THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 39/AHD/2020Status: DisposedITAT Ahmedabad10 September 2024AY 2009-10Bench: Ms. SUCHITRA KAMBLE, JUDICAL MEMBER, SHRI NARENDRA PRASAD SINHA (Accountant Member)100 pages
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What did the Tribunal hold?

The Tribunal found that the assessee's explanations for the foreign bank accounts and jewellery were inconsistent and lacked corroboration. Consequently, additions made by the Assessing Officer were upheld in part.

What were the facts?

During a search operation, undisclosed foreign bank accounts held through a trust in Cayman Islands and Switzerland were discovered. The assessee initially denied possession of these accounts but later admitted to signing documents related to their establishment.

What were the issues?

The primary issues were the taxability of undisclosed foreign bank accounts and unexplained jewellery found during a search, and the validity of the assessee's explanations for these assets.

Which sections of the Income-tax Act were involved?

Section 132,Section 147,Section 153A,Section 143(3)

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Cases cited in this judgment(30)Show list

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IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD BEFORE Ms. SUCHITRA KAMBLE, JUDICAL MEMBER & SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER ITA Nos: 1894 to 1903/Ahd/2019 & 1904/Ahd/2019 Asst. Years: 2000-01 to 2009-10 & 2016-17 & IT(SS)A Nos: 569 to 574/Ahd/2019 Asst. Years: 2010-11 to 2015-16 बनाम बनाम/ बनाम बनाम Central Circle-1, Vadodara C/o. Apex Extrusions - 390007 Pvt. Ltd., 220-221, GIDC Estate, Makarpura, Vadodara, Gujarat, 390010 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : ACQPP7757H (Appellant) .. (Respondent) & ITA Nos: 1905 to 1914/Ahd/2019 & 1915/Ahd/2019 Asst. Years: 2000-01 to 2009-10 & 2016-17 & IT(SS)A Nos: 575 to 580/Ahd/2019 Asst. Years: 2010-11 to 2015-16 बनाम/ बनाम बनाम बनाम Smt. Manjulaben B. Deputy Commissioner of Patel Income Tax Vs. C/o. Apex Extrusions Central Circle-1, Vadodara Pvt. Ltd., 220-221, GIDC - 390007 Estate, Makarpura, Vadodara, Gujarat, 390010 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : ACQPP7419J (Appellant) .. (Respondent)

2 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel

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