RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, WARD 5, , VAPI

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

section 40A(3A) of the Act, 1961. (disallowance in ground no.7 in ITA No.194/SRT/22 at Rs.38,000/- and Ground No.3 in ITA No.193/SRT/22 at Rs.11,88,236/- ) (iv) Ground No.1 raised by the assessee, in ITA No. 194/SRT/2022, and ground No. 2 raised by the assessee, in ITA No.193/SRT/2022, are as follows: “On the facts on the facts

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

section 40A(3A) of the Act, 1961. (disallowance in ground no.7 in ITA No.194/SRT/22 at Rs.38,000/- and Ground No.3 in ITA No.193/SRT/22 at Rs.11,88,236/- ) (iv) Ground No.1 raised by the assessee, in ITA No. 194/SRT/2022, and ground No. 2 raised by the assessee, in ITA No.193/SRT/2022, are as follows: “On the facts on the facts

BHAGYASHRI CREATION PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is allowed

sections": ["263", "143(3)", "143(3A)", "143(3B)", "68", "56(2)(viib)", "11UA"], "issues": "Whether the PCIT's revisionary

MUKESHBHAI RAMUBHAI AHIR,,SURAT vs. ITO,WARD-1(3) (3),, SURAT

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Mukeshbhai Ramubhai Ahir Ito, Ward-1(3)(3), 49,-B, Ambanagar, Room No. 603, 6Th Floor, Vs B/H Kapadia Health Club, Aayakar Bhavan, Majura Bhatar, Surat-395002. Gate, Surat. Pan : Aqqpa1546H Applicant Respondent

68,83,333/-. The assessee claimed indexation cost at Rs. 62,30,412/ by adopting fair market value at Rs. 350/ per sq Mtr as on 01.04.1981. The assessee filed its reply dated 23.03.2016 and stated that no Jantri rate concept was applicable in 1981. The sale-deeds were executed as per consideration shown on record by purchaser and seller

BAKER ABDULAZIZ NORAT,PANOLI, BHARUCH, GUJARAT vs. INCOME TAX OFFICE, WARD 1(1), BHARUCH, BHARUCH, GUJARAT

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

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1232/Srt/2024 Assessment Year: (2018-19) (Hybrid Hearing) Baker Abdulaziz Norat, Vs. Ito, 107, Panoli Travels, Station Road, Ward – 1(1), Panoli, Bharuch – 394115 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Akepn7411Q (Appellant) (Respondent) Appellant By Ms Vidhi Pandya, Ca Respondent By Shri Abhishek Gautam, Sr. Dr Date Of Hearing 24/09/2025 Date Of Pronouncement 21/11/2025

section 68 books of account must be of assessee himself, Thus question of imposing penalty u/s 270A for under reporting of income is not arise. 3. That the appellant craves leave to add, to amend, modify, rescind, supplement or alter any of the grounds stated herein above, either before or at the time of this Appeal.” 3. The facts

M/S. UNITED SALT WORKS,BHARUCH vs. ITO, WARD 1(3), BHARUCH

In the result, the grounds of appeal raised by assessee

Bench: Shri Pawan Singhआ.अ.सं./Ita No.208/Srt/2020 (Ay 2014-15) (Hearing In Physical Court) M/S United Salt Works Income Tax Officer, 9, Pruthvi Nagar, 1St Floor, Ward-1(3), 2Nd Floor, Above Vs Station Road, Bharuch- Bank Of Baroda Building, 392001 Station Road, Bharuch- Pan : Aaafu 4725 A 392001 अपीलाथ"/Appellant ""यथ" /Respondent

68,050/- on 27.03.2014 and both the payments were made in cash. I find that assessee has not disputed that expenses were paid against the liability. I find that on further there is no further dispute that DGVCL is a Company owned and controlled by Government of Gujarat. Further I find that genuineness of expenses is not doubted by Assessing

HOTEL ROYAL GARDEN,,DAMAN AND DIU (UT) vs. THE PCIT, VALSAD, VALSAD

In the result, appeal filed by assessee is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.103/Srt/2022 Assessment Year: (2017-18) (Physical Court Hearing) Hotel Royal Garden, Vs. The Pcit, Valsad. Main Road, Dabhel, Nani Daman – 396210, Daman & Diu (Ut). "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaefh2587H (Appellant) (Respondent) Appellant By Shri Darshit J. Naik, Ca With Jayraj M. Naik, Ca Respondent By Shri Ashok B. Koli, Cit(Dr) Date Of Hearing 05/01/2023 Date Of Pronouncement 21/03/2023

3a) of the letter dated 25.03.2022 the assessee seems to be confused whether there was a diary found at the time of survey conducted by the Income Tax Department, in which such sundry receivable were recorded or not because it is a stated that: "Nothings in the form of a diary in which these receivables were recorded was impounded during

HARMONY YARNS PVT. LTD.,SURAT vs. PR. COMMISSIONER OF INCOME TAX -1, SURAT

In the result, the appeal filed by the assessee is partly allowed in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.348/Srt/2023 Assessment Year: (2018-19) (Physical Hearing) Harmony Yarns Private Vs. The Pcit-1, Limited, Surat Plot-65, 1St Floor Subhash Nagar Society, Ghod Dod Road, Nr. Ram Chowk, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaach5895F (Appellant) (Respondent) Appellant By Shri Rasesh Shah, Ca Respondent By Shri Airiju Jaikaran, Cit(Dr) Date Of Hearing 12/10/2023 23/11/2023 Date Of Pronouncement

3A) & 143(3b) of the Act, on 27.01.2021, accepting the returned income of the assessee. 3. Later on, the Learned Principal Commissioner of Income Tax (in brief ‘ld. PCIT’), exercised his jurisdiction under section 263 of the Income Tax Act, 1961, The ld. PCIT, on perusal of the records, noticed that the assessee company had received unsecured loan

UMADEVI SHIVNARAYAN GARG,SURAT vs. PR. COMMISSIONER OF INCOME TAX-1, SURAT, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.68/Srt/2023 ("नधा"रणवष" / Assessment Year: (2018-19) (Virtual Court Hearing) Umadevi Shivnarayan Garg, Principal Commissioner Of Income- Tax-1, Surat, Room No.123, 1St Floor, 513, Sai Darshan Market, Vs. Ring Road, Surat-395002 Aayakar Bhawan, Majura Gate, Surat-395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpg 0885 A (अपीलाथ" /Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By : Shri Ramesh Malpani, C.A राज"व क" ओर से /Respondent By: Shri Ashok B. Koli, Cit-D.R

3A) r.w.s. 143(3B) of the Act dated 11.02.2021 erroneous in so far as it is prejudicial to the interest of the Revenue within the meaning of Section 263 of the Act. 7. Therefore, ld PCIT issued a show cause notice bearing DIN No.ITBA/COMF/17/2022-23/1047657169(1) dated 25.11.2022 to the assessee to explain the transaction. ITA No.68/SRT/2023 A.Y.18-19 Umadevi

THE SURAT PEOPLES CO OPERATIVE BANK LTD.,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, SURAT, SURAT

In the result the appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.278/Srt/2023 (Assessment Year: 2018-19) (Physical Hearing) The Surat People’S Co Operative Vs. The Pcit, Bank Ltd., Surat-1 1, Vasundhara Bhavan, Timliawad, Nanpura, Surat - 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2885P (Appellant) (Respondent)

3A) and 143(3B) of the Act was framed by assessing officer, on 17.03.2021, by accepting the returned income. 4. Later on, Learned Principal Commissioner of Income Tax, Surat-1 [in short ‘the Ld. PCIT’], exercised his jurisdiction under section 263 of the Income Tax Act, 1961. On verification of Audited Balance Sheet and Tax Audit Report

HASUMATIBEN JAGDISHBHAI PATEL, ,SURAT vs. PRINCIPAL COMMISSIONER OF INCOME TAX, VALSAD

In the result, appeal of assessee is allowed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.322/Srt/2023 (Ay 2018-19) (Hearing In Physical Court) Hasumatiben Jagdishbhai Principal Commissioner Of Patel Income-Tax, Valsad, 301, Vs 80 Shree Ram Estate, Opp. 3Rd Floor, Income Tax Pandesara Petrol Pump Office, Palak Arcade, Shanti Bhedwad, Surat-394220 Nagar, Tithal Road, Pan : Aaopp 1698 K Valsad-396001 अपीलाथ"/Appellant ""यथ" /Respondent

3A) & 143(3B) of the I.T. Act, 1961 was neither erroneous nor prejudicial to the interest of the revenue. Hasumatiben J Patel 2.On the facts and circumstances of the case as well as law on the subject, the learned Pr. CIT has erred inholding that loan processing charges of Rs.3,68,630/- are capital in nature and required