BILAKHIA HOLDINGS PVT. LTD.,,VAPI vs. THE ADDL.CIT.,VAPI RANGE,, VAPI

In the result, the appeal of the assessee is allowed for assessment year 2010-11

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.507/Ahd/2013: िनधा"रण वष"/Assessment Year: 2008-09 आ.अ.सं/.I.T.A.No.1415Ahd/2015: िनधा"रण वष"/Assessment Year: 2009-10 आ.अ.सं/.I.T.A No.1416/Ahd/2015:िनधा"रण वष"/Assessment Year: 2010-11 आ.अ.सं/.I.T.A No.795/Ahd/2016: िनधा"रण वष"/Assessment Year: 2011-12 M/S. Bialkhia Holdings Pvt. Vs. Addl.Cit Range - Vapi / Ltd., Bilakhia House, Assistant Commissioner Of Muktanand Marg, Chala Income Tax Vapi Circle Vapi, Vapi, Gujarat. Shivam Commercial Complex, [Pan: Aadcs 4420 J] National Highway No.8, Vapi. अपीलाथ" Appellant ""यथ"/Respondent

transfer pricing regulations, cannot be compared with a transaction which is something materially different than a loan simplictor, for example, a non- refundable loan which is to be converted into equity. It is in this context that the loans, which are in the nature of quasi capital, are treated differently than the normal loan transactions. 9. The expression 'quasi capital

BILAKHIA HOLDING P LTD,VAPI vs. THE JT.CIT.,VAPI RANGE,, VAPI

In the result, the appeal of the assessee is allowed for assessment year 2010-11

Bench: Shri Sandeep Gosain & Shri O.P.Meena, Accoutant Member आ.अ.सं/.I.T.A No.507/Ahd/2013: िनधा"रण वष"/Assessment Year: 2008-09 आ.अ.सं/.I.T.A.No.1415Ahd/2015: िनधा"रण वष"/Assessment Year: 2009-10 आ.अ.सं/.I.T.A No.1416/Ahd/2015:िनधा"रण वष"/Assessment Year: 2010-11 आ.अ.सं/.I.T.A No.795/Ahd/2016: िनधा"रण वष"/Assessment Year: 2011-12 M/S. Bialkhia Holdings Pvt. Vs. Addl.Cit Range - Vapi / Ltd., Bilakhia House, Assistant Commissioner Of Muktanand Marg, Chala Income Tax Vapi Circle Vapi, Vapi, Gujarat. Shivam Commercial Complex, [Pan: Aadcs 4420 J] National Highway No.8, Vapi. अपीलाथ" Appellant ""यथ"/Respondent

transfer pricing regulations, cannot be compared with a transaction which is something materially different than a loan simplictor, for example, a non- refundable loan which is to be converted into equity. It is in this context that the loans, which are in the nature of quasi capital, are treated differently than the normal loan transactions. 9. The expression 'quasi capital

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

254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of ld. Principal Commissioner of Income-tax-Valsad [for short to as “Ld. PCIT”] passed under section 263 of Income Tax Act, 1961 (hereinafter referred to as ‘the Act’ for the sake of brevity) dated 30.03.2022 for assessment year

SHREE NARMADA KHAND UDYOG SAHKARI MANDALI LTD.,NARMADA vs. INCOME TAX OFFICER, WARD - 2(1), BHARUCH

In the result, the grounds of appeal raised by the assesse are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price made on the last day of the accounting year is allowable under section 28 of the Act being a necessary deduction for ascertaining the real profits on principles of commercial accounting and the payment in question is alternatively allowable under section 37 of the Act having been incurred wholly and exclusively for the purpose of business carried

SHREE NARMADA KHAND UDYOG SAHKARI MANDALI LTD.,NARMADA vs. INCOME TAX OFFICER, WARD - 2(1), BHARUCH

In the result, the grounds of appeal raised by the assesse are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price made on the last day of the accounting year is allowable under section 28 of the Act being a necessary deduction for ascertaining the real profits on principles of commercial accounting and the payment in question is alternatively allowable under section 37 of the Act having been incurred wholly and exclusively for the purpose of business carried

SHREE NARMADA KHAND UDYOG SAHKARI MANDALI LTD.,NARMADA vs. INCOME TAX OFFICER, WARD - 2(1), BHARUCH

In the result, the grounds of appeal raised by the assesse are allowed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price made on the last day of the accounting year is allowable under section 28 of the Act being a necessary deduction for ascertaining the real profits on principles of commercial accounting and the payment in question is alternatively allowable under section 37 of the Act having been incurred wholly and exclusively for the purpose of business carried

SHREE KHEDUT SAHAKARI KHAND UDYOG MANDLI LTD.,BARDOLI vs. INCOME TAX OFFICER, WARD-1, BARDOLI

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

254 of the Act which is the subject matter of appeal by the assessee.\n5.\nAll the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by the Revenue is directed against the order of learned Commissioner of Income Tax (Appeals)-1, Surat (in short, the ld. CIT(A)) dated 26/11/2019 for the Assessment Year (AY) 2008-09. The Revenue has raised following grounds of appeal: “(i) On the facts

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

254 of the Act which is the subject matter of appeal by the assessee.\n5. All the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254 of the Act which is the subject matter of appeal by the assessee.\n5.\nAll the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254 of the Act which is the subject matter of appeal by the assessee.\n5.\nAll the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254 of the Act which is the subject matter of appeal by the assessee.\n5. All the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254 of the Act which is the subject matter of appeal by the assessee.\n5. All the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

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

254 of the Act which is the subject matter of appeal by the assessee.\n5.\nAll the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

SHRI RAJU MAGANLAL PATEL,VALSAD vs. INCOME TAX OFFICER, INT. TAXATION, SURAT, SURAT

In the result, the appeal of assessee is allowed

Bench: Shri Pawan Singh(Virtual Hearing) Raju Maganlal Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Auspp 1436 F Appellant/ Assessee Respondent/ Revenue Tara Raju Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Avdpp 6714 G Appellant/ Assessee Respondent/ Revenue

254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. These two appeals by the two different assessee(s) are directed against the separate orders of learned Commissioner of Income Tax (Appeals)- 13, Ahmedabad (in short, the ld. CIT(A)) both dated 23/01/2023 for the Assessment Year (AY) 2011-12 and 2012-13 respectively. In both these appeals

TARA RAJU PATEL,VALSAD vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION, , SURAT

In the result, the appeal of assessee is allowed

Bench: Shri Pawan Singh(Virtual Hearing) Raju Maganlal Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Auspp 1436 F Appellant/ Assessee Respondent/ Revenue Tara Raju Patel, I.T.O. C/O-Dinkarbhai T. Patel, Shankar (International Taxation), Vs. Talao, Via-Dungri, Valsad. Surat. Pan No. Avdpp 6714 G Appellant/ Assessee Respondent/ Revenue

254(1) of Income Tax Act PER: PAWAN SINGH, JUDICIAL MEMBER: 1. These two appeals by the two different assessee(s) are directed against the separate orders of learned Commissioner of Income Tax (Appeals)- 13, Ahmedabad (in short, the ld. CIT(A)) both dated 23/01/2023 for the Assessment Year (AY) 2011-12 and 2012-13 respectively. In both these appeals

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

254 of the Act which is the subject matter of appeal by the assessee.\n5. All the grounds raised by the assessee, though numerous and\narticulated from different legal and factual perspectives, cumulatively\nrevolve around a single core dispute, namely the allowability of the FCP/\nadditional sugarcane price paid over and above the FRP to cane growers\nand farmer-members

UMESH P. MAHANSARIA (HUF),SURAT vs. DY. COMMR. OF INCOME TAX, CIRCLE- 1(3), SURAT, SURAT

In the result, the addition of undisclosed income under section 68 is deleted

Bench: Shri Pawan Singh & Shri Bhagirath Mal Biyaniआयकर अपील सं./Ita No. 151/Srt/2024 (Ay 2015-16) (Hybrid Hearing) Umesh P. Mahansaria (Huf) Deputy Commissioner Of Income- C-501, The Legend, Vastu Gram, Tax, Circle-1(3), Surat, बनाम Vesu, Surat-395 007 Aaykar Bhavan, Anavil Building, Vs [Pan : Aaahu 6298 L] Adajan, Surat-395 009 अपीलाथ"/Appellant ""थ" /Respondent

254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER: 1. This appeal by assessee is directed against the order of National Faceless Appeal Centre, Delhi/Commissioner of Income tax (Appeals) [for short to as “NFAC/Ld.CIT(A)] dated 28.12.2023 for assessment year (AY) 2015-16, which in turn arises out of assessment order passed by Assessing Officer under section