assessee in addition to on money must have generated some profit from allotment of plots to customers. On the various observation made by ld. PCIT, the ld AR for the assessee submits that assessee has duly accounted each and every entry of the impounded materials and prepared

SATYAM TEXTILE PARK,SURAT vs. PR. COMMISSIONER OF INCOME TAX (CENTRAL), SURAT

In the result the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

68 to 69 of the act. The ld. PCIT also noted that the assessee in addition to on money must have generated some profit from allotment of plots to customers. On the various observation made by ld. PCIT, the ld AR for the assessee submits that assessee has duly accounted each and every entry of the impounded materials and prepared

RAJESH PODDAR,SURAT vs. ACIT CENTRAL CIRCLE-4, SURAT

In the result, assessee's appeal is dismissed

68, 69 and 104\nand that purchases from both these parties are genuine and duly paid through\nbanking channel. Both the parties have mentioned their PAN and GST\nregistration numbers on their sales invoices. They have also charged GST from\nthe assessee in these bills. In the absence of any adverse material on record,\nwe find no reason to disbelieve

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, VAPI vs. RAJESHBHAI MAGANBHAI AHIR, SURAT

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

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

section 292C of the Act, without appreciating the fact that the addition was based on incriminating details/documents recovered during the course of survey proceedings. The Ld. DR further submitted that the Ld. CIT(A) also erred in deleting the addition of Rs.1,68

DCIT, CENTRAL CIRCLE-4, SURAT, SURAT vs. EKKTA DEVLOPERS, MUMBAI

In the result, both appeals are dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.576 & 577/Srt/2024 (Ays:2014-15 & 2015-16) (Hybrid Hearing) Dcit, Vs. M/S Ekkta Developers, Central Circle – 4, B-702, Business Point, S. V. Road, Surat Andheri (W), Mumbai - 400058 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefe5374R (Appellant) (Respondent) Co Nos.38 & 37/Srt/2024 (Arising Out Of Ita Nos.576 & 577/Srt/2024) (Ays: 2014-15 & 2015-16) M/S Ekkta Developers, Vs. Dcit, B-702, Business Point, S. V. Road, Central Circle – 4, Andheri (W), Mumbai - 400058 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefj3969P (Appellant) (Respondent) Appellant By Shri Ravi Kant Gupta, Cit-Dr Respondent By Shri Ramesh Malpani, Ca Date Of Hearing 30/07/2025 Date Of Pronouncement 07/08/2025

292C of the Assessee. 5) On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made by the Assessing Officer ignoring the principles of "Human Probability Test" i.e. preponderance of probabilities which is applicable for Income Tax proceedings. 6) On the facts and in the circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 4, SURAT vs. KISHORKUMAR DHIRAJLAL KATHROTIYA, SURAT

In the result the appeal filed by the Revenue in ITA No

section 115BBE is also incorrect, as the additions are\nrelate to business income arising from the real estate project. Thus\nthe Grounds raised by the assessee are allowed.\n13. In the result the appeal filed by the assessee in ITA No.\n476/SRT/2023 is allowed.\nITA No.531/Ahd/2023 for A.Y. 2018-19\n14. The Grounds of Appeal raised by the Revenue

ITO, WARD-2(2)(3), SURAT vs. MAHESHCHAND G. PATEL (HUF), SURAT

In the result, the grounds of appeal raised by the revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Physical Hearing) I.T.O., Maheshchandra G. Patel (Huf), Ward-2(2)(3), 22, Vrajbhumi, Tirumala Society, In Vs. Surat. Front Of Balaji Nagar, Piplod, Surat. Pan No. Aajhm 2315 P Appellant/ Assessee Respondent/ Revenue

292C of the Act mandates and supports such conclusion. (iv) On the facts and circumstances of the case and in law, the ld. CIT(A), Surat ought to have upheld the order of the Assessing Officer. It is, therefore, prayed that the order of the ld. CIT(A)-1, Surat may be set aside and that of the Assessing Officer

M/S. PATEL AMBALAL HARGOVANDAS & CO.,,SURAT vs. THE DCIT, CENTRAL CIRCLE-2,, SURAT

In the results, appeal filed by Revenue (in IT(SS)A Nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं/.It(Ss)A No.49/Srt/2022 Assessment Year: (2019-20) (Physical Hearing) The Acit, Central Circle-2, Vs. Rasikbhai Narottamdas Patel, Surat. Flat No.9-10, Mahavir Nagar Co.Op H.S. Ltd., Bldg-12, Nr. Gayatri Mandir, Udhna Magdalla Road, Surat – 395007. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Adgpp4550M (Appellant) (Respondent) आयकर अपील सं/.It(Ss)A No.86/Srt/2022 Assessment Year: (2015-16) The Dcit, Central Circle-2, Vs. Ashish Karamshibhai Koshiya, Surat. 40, Jivandeep Soceity, Singanpor Road, Katargam, Surat, Gujarat – 395004. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aojpk1118G (Appellant) (Respondent) आयकर अपील सं/.Ita No.185/Srt/2022 Assessment Year: (2020-21) M/S. Patel Ambalal Hargovandas Vs. The Dcit, Central Circle-2 & Co., Surat. 5/725, Haripura, Bhavaniwad, Opp. Dhobi Sheri, Surat – 395003. "थायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aadfp2517N (Appellant) (Respondent) Appellant By Shri Ashok B. Koli, Cit(Dr) Shri Vartik Choksi, Shri Biren Shah & Shri Respondent By Nitin Gheewala, Ar Date Of Hearing 26/04/2023 Date Of Pronouncement 26/05/2023 आदेश /O R D E R Per Bench:

292C(1) of the Act. [ii] On the facts and in the circumstances of the case and in law, the Ld.CIT(A) has erred in deleting the protective addition made by the Assessing Officer of Rs.10,74,15,724/- on account of unaccounted income under Sec.69A of the Act by observing that the Assessing Officer was not able to bring

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

292C of the Act and by observing that the paper\nwas not in the handwriting of assessee and not signed by the assessee and\ndespite the fact that addition has been made on the basis of incriminating\ndetails/document recovered during the search proceedings as a whatsapp\nimaged found from the mobile of the assessee and the assessee has failed

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

292C of the Act and by observing that the paper\nwas not in the handwriting of assessee and not signed by the assessee and\ndespite the fact that addition has been made on the basis of incriminating\ndetails/document recovered during the search proceedings as a whatsapp\nimaged found from the mobile of the assessee and the assessee has failed

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

292C of the Act and by observing that the paper\nwas not in the handwriting of assessee and not signed by the assessee and\ndespite the fact that addition has been made on the basis of incriminating\ndetails/document recovered during the search proceedings as a whatsapp\nimaged found from the mobile of the assessee and the assessee has failed

HEMANT NARESH AGARWAL,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIR. 4, SURAT

In the result, appeal of assessee is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआ.(खो और ज).सं /It(Ss)A No.68 & 70/Srt/2023 Assessment Years: 2015-16 & 2018-19 (Physical Court Hearing) Deputy Commissioner Of Hemant Naresh Agarwal बनाम/ Income-Tax, Central Circle-4, 701, Shree Shyam Awas, Bhatar Vs. Surat Room No.508, 5Th Floor, Road, Near Vidhya Bharti School, Aayakar Bhawan, Majura Surat-395 010 Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Auppa 9003 J (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita.No.170/Srt/2023 Assessment Year: 2020-21 Hemant Naresh Agarwal Assistant Commissioner Of बनाम/ 701, Shree Shyam Awas, Bhatar Income-Tax, Central Circle-4, Vs. Road, Near Vidhya Bharti School, Surat, Aaykar Bhawan, Surat-395 010 Majura Gate, Surat-395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Auppa 9003 J (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By Shri Kiran K. Shah राज" की ओर से /Revenue By Shri Mukesh Jain, Cit-Dr & Shri Kevin Langaliya, Ca सुनवाई की तारीख/Date Of Hearing 18/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 24/10/2025

section 292C of the assessee. IT(SS)A No.68, 70 & ITA. No.170/Srt/2023 A.Ys 15-16, 18-19 & 20-21 Sh. Hemant N. Agarwal 5. Without prejudice to and in addition to the grounds No.1, 2, 3 & 4 on the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition made

DY. COMMISSIONER OF INCOME TAX, CC-4, SURAT, SURAT vs. M/S. SHREE KUBERJI ASSOCIATES, SURAT

In the result, the ground No

Bench: Shri Pawan Singh & Dr Arjun Lal Saini(Hearing In Physical Court) आ. (खो और ज).सं./It(Ss)A No.28/Srt/2023 (Ay 2019-20) Shree Kuberji Associates, Assistant Commissioner Of 2Nd Floor, Shree Kuberji Income Tax, Central Circle-4, Vs Corporate House, Khana Kuva Surat, Aayakar Bhawan, Road, Begumpura, Surat- Majura Gate, Sura-395001 395002 Pan No. Acqfs 0423 D अपीलाथ"/Appellant ""थ" /Respondent आ.(खो और ज).सं./It(Ss)A No.29/Srt/2023 (Ay 2020-21) Shree Kuberji Associates Assistant Commissioner Of 2Nd Floor, Shree Kuberji Income Tax, Central Circle-4, Corporate House, Khana Kuva Surat, Aayakar Bhawan, Majura Gate, Sura-395001 Road, Begumpura, Surat- Vs 395002 Pan No. Acqfs 0423 D अपीलाथ"/Appellant ""थ" /Respondent आ.अ.सं./Ita No.155/Srt/2023 (Ay 2020-21) Dy.Commissioner Of Income- M/S Shree Kuberji Associates Tax, Central Circle-4, Surat, 2Nd Floor, Shree Kuberji Vs Room No.508, 5Th Floor, Corporate House, Khana Kuva Aayakar Bhawan, Majura Gate, Road, Begumpura, Surat- Surat-395001 395002 Pan No. Acqfs 0423 D अपीलाथ"/Appellant ""थ" /Respondent आ. (खो और ज).सं./It(Ss)A No.30/Srt/2023 (Ay 2019-20) Shree Kuberji Leisure & Assistant Commissioner Of Infraspace Llp, Income Tax, Central Circle-4, Vs Plot No.2 H/28/29, Shree Surat, Aayakar Bhawan, Kuberji Corporate House, Majura Gate, Sura-395001 Khana Kuva Road, Begumpura, Surat-395002 Pan No. Adcfs 0636 D अपीलाथ"/Appellant ""थ" /Respondent आ.(खो और ज).सं./It(Ss)A No.34/Srt/2023 (Ay 2019-20) Dy.Commissioner Of Income- M/S Shree Kuberji Leisure & Tax, Central Circle-4, Surat, Infraspace Llp, Room No.508, 5Th Floor, Plot No.2.H/28/29, Shree

292C is not applicable. The assessee strongly opposed the estimation of Rs.58.00 lakh per shop IT(SS)A No.28-31, 34-35/SRT/2023 & ITA 155/SRT/2023 (A.Ys 19-20 & 20-21) Shree Kuberji Leisure & Infraspace LLP & Shree Kuberji Associates on third floor, which is not possible. The assessee further stated that Assessing Officer relied on general statement of Pratik Agrawal, wherein

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -2, SURAT vs. SHAH MAGANLAL GULABCHAND CHOKSI, SURAT

In the result, appeals of assessee are allowed for statistical purpose

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)

Section 292C of the I.T. Act. [xiii] In addition and in alternative to Ground No. 1 to 12, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the additions made by the Assessing Officer ignoring the principles of "Human Probability Test" i.e. preponderance of probabilities which is applicable

SHAH MAGANLAL GULABCHAND CHOKSI,SURAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, appeals of assessee are allowed for statistical purpose

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI BIJAYANANDA PRUSETH (Accountant Member)

Section 292C of the I.T. Act. [xiii] In addition and in alternative to Ground No. 1 to 12, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in deleting the additions made by the Assessing Officer ignoring the principles of "Human Probability Test" i.e. preponderance of probabilities which is applicable