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.

seizure action carried out in the case of the assessee. (b) The AO has noted that the search has revealed that the assessee - company has received share application money of Rs. 2.20 crores from Rangila Suppliers Pvt. Limited, a loss making company with no fixed assets. (c) This information was not available at the time of passing the original assessment

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.

seizure action carried out in the case of the assessee. (b) The AO has noted that the search has revealed that the assessee - company has received share application money of Rs. 2.20 crores from Rangila Suppliers Pvt. Limited, a loss making company with no fixed assets. (c) This information was not available at the time of passing the original assessment

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

search and seizure operation u/s 132 of the Act in case of the assessee as well as in the case of Shri Shankarlal Uttamchandani, no evidence of payment of unaccounted money was found for shops transferred in the name of the assessee. He also submitted that the AO had confronted digital image of first floor, but the assessee

SMT. MUKTABEN NISHANTBHAI PATEL,ANKLESHWAR vs. INCOME TAX OFFICER WARD -2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

search and seizure and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely. Further, in respect of pending assessment proceedings also, AOs should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." 7. From

SHRI NISHANT KANTILAL PATEL,BHARUCH vs. INCOME TAX OFFICER, WARD-2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

search and seizure and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely. Further, in respect of pending assessment proceedings also, AOs should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." 7. From

SHRI NISHANT KANTILAL PATEL,BHARUCH vs. INCOME TAX OFFICER, WARD-2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

search and seizure and survey operations no attempt should be made to obtain confession as to the undisclosed income. Any action on the contrary shall be viewed adversely. Further, in respect of pending assessment proceedings also, AOs should rely upon the evidences/materials gathered during the course of search/survey operations or thereafter while framing the relevant assessment orders." 7. From

INCOME TAX OFFICER, WARD-2(3)(8), SURAT vs. MAHAVEER SHANTILAL JAIN, SURAT

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.453/Srt/2019 "नधा"रण वष"/Assessment Year: (2013-14) (Physical Hearing) The Ito, Vs. Mahaveer Shantilal Jain, Ward-2(3)(8), Prop. M/S Mukesh Diamonds, 1St Surat. Office No.401, Floor, H.No.5/1171/72/73/1090, New Dtc, Hath Falia, Haripura, Surat – 395009. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aqupj6439L Appellant By Shri Ritesh Mishra, Cit(Dr) Respondent By Shri P. M. Jagasheth, Ca Date Of Hearing 08/09/2023 Date Of Pronouncement 25/09/2023

seizure action, it was conclusively proved that 453/SRT/2019/AY.2013-14 Mahaveer Shantilal Jain these diamond concerns are only on paper base with no real business activities. Findings of the search action on Shri Rajendra Jain and Shri Bhanwarlal Jain reveals that Shri Rajendra Jain and Shri Bhanwarlal Jain and their associates manage, control and operate numerous concerns in the name of various

SMT. KANCHANBEN PRAVINBHAI SHETH,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.343 & 344/Srt/2025 Assessment Year: (2018-19) Kanchanben Pravinbhai Sheth Vs. Pcit - 1, Surat 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adops2971D (Appellant) (Respondent) Gautam Pravinbhai Sheth (Huf) Vs. Pcit - 1, 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafhg1435A (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms. Namita Patel, Sr. Dr Date Of Hearing 25/08/2025 Date Of Pronouncement 18/11/2025

seizure action, several incriminating documents, communications and digital data had been found, establishing clearly the modus operandi of providing exempt bogus long term capital gain/loss and rigging the prices of various scrips on stock exchange. Therefore, the case of the assessee was reopened u/s.147 and notice u/s.148 of the Act was issued on 31.03.2022. 5. During the assessment proceedings, notices

GAUTAM PRAVINCHANDRA SHETH HUF,SURAT vs. PCIT-1, SURAT

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.343 & 344/Srt/2025 Assessment Year: (2018-19) Kanchanben Pravinbhai Sheth Vs. Pcit - 1, Surat 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Adops2971D (Appellant) (Respondent) Gautam Pravinbhai Sheth (Huf) Vs. Pcit - 1, 3/A, 1 St Floor, Royal Vila Apts., Surat Ghoddod Road, Surat (Jao: Ito, Ward – 1(3)(1), Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aafhg1435A (Appellant) (Respondent) Appellant By Shri Sapnesh Sheth, Advocate Respondent By Ms. Namita Patel, Sr. Dr Date Of Hearing 25/08/2025 Date Of Pronouncement 18/11/2025

seizure action, several incriminating documents, communications and digital data had been found, establishing clearly the modus operandi of providing exempt bogus long term capital gain/loss and rigging the prices of various scrips on stock exchange. Therefore, the case of the assessee was reopened u/s.147 and notice u/s.148 of the Act was issued on 31.03.2022. 5. During the assessment proceedings, notices

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT, SURAT vs. JAYANTIBHAI VIRJIBHAI BABARIYA, SURAT

In the result, the appeal of the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.297/Srt/2023 (िनधा"रणवष" / Assessment Year: (2018-19) (Virtual Court Hearing) Assistant Commissioner Of Shri Jayantibhai Virjibhai Babariya, Income-Tax, Circle-2, Surat, Vs. K-801, River View Heights, Room No.503, 5Th Floor, Aayakar Pedar Road, Mota Varachha, Bhawan, Majura Gate, Surat- Surat-394101 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpb 0820 M (अपीलाथ" /Appellant) (""थ"/Respondent)

seizure action. 5. On the facts and circumstances of the case and in law, the Ld.CIT(A) has failed to appreciate the fact that the Valuation Report of the DVO was mere estimates on the basis of sale instances of the locality as per their Jantri Value without taking into consideration the incriminating and corroborative evidences in respect

MS. SHREE WAHEGURU FASHIONS PVT. LTD.,RING ROAD, SURAT vs. PCIT , AAYAKAR BHAVAN, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.402/Srt/2024 Assessment Year: (2020-21) (Hybrid Hearing) M/S Shree Waheguru Fashions Principal Commissioner Of बनाम/ Pvt. Ltd., B-1110, Radha Krishna Vs. Income-Tax (Central), Textile Market, Ring Road, Surat Central Circle-1, Surat, Aayakar - 395002 Bhavan, Majura Gate, Surat- 395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aahcs 9568 H (अपीलाथ"/Appellant) (""थ" /Respondent)

seizure operation u/s 132 of the Act was conducted on 25.06.2019 and cash of Rs.10,00,000/- was seized from Shri Amit Babulal Adnani, CEO of the assessee-company. Shri Adnani admitted in his statement u/s 132(4) that the seized cash belonged to the appellant-company. The assessee filed its return of income

SHRI JAYANTIBHAI VIRJIBHAI BABARIYA,SURAT vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.,2, SURAT

In the result, appeals filed by the Revenue (in ITA nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.110/Srt/2021 ("नधा"रणवष" / Assessment Year: (2016-17) (Physical Court Hearing) Jayantibhai Virjibhai Babariya, Vs. The Acit, Central Circle-2, K-801, River View Heights, Surat. Peddar Road, Mota Varachha, Surat-394101 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpb0820M (Assessee) (Respondent) आयकरअपीलसं./Ita No.195/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) The Dcit, Central Circle-2, Vs. Jayantibhai Virjibhai Babariya, K-801, River View Heights, Surat. Peddar Road, Mota Varachha, Surat-394101 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpb0820M (Assessee) (Respondent) Shri Ashwin K. Parekh, Ar Assessee By Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 07/10/2022 Date Of Pronouncement 22/11/2022

seizure action. 110 & 195/SRT/2021/AYs.2016-17 & 2017-18 Jayantibhai Virjibhai Babariya 5. On the facts and circumstances of the case and in law, the Ld.CIT(A) has failed to appreciate the fact that the Valuation Report of the DVO was mere estimates on the basis of sale instances of the locality as per their Jantri Value without taking into consideration the incriminating

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-2, SURAT vs. SHRI JAYANTIBHAI VIRJIBHAI BABARIYA, SURAT

In the result, appeals filed by the Revenue (in ITA nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita No.110/Srt/2021 ("नधा"रणवष" / Assessment Year: (2016-17) (Physical Court Hearing) Jayantibhai Virjibhai Babariya, Vs. The Acit, Central Circle-2, K-801, River View Heights, Surat. Peddar Road, Mota Varachha, Surat-394101 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpb0820M (Assessee) (Respondent) आयकरअपीलसं./Ita No.195/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) The Dcit, Central Circle-2, Vs. Jayantibhai Virjibhai Babariya, K-801, River View Heights, Surat. Peddar Road, Mota Varachha, Surat-394101 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afhpb0820M (Assessee) (Respondent) Shri Ashwin K. Parekh, Ar Assessee By Respondent By Shri Ritesh Mishra, Cit-Dr Date Of Hearing 07/10/2022 Date Of Pronouncement 22/11/2022

seizure action. 110 & 195/SRT/2021/AYs.2016-17 & 2017-18 Jayantibhai Virjibhai Babariya 5. On the facts and circumstances of the case and in law, the Ld.CIT(A) has failed to appreciate the fact that the Valuation Report of the DVO was mere estimates on the basis of sale instances of the locality as per their Jantri Value without taking into consideration the incriminating

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR. -4, SURAT vs. SHREE KUBERJI TEXTILE DECK, SURAT

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No. 63 & 64/Srt/2023 (Ay: 2016-17 & 2019-20) (Physical Hearing) D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/ Revenue Respondent/ Assessee D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/Revenue Respondent/Assessee

seizure action was carried out in case of M/s Kuberji Group of Surat on 06/02/2020. The assessee is one of the entity, therefore, covered in the said search. At the time of search action, various incriminating evidences were found and seized. Consequent upon, case of assessee group was centralized. Notice under Section 153A of the Income

MRS. DAXABEN JAYESHBHAIPATEL,VAPI vs. ITO, WARD-2, VAPI, VAPI

In the result, both appeals filed by the assessee are partly allowed in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.228 & 229/Srt/2020 Assessment Years: (2011-12 & 2012-13) (Physical Court Hearing) Dixaben Jayeshbhai Patel, Vs. The Ito, Ward-2, Plot No.42, Krishna Colony, Vapi. Muktanand Marg, Chala, Vapi, Gujarat – 396191. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahspp3273F (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 02/02/2023 10/02/2023 Date Of Pronouncement

transferred to on account of Panji branch and they are also withdrawn in cash by different individuals. Since the use of funds is not ascertainable and majority of transactions are cash withdrawals over the period in crores of rupees i.e. total cash withdrawals from both accounts in 8 months is to the tune of Rs.9.75 crores. Therefore, we are reporting

MRS. DIXABEN JAYESHBHAI PATEL,VAPI vs. ITO, WARD-2, VAPI, VAPI

In the result, both appeals filed by the assessee are partly allowed in above terms

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.228 & 229/Srt/2020 Assessment Years: (2011-12 & 2012-13) (Physical Court Hearing) Dixaben Jayeshbhai Patel, Vs. The Ito, Ward-2, Plot No.42, Krishna Colony, Vapi. Muktanand Marg, Chala, Vapi, Gujarat – 396191. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahspp3273F (Revenue)/(Appellant) (Assessee)/(Respondent) Assessee By Shri Sapnesh Sheth, Ca Respondent By Shri Vinod Kumar, Sr. Dr Date Of Hearing 02/02/2023 10/02/2023 Date Of Pronouncement

transferred to on account of Panji branch and they are also withdrawn in cash by different individuals. Since the use of funds is not ascertainable and majority of transactions are cash withdrawals over the period in crores of rupees i.e. total cash withdrawals from both accounts in 8 months is to the tune of Rs.9.75 crores. Therefore, we are reporting

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-2, SURAT vs. SHRI SHANKAR MULCHAND UTTAMANI, SURAT

In the result, appeals filed by the Revenue ( in ITA nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

seizure action carried out by the Department as dumb documents without appreciating the fact that the same carries a solid and complete evidentiary value and the person from whom the same was found and seized has admitted that it was found from his possession in the statement recorded on oath and the contents therein were also clearly explained

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIR.,2, SURAT vs. SHRI PRAVINCHANDRA DAHYABHAI UMRIGER, SURAT

In the result, appeals filed by the Revenue ( in ITA nos

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.134 To 137/Srt/2021 ("नधा"रणवष" / Assessment Year: (2017-18) (Virtual Court Hearing) The Dcit, Central Circle-2, Vs. Shri Pravinchandra Dahyabhai Umriger, Surat. Bungalow No.01, Opp. Talao Street, Near Govindji Park, Umra, Surat-395007(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabpu5216D The Dcit, Central Circle-2, Vs. Shri Vasantrai Ambaram Modi, Surat. 504, D/1, Subham Residency, Pal, Surat- 395005. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrpm0852D The Dcit, Central Circle-2, Vs. Shri Shankar Mulchand Uttamani, Surat. 1/3210-11, New Textile Market, Ring Road, Surat-395002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahpu9028R The Dcit, Central Circle-2, Vs. Shri Prabodhchandra Jayantilal Patel, Surat. 297, Hari Narar-3, Opp. Brc Gate, Udhna, Surat-394210. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afvpp7466F (Assessee) (Respondent) Assessee By: Shri Rasesh Shah, Ca Revenue By: Shri Ritesh Mishra, Cit(Dr) सुनवाईक"तार"ख/ Date Of Hearing : 02/03/2022 घोषणाक"तार"ख/Date Of Pronouncement : 10/05/2022 आदेश / O R D E R Per Dr. A. L. Saini: Captioned Four Appeals Filed By The Revenue, Pertaining To Assessment Year (Ay) 2017-18, Are Directed Against The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), Which In Turn Arise Out Of Separate Assessment Orders Passed By The Assessing Officer Under Section 143(3) Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

seizure action carried out by the Department as dumb documents without appreciating the fact that the same carries a solid and complete evidentiary value and the person from whom the same was found and seized has admitted that it was found from his possession in the statement recorded on oath and the contents therein were also clearly explained