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.

transferred the equity shares of Survika Vinimay Pvt Ltd, which were purchased at a premium of Rs.187/- to Directors and group companies of Sumeet Group namely Betex India Ltd and Ambaji Syntex Pvt. Ltd. at Rs.10/- which was the face value of shares of Survika Vinimay Pvt. Ltd. By this Sumeet Group companies and its directors have got control over

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.

transferred the equity shares of Survika Vinimay Pvt Ltd, which were purchased at a premium of Rs.187/- to Directors and group companies of Sumeet Group namely Betex India Ltd and Ambaji Syntex Pvt. Ltd. at Rs.10/- which was the face value of shares of Survika Vinimay Pvt. Ltd. By this Sumeet Group companies and its directors have got control over

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.

transferred the equity shares of Survika Vinimay Pvt Ltd, which were purchased at a premium of Rs.187/- to Directors and group companies of Sumeet Group namely Betex India Ltd and Ambaji Syntex Pvt. Ltd. at Rs.10/- which was the face value of shares of Survika Vinimay Pvt. Ltd. By this Sumeet Group companies and its directors have got control over

HUBERGROUP INDIA PRIVATE LIMITED,VAPI vs. PR. COMMISSIONER OF INCOME TAX, VALSAD

In the result, appeal of the assessee is dismissed

Bench: Shri Pawan Singh & Dr Arjun Lal Sainiआ.अ.सं./Ita No.133/Srt/2022 (Ay 2018-19) (Hearing In Virtual Court) Hubergroup India Pvt. Ltd. Principal Commissioner Of Plot No.808/E, Phase-Ii, Income Tax, Valsad, Room Vs Gidc, Vapi-396195 No.301, 3Rd Floor, Income Tax Pan No. Aaach 7063 F Office, Palak Arcade, Pali Hill, Santi Nagar, Tithal Road, Valsad-396001 ""थ" /Respondent अपीलाथ"/Appellant

153(4) prescribed that where a reference under sub-section (1) of section 92CA is made during the 13 Hubergroup India Pvt. Ltd. course of assessment proceedings, the period available for completion of assessment under sub-clause (1), (2)(3) shall be extended by twelve months only. Therefore, to avail the extended period of completion the reference to TPO shall

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

153 A of the Act, it being the search year and not covered in the six year to the year of search as as per the assessment scheme/procedure defined u/s section 153A; that the AO has passed regular assessment u/s 143 (3) of the Act; although the ld CIT has mentioned the section as 143 r.w.s. 153A and that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, SURAT, SURAT vs. SAFFRON GEMS 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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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.

section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as the “Act”]. 2. Since, the issue 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 and brevity. The grounds as well as facts narrated

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

section 40A(2)(b) of Rs.5,912 without appreciating that payment made to related party for purchase of material was excessive as compared to other party. 150. We have heard the rival submissions and perused the relevant material on record. We find that the CIT (A) has deleted this ground by observing that the assessee has purchased the material

THE ASSTT. COMMISSIONER OF INCOME TAX, VAPI CIRCLE,, VAPI vs. M/S. MITSU LIMITED,, DAMAN

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

section 40A(2)(b) of Rs.5,912 without appreciating that payment made to related party for purchase of material was excessive as compared to other party. 150. We have heard the rival submissions and perused the relevant material on record. We find that the CIT (A) has deleted this ground by observing that the assessee has purchased the material

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR.-2,, SURAT vs. SHRI RAMESHBHAI RAGHAVBHAI BHADANI, SURAT

In the result, summarized and concise ground No

Bench: Shri Pawan Singh, Jm & Dr. A.L. Saini, Am आयकरअपीलसं./It(Ss)A Nos.25 &31/Srt/2021 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Deputy Commissioner Of Rameshbhai Raghavbhai Bhadani, Prop. Of M/S Rangeela Fashion, 14, Income-Tax, Central Circle-2, Room No. 505, 5Th Floor, Nirman Industrial Estate, A.K. Road, Fulpada, Surat Aaykar Bhawan, Majura Gate, Vs. Surat-395001. Deputy Commissioner Of Income- Rameshbai Raghavhai Bhadani Plot No.14-16, Nirman Tax, Central Circle-2, Room No.505, 5Th Floor, Aaykar Bhawan, Majura Industrial Estate, A./K. Road, Surat-395008 Gate, Surat-395001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.45/Srt/2021 ("नधा"रणवष" / Assessment Year: (2014-15) Deputy Commissioner Of Shri Rameshbhai Raghavbhai Income-Tax, Circle-3, Room No. Bhadani, Prop. Of M/S Rangeela Vs. 505, 5Th Floor, Aaykar Bhawan, Fashion, 14, Nirman Industrial Majura Gate, Surat-395001. Estate, A.K. Road, Fulpada, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Adkpb 0556 F (Assessee) (Respondent)

Section 153. 6. The reliance is placed on the following case laws of courts.  CIT vs. Uttarakhand Van Vikas Nigam [66 taxmann.com 87 (Utt. HC)  Rural Electrification Corporation Ltd. Vs. CIT [34 taxmann.com 197 (Del. HC) IT(SS)A Nos.25, 31, 45, 26 & 30/SRT/2021 A.Ys.13-14 & 14-15 Rameshbhai R Bhadani & Jayeshkumar D Mistry  A.B. Parikh

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. 7. Without prejudice to and in addition to the grounds No. 1 to 6 on the facts and in the 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

DEPUTY COMMISSIONER OF INCOME-TAX,CENTRAL CIRCLE-1, SURAT, AAYAKAR BHAWAN, MAJURA GATE, SURAT vs. ROYAL DEVELOPERS, NR. IP MISSION SCHOOL, MUGLISA

In the result, the appeal of the Revenue is allowed for statistical purposes

price mentioned in the purchase documents and, therefore, there no reason to interfere with the order of the CIT(A). The copy of the Order is enclosed herewith at Pg # 147-154 of PB. Considering the above facts of the matter, the addition made u/s 69 considering the payment of Land Purchase as made during the year is erroneous

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1)(1), SURAT vs. M/S. LEMON TECHNOMIST PVT. LTD., SURAT

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

153 65,17,96,563 income Mfg. and Operational 2,57,26,449 2,47,95,784 Expenses Another discrepancy, that the assessing officer found in the books of the assessee company was that, in previous year related to AY 2013-14 there is a sizeable margin in sales and cost of material sold (Sales - Cost of Material - Increase/Decrease