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

SAHAKARI KHAND UDUOG MANDAL LTD.,NA vs. ARIVS.DCIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD.,, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,.,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, , NAVSARI

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

SAHAKARI KHAND UDYOG MANDAL LTD.,,GANDEVI vs. ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

SAHADARI KHAND UDYOG MANDAL LTD.,,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG, KAND UDYOG SAHAKARI MANDALI LTD., NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

ACIT, NA vs. ARI CIRCLE., NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,, NAVASARI

172 taxmann.com 467\n(Guj.), dated 11.02.2025, affirming the Tribunal is entirely misplaced and\nfact-specific. He pointed out that in Narmada Khand (supra), the Tribunal\nhad recorded specific findings of fact that the additional cane price had\nbeen approved by the Managing Committee which included Government\nrepresentatives under the Co-operative law, and that such price was, on\nfacts

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

price. There is presumption under Section 292C about the documents seized during the search from the control and ownership of co-owner that said document belonged to assessee and his co-owner. During the search action, Pitamberbhai Ruchandani stated that writing on the seized material may be in the handwriting of his brother Arjundan Ruchandani, who was no more. During

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

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 27,818,478 Deducted) 17 Prakash Patel (TDS Deducted) CTGPP720SK

ARUN KUMAR GUPTA, DCIT, CIRCLE-1(3), SURAT, ADAJAN vs. CHUNIBHAI HARIBHAI GAJERA, ADARSH NAGAR SOCIETY

In the result, the appeal of the revenue is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.778 & 779/Srt/2023 Assessment Years: (2013-14 & 2014-15) (Physical Hearing) Dcit, Vs. Chunibhai Haribhai Gajera, Circle - 1(3), 67, Adarsh Nagar Society, Athwalines, Surat Surat - 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawpg3525A (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mukesh Jain, Cit-Dr Respondent By Shri Rasesh Shah, Ca Date Of Hearing 03/09/2025 Date Of Pronouncement 17/11/2025

172 taxmann.com 572 (SC), (iv) PCIT vs. Divyaben Prafulchandra Parmar (supra) and (v) PCIT vs. Muktaben Nishantbhai Patel, Tax Appeal No.294 of 2021 (Guj.). The ld. AR also submitted that the impugned scrip of Kyra Landscape Ltd. is not in the list of 84 shares investigated by the Investigation Wing of Kolkata. Hence, the investigation report relied upon

ARUN KUMAR GUPTA, DCIT, CIRCLE-1(3), SURAT, ADAJAN vs. CHUNIBHAI HARIBHAI GAJERA, ADARSH NAGAR SOCIETY

In the result, the appeal of the revenue is dismissed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.778 & 779/Srt/2023 Assessment Years: (2013-14 & 2014-15) (Physical Hearing) Dcit, Vs. Chunibhai Haribhai Gajera, Circle - 1(3), 67, Adarsh Nagar Society, Athwalines, Surat Surat - 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawpg3525A (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mukesh Jain, Cit-Dr Respondent By Shri Rasesh Shah, Ca Date Of Hearing 03/09/2025 Date Of Pronouncement 17/11/2025

172 taxmann.com 572 (SC), (iv) PCIT vs. Divyaben Prafulchandra Parmar (supra) and (v) PCIT vs. Muktaben Nishantbhai Patel, Tax Appeal No.294 of 2021 (Guj.). The ld. AR also submitted that the impugned scrip of Kyra Landscape Ltd. is not in the list of 84 shares investigated by the Investigation Wing of Kolkata. Hence, the investigation report relied upon