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

unexplained investment in the land in excess of the 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

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

unexplained investment. 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as 3. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income law on the subject, the learned Commissioner of Income law on the subject

RAJESH PODDAR,SURAT vs. ACIT CENTRAL CIRCLE-4, SURAT

In the result, assessee's appeal is dismissed

transfer the subject land. The AO also noted that the said\nland has been purchased by the assessee and Shri Kedar Jagirdar from Smt.\nParulben Patel and others, therefore, facts written in this letter of undertaking\nare true and relevant to the transaction of purchase of land. Before the AO, the\nassessee contended that this document is a mere draft

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 4, SURAT vs. KISHORKUMAR DHIRAJLAL KATHROTIYA, SURAT

In the result, the appeal of the revenue is dismissed

unexplained cash credit and addition of\nRs.22,82,312/- on account of non-genuine interest expense thereon. The assessee\nhad accepted the addition made by the AO by paying the taxes under the IDS-2016\nout of total disclosure of Rs.1,50,000/-, Rs.50,00,000/- pertains to AY 2015-16. Thus,\nthe assessment made

THE DCIT, CENT, CIRCLE-1,, SURAT vs. SHRI JAIPRKASH K.ASWANI, SURAT

In the result, appeal of the Revenue is dismissed

Bench: Shri Amarjit Singh & Shri O.P.Meenaआ.अ.सं./I.T.A No.709/Ahd/2011 "नधा"रण वष"/Assessment Year: 2008-09 The Dy.Commissioner Of V Shri Jaiprakash K Aswani, Income Tax, Central Circle-1, S. J-18, J.J. A/C. Market, Ring Surat. Road, Surat. [Pan: Aaspa 3016 C] अपीलाथ" / Appellant ""यथ"/Respondent आ.अ.सं./I.T.A No.708/Ahd/2011 "नधा"रण वष"/Assessment Year: 2008-09 The Dy.Commissioner Of V Shri Rajubhai Lakhabhai Income Tax, Central Circle-1, S. Bharwad, Surat. At & Post Laskana, Kamrej, Surat. [Pan: Afkpb 9356 B] अपीलाथ" / Appellant ""यथ"/Respondent "नधा"रतीक"ओरसे /Assessee By Shri Rajesh Shah – Ca राज"वक"ओरसे /Revenue By Shri O.P.Singh – Cit-Dr सुनवाईकीतारीख/ Date Of Hearing: 24.10.2019 उ"घोषणाक"तार"ख/Pronouncement On: 10.12.2019 आदेश /O R D E R Per O.P.Meena, Am: 1. These Two Appeals By The Revenue Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)-Ii, Surat Dated 23.12.2010 For The Assessment Year 2008-09. Jay Prakash K. Aswani & Rajubhai Lakhabhai Bharwad /Ita No.709 & 708/Ahd/2011 For A.Y. 2008-09 Page 2 Of 12

unexplained investment was made by Shri Jaiprakash Aswani and not by Shri Rajubhai Bharwad. The reasons given by the Assessing Officer are as follows. “Shri Jaiprakash Aswani is a builder and has construction business by profession. A search was carried out at the business as well as residential premises. From past several years, he has a prominent Jay Prakash

RAVI MAHEXA,DAMAN AND DIU vs. INCOME TAX OFFICER, WARD 5, , VAPI

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

investment to the fixed assets.” (v) Ground No.5 raised by the assessee, in ITA No. 194/SRT/2022, is as follows: “On the facts on the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred in confirming the action of assessing officer in making the addition of Rs.32

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

investment to the fixed assets.” (v) Ground No.5 raised by the assessee, in ITA No. 194/SRT/2022, is as follows: “On the facts on the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred in confirming the action of assessing officer in making the addition of Rs.32

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

investment to the fixed assets.” (v) Ground No.5 raised by the assessee, in ITA No. 194/SRT/2022, is as follows: “On the facts on the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals) has erred in confirming the action of assessing officer in making the addition of Rs.32

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

unexplained investment u/s 69 of the Act in respect of shop in Westfield Shopping Complex. The CIT(A) has deleted the addition by observing that the project was developed by M/s Kuberji Developers where Shri Naresh B. Agarwal, father of the appellant, was one of the partners. Since major portion of the project could not be sold, the partners decided

SHRI NISHANT KANTILAL PATEL,BHARUCH vs. INCOME TAX OFFICER, WARD-2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

unexplained for the purpose of taxation. No such cogent evidence or material has been noticed by the Investigation Directorate or by the AO and therefore, merely because the assessee was able to get good return on her investment does not mean that it is bogus transaction. Such return is in the nature of long term gain within the meaning

SHRI NISHANT KANTILAL PATEL,BHARUCH vs. INCOME TAX OFFICER, WARD-2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

unexplained for the purpose of taxation. No such cogent evidence or material has been noticed by the Investigation Directorate or by the AO and therefore, merely because the assessee was able to get good return on her investment does not mean that it is bogus transaction. Such return is in the nature of long term gain within the meaning

SMT. MUKTABEN NISHANTBHAI PATEL,ANKLESHWAR vs. INCOME TAX OFFICER WARD -2(2), BHARUCH

In the result, the appeals filed by the assessee (In ITA No

Bench: Shri Pawan Singh, Jm & Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.05 & 06/Srt/2019 ("नधा"रणवष" / Assessment Year: (2013-14) (Virtual Court Hearing) Shri Nishantkantilal Patel, Vs. Income Tax Officer, 9, Uma Park Society, Near Uma Ward-2(2), Bharuch. Bhavan, Bharuch-393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Amepp2505R (Assessee) (Respondent) Smt Muktabennishantbhai Patel, Vs. Income Tax Officer, 9-10, Patel Kubj, Uma Park Society, B/H Ward-2(2), Bharuch. Uma Bhavan, Old Nh No.8, Gidc, Zadeshwar, Ankleshwar -393002. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Binpp5922N (Assessee) (Respondent) आयकरअपीलसं./Ita Nos.07 & 10/Srt/2019 ("नधा"रणवष" / Assessment Year: (2014-15)

unexplained for the purpose of taxation. No such cogent evidence or material has been noticed by the Investigation Directorate or by the AO and therefore, merely because the assessee was able to get good return on her investment does not mean that it is bogus transaction. Such return is in the nature of long term gain within the meaning

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

investment in form of cash deposits in saving bank account No. 31/0602920 with the Central Bank of India during F.Y. 2010-11 relevant A.Y. 2011-12.” 2. Brief facts of the case are that no return of income was filed by assessee for the A.Y. 2011-12. The Assessing Officer was having information from their system that there was cash

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

investment in form of cash deposits in saving bank account No. 31/0602920 with the Central Bank of India during F.Y. 2010-11 relevant A.Y. 2011-12.” 2. Brief facts of the case are that no return of income was filed by assessee for the A.Y. 2011-12. The Assessing Officer was having information from their system that there was cash

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIR. -4, SURAT vs. SHREE KUBERJI TEXTILE DECK, SURAT

In the result, grounds of appeal raised by revenue as well as assessee are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Sainiit(Ss)A No. 63 & 64/Srt/2023 (Ay: 2016-17 & 2019-20) (Physical Hearing) D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/ Revenue Respondent/ Assessee D.C.I.T., Shree Kuberji Textile Deck, Central Circle-4, 2Nd Floor, Shree Kuberji Corporate Vs. Surat. House, Begumpura, Nr. Khndaa Kuva Road, Surat-395002. Pan No. Acsfs 4939 A Appellant/Revenue Respondent/Assessee

unexplained investment. Thus, in view of the aforesaid additional observation, we do not find any reason to interfere with the finding of ld. CIT(A) which we affirm. 11. In the result, this appeal of revenue is dismissed. IT(SS)A No. 64/SRT/2023 (AY: 2019-20) by revenue 12. The Revenue in the present appeal, though raised multiple grounds

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 investment. The learned counsel for the assessee further Mukesh N Desai v. DCIT-2, Surat /I.T.A. No. 2376/AHD/2014/A.Y: 2006-07 Page 9 of 21 supported his view by relying in the case of ITO v. Smt. Sejal D Shah [I.T.A.No. 3400/Ahd/2014 dtd. 10.01.2018 of Ahmedabad Tribunal] [copy filed and placed at Paper Book Page

DCIT, CIRCLE-1(1)(1), SURAT, SURAT vs. M/S. J K PAPER LIMITED, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016. The ld. Sr. Counsel submits that the price charged by Captive Power Project (CPP) Unit from paper and board units does not exceed price charged by Gujarat Electricity Board (GEB) from assessee company. The ld. CIT(A) while granting relief to the assessee, followed the decision of Gujarat High Court

DCIT, CIRCLE-1(1)(2), SURAT vs. J K PAPER LTD, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016. The ld. Sr. Counsel submits that the price charged by Captive Power Project (CPP) Unit from paper and board units does not exceed price charged by Gujarat Electricity Board (GEB) from assessee company. The ld. CIT(A) while granting relief to the assessee, followed the decision of Gujarat High Court

DCIT, CIRCLE-1(1)(2), SURAT vs. J K PAPER LTD, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016. The ld. Sr. Counsel submits that the price charged by Captive Power Project (CPP) Unit from paper and board units does not exceed price charged by Gujarat Electricity Board (GEB) from assessee company. The ld. CIT(A) while granting relief to the assessee, followed the decision of Gujarat High Court