M/S. MITSU PRIVATE LIMITED,,VAPI vs. THE ACIT, VAPI CIRCLE,, VAPI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

transfer are treated as revenue receipts and treated as business income. Therefore, the action of the AO is merely based on presumption basis. Hence, we do not find any infirmity in the order of CIT (A), accordingly, same is upheld. This ground of appeal is therefore, dismissed. 73. Ground No. 4 states that the ld. CIT (A) has erred

BHARATKUMAR RANCHODBHAI SONI,NA vs. ARIVS.PCIT, VALSAD

In the result, the appeal of the assessee is allowed

108\n(Bom) and a plethora of decisions where the Hon'ble Courts have allowed relief\nto the assessee on similar facts. Accordingly, it was requested not to invoke\nprovisions of section 263 of the Act.\n4.\nThe Id. PCIT considered the submission of the assessee and held that the\norder passed by the AO on 30.12.2019 was without making

KANUBHAI VANMALIBHAI PATEL HUF,SURAT vs. ITO, WARD-1(2)(1), SURAT, SURAT

In the result, the grounds of appeal raised by the assessee is allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) Kanubhai Vanmalibhai Patel I.T.O.,Ward 1(2)(1), Huf,6, Siddharth Society, Surat. Vs. Behind Afil Tower, Lambe Hanuman Road, Surat-395010. Pan: Aakhp 0725 K Appellant Respondednt

price. The land in question was also sold after converting into non-agriculture land for commercial use. It was held that the assessee never seems to have held the property for personal use, possession or enjoyment. The ld PCIT ultimately held that no enquiry was made by the Assessing Officer with respect to sale of land transaction being

ENGINEERING PROFESSIONAL CO. PVT LTD,SURAT vs. PCIT-1, SURAT

In the result, appeal of the assessee is partly allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.541/Srt/2024 Assessment Year: (2018-19) (Physical Hearing) Engineering Professional Co. Pvt. Ltd., Vs. The Pcit -1, 444, Royal Arcade, Opp. Sarthana Zoo, Surat Varachha Road, Near Sarthana Jakatnaka, Surat – 395006, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabce0313Q (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Ravi Kant Gupta, Cit(Dr) Date Of Hearing 13/02/2025 Date Of Pronouncement 19/02/2025

108,318 11 Jitubhai Kathiriya (TDS Deducted) EHAPK1 1 HE 317,172 12 Koes Construction (TDS Deducted) BANPK9072K 36,800 13 Mangukiya Brothers Project Pvt Ltd AALCM5099B 5,492,000 (TDS Deducted) 14 Mehulbhai Jaysukhbhai Vekariya (CR) AWZPV5715A 123,000 (TDS Deducted) 15 Nitin R Bhavani (TDS Deducted) AQHPB2009D 5,113,964 16 NR EPC Project Private Limited (TDS AAFCN2999F

SHRIFAL IMPEX PRIVATE LIMITED,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)

price received by the seller of the goods for the acquisition of which M has already incurred the cost. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales.” d) CTT vs. Balchand Ajit Kumar 135 Taxman 180 (High Court - MP) ITA Nos. 190 - 191 &250/SRT/2023 Shrifal

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)

price received by the seller of the goods for the acquisition of which M has already incurred the cost. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales.” d) CTT vs. Balchand Ajit Kumar 135 Taxman 180 (High Court - MP) ITA Nos. 190 - 191 &250/SRT/2023 Shrifal

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)

price received by the seller of the goods for the acquisition of which M has already incurred the cost. It is the realisation of excess over the cost incurred that only forms part of the profit included in the consideration of sales.” d) CTT vs. Balchand Ajit Kumar 135 Taxman 180 (High Court - MP) ITA Nos. 190 - 191 &250/SRT/2023 Shrifal

GIRDHARBHAI HARIBHAI GAJERA,SURAT vs. ITO(INTERNATIONAL TAXATION), SURAT

In the result, additional grounds raised by the assessee is allowed

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.143/Srt/2019 (िनधा"रणवष" / Assessment Year: (2015-16) (Physical Court Hearing) Girdharbhai Haribhai Gajera Income Tax Officer 1,Vrushal Nagar, Opp. (International Taxation), 107, 1St Vs. Ktargam Police Station, Floor, Anavil Business Centre, Katargam Road, Surat-35004 Adajan-Hazira Road, Opp. Star Bazar, Adajan, Surat-395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abepg 7339 M (Assessee ) (Respondent)

price of land, but merely because of those steps, it cannot be held that the assessee is dealing in land estate business. The land in question was never treated as a stock-in-trade but it was treated as capital asset on which wealth-tax was paid. All the circumstances and evidences thus demonstrated the purpose of purchase of land

BALUBHAI BRIJBHUKHANDAS CHOKSI,NA vs. ARIVS.PRINCIPAL COMMISSIONER OF INCOME TAXVALSAD, VALSAD

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.119/Srt/2022 ("नधा"रणवष" / Assessment Year: (2017-18) (Physical Court Hearing) Balubhai Brijbhukhandas Principal Commissioner Of Income- Tax-Valsad, Room No. 301, 3Rd Floor, Choksi, Mota Bazar, Vs. Navsari-396445 Income Tax Office, Palak Arcade, Pali Hill, Santinagar, Tithal Road, Valsad-396001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaifb 9804 B (अपीलाथ" /Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Assessee By : Shri Hiren M. Diwan, C.A राज"व क" ओर से /Respondent By: Shri Ravinder Sindhu, Cit-D.R

transfer. It is noted that assessee is a firm and the firm has accepted depositing Rs.12,50,000/- towards PMGKS 2016. However, the source of this amount has not been routed through the P & L account. How the taxes have been paid and accounted for and whether the balance amount has been taken to balance sheet is also not clear

M/S. C. J. GROUP & GAJRAS BUILDERS & DEVELOPERS,PANVEL, MUMBAI vs. DCIT, CIRCLE-1, BHARUCH, BHARUCH

In the result, this ground of appeal is also dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.02/Srt/2021 (Ay 2011-12) (Hearing In Physical Court) M/S C.J. Group & Gajras Deputy Commissioner Of Income Tax, Circle-1, Builders & Developers, Vs Bharuch Bhoomi Land Mark, Plot No. 30-30A, Sector-17, Khan Colony, Panvel-410206, Maharashtra Pan No. Aagfc 4658 J अपीलाथ"/Appellant ""यथ" /Respondent

section 143(3) of Income Tax Act, 1961 (hereinafter referred to as ‘the Act’ for the sake of brevity) on 24.03.2014. M/s C J Group & Gajras Builders & Developers 2. On perusal of record shows that impugned order was passed by Ld. CIT(A) on 24.08.2020, however, assessee has filed present appeal on 05.01.2021. Thus, there is delay of 65 days

JITENDRAKUMAR AMBELAL PATEL,NA vs. ARIVS.ITO, WARD-3, NAVSARI

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

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2009-2010 Jitendrakumarambelal Patel Ito, Ward-3, 52, Kanbiwad. At & Po-Pananj, Room No. 108, Swapnalok Soc., Tal-Chikhli, Navsari-396521 Vs. Near Kaliawadi Bridge, Navsari - 396521 Pan No. Bncpp 7509 R Appellant Respondent

108, Swapnalok Soc., Tal-Chikhli, Navsari-396521 Vs. Near Kaliawadi Bridge, Navsari - 396521 PAN NO. BNCPP 7509 R Appellant Respondent : Shri P M Jagasheth, CA Assessee by : Shri J. K. Chandnani, Sr. DR Revenue by : 08/10/2025 Date of Hearing : 30/10/2025 Date of pronouncement ORDER PER OM PRAKASH KANT, AM This appeal by the assessee is directed against order dated

ACIT, CENTRAL CIRCLE-3, SURAT, SURAT vs. NOBAL JEWELS PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2, SURAT, SURAT vs. TANMAN JEWELS PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-3, SURAT, SURAT vs. ANTIQUE EXIM PVT. LTD., SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

ANTIQUE EXIM PVT. LTD, SURAT,SURAT vs. ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-3, SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

SAFFRON GEMS PVT LTD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

TANMAN JEWELS PVT LTD,SURAT vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing

NOBAL JEWELS PVT LTD ,SURAT vs. ASST COMMISSIONER OF INCOME TAX, SURAT

In the result, appeals filed by the Assessee in ITA Nos

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble(Physical Hearing) Sl.

priced in the range of US$ 424 to 2368 per carat. On page 2 and 3 of the assessment order, the AO has given the exact details of the imports with import bills, dates of imports and how the imports were overvalued. During the investigation, it was observed that the appellant routed the transactions through various shell companies for routing