RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

transfer or receive any specified bank note”. We therefore, find that the specified bank notes can be measured in monetary terms since the guarantee of the Central Government and the liability of Reserve Bank of India does not cease to exist till31.12.2016. In view of the above, the contention of the Ld. DR, treating the receipt of SBNS from cash

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, DAMAN WARD, DAMAN

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita Nos.193 To 195/Srt/2022 Assessment Years: (2015-16 To 2017-18) (Physical Hearing) Ravi Mahexa, Vs. Income Tax Officer, Ward-5, 7Th 14/55, Dilipnagar Near Dilip Nagar Vapi, Fortune Square, Floor, 8Th Floor & 9Th Floor, Ii, Ground, Daman, Daman – 396210, Daman & Diu (Ut) Chala Road, Vapi-396191 Ravi Mahexa Income Tax Officer, Daman 14/55, Dilipnagar Near Dilip Nagar Ward, Daman Jevanji Ground, Daman, Daman & Diu (Ut) - Apartment, Kavi Khabardar 396210 Road, Daman-396210 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Apkpm1888H (Assessee) (Respondent) Assessee By Shri P. M. Jagasheth, Ca Respondent By Shri Minal Kamble, Sr. Dr Date Of Hearing 19/07/2023 Date Of Pronouncement 31/07/2023

transfer or receive any specified bank note”. We therefore, find that the specified bank notes can be measured in monetary terms since the guarantee of the Central Government and the liability of Reserve Bank of India does not cease to exist till31.12.2016. In view of the above, the contention of the Ld. DR, treating the receipt of SBNS from cash

DEVNGI JEWELLWERS PVT. LTD.,SURAT vs. DCIT, CIRCLE-1(1)(1), SURAT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Pruseth, Accountant Mmber आयकरअपीलसं./Ita No.672/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Devngi Jewellers Pvt. Ltd. Vs. Dcit, 109 -110, Shreyas Diamond Centre, Circle – 1(1)(1), Mini Bazar, Varachha Road, Surat Surat - 395006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabcd3227A (Appellant) (Respondent) Appellant By Shri Sapnesh R. Sheth, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 31/07/2025 Date Of Pronouncement 13/08/2025

price received by the appellant for sale of jewellery, for the acquisition of which the appellant has already incurred the cost, so, it is excess of realization over the cost incurred only forms part of profit and which has already been offered by the appellant. 5. On the facts and circumstances of the case as well

SHRI MUKESH N. DESAI,,SURAT vs. THE DY.CIT, CIRCLE-2,, SURAT

In the result, the appeal of the assessee is partly allowed

Bench: Shri Ram Lal Negi & Shri O. P. Meena

unexplained cash credit in bank account for which the AO has made separate addition as discussed in Ground No. 3 to 5. The CIT (A) further observed that the stamp duty valuation at Rs.1,25,45,520/- was reduced to Rs. 85,54,520/- in appeal, hence, it was not determined in routine manner. Hence, addition made

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

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

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

ACIT, CC-3, SURAT vs. SHRI NARESH NEMCHAND SHAH, SURAT

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.197/Srt/2020 ("नधा"रणवष" / Assessment Years: (2012-13) (Physical Court Hearing) The Acit, Central Cir.-3, Vs. Naresh Nemchand Shah, Surat. Abhishek House, Bh. Jeevan Bharti School, Kadampali Society, Nanpura, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acrps 0182 J (Assessee)/(Revenue) (Respondent)/(Assessee)

unexplained cash credit only on the basis of presumptions. There is no evidence contrary to the evidence of the purchase and sale of shares and the transactions as disclosed by the assesee. Assessments cannot be done on the basis of presumptions. A perusal of the order of CIT(A) clearly shows that the Ld. CIT(A) has followed the decision

KIRTIPRADA FASHIONS PVT. LTD.,SURAT vs. ITO, WARD -1(1)(3), SURAT

In the result, appeal of the assessee is allowed

unexplained cash credit, hence she prayed the Bench that addition made by the assessing officer may be sustained. 7. We have heard both the parties and carefully gone through the submission put forth on behalf of the assessee along with the documents furnished and the case laws relied upon, and perused the fact of the case including the findings

RAMBILASH RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WARD-2(2)(4), SURAT

In the result, assessee's appeal is allowed

cash credit u/s 68 of the I.T. Act,1961 without\nacknowledging the submission of the assessee.\n4. On the facts and circumstances of the case as well as law on the\nsubject, the learned CIT(A) has erred in confirming action of Assessing\nOffice in making addition of Rs.3,406/- as unexplained expenditure u/s\n69C

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

unexplained cash credit to be taxed u/s 68 of the IT Act 1961. We find the Ld. CIT(A) upheld the action of the Assessing Officer, the reasons of which 20 are already reproduced in the preceding paragraph. It is the submission of Ld. Counsel for the assessee that the assessee has invested an amount of Rs. 20 lacs through

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

unexplained cash credit to be taxed u/s 68 of the IT Act 1961. We find the Ld. CIT(A) upheld the action of the Assessing Officer, the reasons of which 20 are already reproduced in the preceding paragraph. It is the submission of Ld. Counsel for the assessee that the assessee has invested an amount of Rs. 20 lacs through

SUNITA JAJOO,SURAT vs. ITO WARD 2(2)(4), SURAT

In the result, assessee’s appeal is allowed

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No. 552/Srt/2024 (Ay 2011-12) (Physical Court Hearing) Rambilash Rajaram Jajoo Income Tax Officer, Ward- 429-432, Golden Point, Falsawadi, 2(2)(4), Aaykar Bhawan, Majura बनाम Ring Road, Surat City, Gate, Opp. New Civil Hospital, Vs Surat-395 002 Surat-395 001 [Pan : Aampj 0040 K] अपीलाथ"/Appellant ""थ" /Respondent

cash credit u/s 68 of the I.T. Act,1961 without acknowledging the submission of the assessee. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming action of Assessing Office in making addition of Rs.3,406/- as unexplained expenditure

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)

transfer forms were not pertaining to the year under appeal. Addition of Rs. 48,83,483/- (Ground No 2) Facts:- 4. An addition of Rs. 48,83,483/- on account of unexplained investment by the assessee in the project called “La-Grand “ was made in the case of the assessee. Similar addition was also made in the case of Rameshbhai

NEELU MAHANSARIA,SURAT vs. INCOME TAX OFFICER, WARD - 1(3)(3), SURAT

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

Bench: Shri Pawan Singhआ.अ.सं./Ita No.197/Srt/2023 (Ay 2011-12) (Hearing In Physical Court) Neelu Mahansaria Income Tax Officer, 304, Green Park Apartment, Ward-1(3)(3), Surat Vs City Light Road, Nr. Corner Point Complex, Surat-395007 Pan No: Adbpm 2707 Q अपीलाथ"/Appellant ""थ" /Respondent

unexplained cash credit. I further find that Hon'ble jurisdictional High Court in the case of Parasben Kasturchand Kochar (supra) also held that when assessee discharged his onus by establishing that transactions were fair and transparent and all relevant details with regard to transfer furnished by Income Tax Authority and the Tribunal have also took the notice of fact that

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

cash Credit. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming Rs.10,426/- as unexplained u/s 69 of the Act. 5. It is therefore prayed that addition made by the assessing officer and confirmed by CIT(A) of Rs.3,57,990/- may please be deleted

JASODADEVI RAJARAM JAJOO,SURAT vs. INCOME TAX OFFICER WD.-2(2)(2), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

cash Credit. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming Rs.10,426/- as unexplained u/s 69 of the Act. 5. It is therefore prayed that addition made by the assessing officer and confirmed by CIT(A) of Rs.3,57,990/- may please be deleted

DAMODAR JAJOO,SURAT vs. INCOME TAX OFFICER, WD.2(2)(1), SURAT

In the result, appeal filed by the assessee (in ITA No

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकरअपीलसं./Ita Nos.183 To 184/Srt/2021 ("नधा"रणवष" / Assessment Years: (2011-12) (Physical Court Hearing) Damodar Jajoo, Vs. The Ito, Ward-2(2)(1), 429-432, Golden Point, Nr. Bsnl Surat. Office, Falsawadi, Ring Road, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawpj4341H (Assessee) (Respondent) आयकरअपीलसं./Ita No.185/Srt/2021 ("नधा"रणवष" / Assessment Year: (2012-13) Jasodadevi Rajaram Jajoo, Vs. The Ito, Ward-2(2)(2), 429-432, Golden Point, Ring Surat. Road, Falsawadi, Begampura, Surat-395002, Gujarat. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaqpj7257E (Assessee) (Respondent) Assessee By Ms Richa Tosniwal, Ca & Shri Harishankar Tosniwal, Ca Shri J. K. Chandnani, Sr. Dr Respondent By Date Of Hearing 21/11/2022 Date Of Pronouncement 09/12/2022

cash Credit. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming Rs.10,426/- as unexplained u/s 69 of the Act. 5. It is therefore prayed that addition made by the assessing officer and confirmed by CIT(A) of Rs.3,57,990/- may please be deleted

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

unexplained cash credit. I further find that Hon'ble jurisdictional High Court in the case of Parasben Kasturchand Kochar (supra) also held that when assessee discharged his onus by establishing that transactions were fair and transparent and all relevant details with regard to transfer furnished by Income Tax Authority and the Tribunal have also took the notice of fact that