ITAT Ahmedabad Judgments — March 2026

AMBICA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2355/AHD/2025[2021-22]Status: Disposed27 Mar 2026AY 2021-22Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

AMBICA ASHISH TRADE LINK LLP,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2352/AHD/2025[2022-23]Status: Disposed27 Mar 2026AY 2022-23Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

MEHAAN ENTERPRISE,AHMEDABAD vs THE PCIT, CENTRAL, AHMEDABAD

ITA 789/AHD/2025[2018-19]Status: Disposed27 Mar 2026AY 2018-19Dismissed

The Tribunal held that the conditions for invoking jurisdiction under Section 263 were satisfied. The PCIT's observation that the Assessing Officer failed to conduct proper inquiry regarding the disallowance of interest expenditure on unsecured loans was considered valid.

HASMUKHBHAI JAYANTIBHAI PATEL,AHMEDABAD vs ITO WARD 2(1)(2), AHMEDABAD, GUJARAT

ITA 410/AHD/2026[2015-16]Status: Disposed27 Mar 2026AY 2015-16Allowed

The Tribunal held that for the assessment year in question, Section 194-IA applied to the aggregate consideration of the property, not individual shares. However, subsequent amendments changed this position. Citing previous rulings, the Tribunal found that for the period before the amendment, if individual shares were below the threshold, TDS was not required.

DEPUTY COMMISIONER OF INCOME TAX CENTRAL CIRCLE 1.4 AHMEDABAD, AHMEDABAD vs AMBICA ASHISH TRADE LINK LLP, AHMEDABAD

ITA 2284/AHD/2025[2022-23]Status: Disposed27 Mar 2026AY 2022-23Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

AMBICA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2358/AHD/2025[2024-25]Status: Disposed27 Mar 2026AY 2024-25Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

KAMDAR (BILKHIYA) PARIVAR NA KULDEVI AMBA MATA TRUST - JUNA SAVAR,SAVARKUNDLA vs CIT(EXEMPTION) AHMEDABAD, AHMEDABAD

ITA 466/AHD/2026[N.A.]Status: Disposed27 Mar 2026Remanded

The Tribunal held that the rejection was based solely on non-compliance and that principles of natural justice required the assessee to be given another opportunity. The matter was restored to the CIT(E) for fresh adjudication.

INCOME TAX OFFICER WARD-2(1)(2),AHMEDABAD, AHMEDABAD vs DHARMENDRAKUMAR ISHWARBHAI PATEL, AHMEDABAD

ITA 1549/AHD/2025[2018-19]Status: Disposed27 Mar 2026AY 2018-19Remanded

The Tribunal noted that the Rectification Deed was not available during the reassessment proceedings. Since the assessee agreed to produce all documents before the Assessing Officer, the Tribunal set aside the orders of the lower authorities. The matter was remitted back to the Assessing Officer to pass a fresh reassessment order after considering all necessary documents.

NIMISH MAHESHKUMAR BHA vs AR,AHMEDABAD

ITA 32/AHD/2026[2019-20]Status: Disposed27 Mar 2026AY 2019-20Allowed

The Tribunal found that the notice issued under section 148 for reopening the assessment was invalid because the escapement of income (Rs. 5 lacs) did not meet the threshold of Rs. 50 lakhs or more required under section 149(b) for reopening beyond three years and three months from the end of the assessment year. Therefore, the proceedings were void ab initio.

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs DEPUTY COMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

ITA 2420/AHD/2025[2015-2016]Status: Disposed27 Mar 2026AY 2015-2016Allowed

The Tribunal restored the matter to the Assessing Officer for de-novo adjudication, allowing the assessee an adequate opportunity to present its case. This was done in the interest of justice, considering the assessee's inability to properly present its case before lower authorities.

DINESH DHARAMDASANI,AHMEDABAD vs THE ITO, WARD-1(2)(1), AHMEDABAD

ITA 2498/AHD/2025[2013-14]Status: Disposed27 Mar 2026AY 2013-14Remanded

The Tribunal observed that the assessee failed to provide necessary details to the CIT(A). However, considering the assessee's plea for an opportunity to furnish documents and in the interest of justice, the matter was remanded for de novo adjudication.

BAHUCHARKRUPA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2362/AHD/2025[2023-24]Status: Disposed27 Mar 2026AY 2023-24Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

SAHAJANAND EDUCATION AND CHARITABLE TRUST,GANDHINAGAR vs THE CIT(EXEMPTION), AHMEDABAD

ITA 2392/AHD/2025[NA]Status: Disposed27 Mar 2026Remanded

The Tribunal noted the assessee's plea of compelling circumstances for non-response and the need for another opportunity. The Tribunal held that remanding the matter to the CIT(E) for a fresh consideration of the application, along with the assessee's submissions, would serve the interests of justice.

KANAIYALAL P DANA,VADODARA vs DCIT, CIRCLE- 2(1)(1), VADODARA

ITA 2148/AHD/2025[2022-23]Status: Disposed27 Mar 2026AY 2022-23Allowed

The Tribunal held that the processing of the return under section 143(1) was invalid because the Assessing Officer (CPC) failed to provide the mandatory prior notice to the assessee before making the adjustment/disallowance, as required by the first proviso to section 143(1)(a). This failure violates the principle of natural justice ('audi alteram partem').

BAHUCHARKRUPA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2359/AHD/2025[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

AMBICA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2356/AHD/2025[2022-23]Status: Disposed27 Mar 2026AY 2022-23Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

ELECTRONICS & QUALITY DEVELOPMENT CENTRE,GANDHINAGAR vs CPC, BENGALURU CURRENT JURIS. -THE DY.CIT, (EXEMPTION), CIRCLE-1, AHMEDABAD

ITA 1684/AHD/2025[2024-25]Status: Disposed27 Mar 2026AY 2024-25Allowed

The Tribunal held that the late filing of Form 10B is a procedural defect and not a substantive condition for claiming exemption. Since the audit report was available before the intimation under Section 143(1) was issued, the denial of exemption was not justified.

RANIMA SARVAJANIK CHARITABLE TRUST,BHAVNAGAR vs THE CIT(EXEMPTION), AHMEDABAD

ITA 1447/AHD/2025[NA]Status: Disposed27 Mar 2026Remanded

The Tribunal noted that the CIT(Exemption) had not considered the expenses incurred by the assessee for religious purposes. Therefore, the Tribunal set aside the impugned order and remanded the matter back to the CIT(Exemption) for a fresh analysis.

KAMINIBEN JAGDISHBHAI PATEL,ANAND vs INCOME-TAX OFFICER, WARD-1, ANAND, ANAND

ITA 2/AHD/2026[2018-19]Status: Disposed27 Mar 2026AY 2018-19Allowed

The Tribunal found that the sale value, purchase cost, and cost of improvement of the property were not in dispute. The fixed deposits made out of the sale consideration were also not disputed. The Tribunal decided to adjudicate the issue on merits to serve the interest of justice.

SHREE ZALAWAD JAIN SAMAJ,SURAT vs THE CIT(EXEMPTION), AHMEDABAD

ITA 266/AHD/2026[NA]Status: Disposed27 Mar 2026Allowed

The Tribunal condoned the delay in filing the appeals and the ex-parte rejection orders, subject to the assessee paying a cost of Rs. 5,000/- to the Income Tax Department. The matters were set aside to the CIT(Exemption) to provide one more opportunity for the assessee to furnish necessary documents for registration.

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1). VADODARA, VADODARA vs ALEMBIC PHARMACEUTICALS LIMITED, VADODARA

ITA 1674/AHD/2024[2018-19]Status: Disposed27 Mar 2026AY 2018-19Partly Allowed

The Tribunal held that the disallowance of weighted deduction under Section 35(2AB) for R&D expenses was to be decided based on a previous co-ordinate bench ruling. The Tribunal also dismissed the Revenue's grounds regarding MEIS receipts being capital in nature and not taxable under Section 115JB, following its own prior decisions.

AMBICA ASHISH TRADE LINK LLP,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2350/AHD/2025[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

RUSHINA VIKRAM DESAI,AHMEDABAD vs THE ITO, WARD-3(3)(2), AHMEDABAD

ITA 1884/AHD/2025[2016-17]Status: Disposed27 Mar 2026AY 2016-17Allowed

The Tribunal held that the AO erred in reopening the assessment under section 148 as the case had already been subjected to scrutiny assessment under section 143(3). The Tribunal further noted that the loan transaction was genuine and supported by bank details, being out of the sale proceeds of land already assessed.

SHREE ZALAWAD JAIN SAMAJ,SURAT vs THE CIT (EXEMPTION), AHMEDABAD

ITA 2142/AHD/2025[NA]Status: Disposed27 Mar 2026Allowed

The Tribunal condoned the delay in filing the appeals and the ex-parte rejection orders, subject to the assessee paying a cost of Rs. 5,000/- to the Income Tax Department. The matters were set aside to the CIT(Exemption) to provide one more opportunity for the assessee to furnish necessary documents for registration.

AMBICA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2357/AHD/2025[2023-24]Status: Disposed27 Mar 2026AY 2023-24Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

BAHUCHARKRUPA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2361/AHD/2025[2022-23]Status: Disposed27 Mar 2026AY 2022-23Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

SAHAJANAND EDUCATION AND CHARITABLE TRUST,GANDHINAGAR vs THE CIT(EXEMPTION), AHMEDABAD

ITA 2391/AHD/2025[NA]Status: Disposed27 Mar 2026Remanded

The Tribunal noted the assessee's plea of compelling circumstances for non-response and the need for another opportunity. The Tribunal held that remanding the matter to the CIT(E) for a fresh consideration of the application, along with the assessee's submissions, would serve the interests of justice.

DEPUTY COMMISIONER OF INCOME TAX CENTRAL CIRCLE 1.4 AHMEDABAD, AHMEDABAD vs AMBICA ASHISH TRADE LINK LLP, AHMEDABAD

ITA 2285/AHD/2025[2023-24]Status: Disposed27 Mar 2026AY 2023-24Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

ALEMBIC PHARMACEUTICALS LIMITED,VADODARA vs THE DY. CIT, CIRCLE-1(1)(1), VADODARA

ITA 1661/AHD/2024[2018-19]Status: Disposed27 Mar 2026AY 2018-19Partly Allowed

The Tribunal held that the disallowance of weighted deduction under Section 35(2AB) for R&D expenses was to be decided based on a previous co-ordinate bench ruling. The Tribunal also dismissed the Revenue's grounds regarding MEIS receipts being capital in nature and not taxable under Section 115JB, following its own prior decisions.

ALEMBIC PHARMACEUTICALS LIMITED,VADODARA vs THE DY.CIT, CIRCLE-1(1)(1), VADODARA

ITA 1662/AHD/2024[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that the disallowance of weighted deduction under Section 35(2AB) for R&D expenses was to be decided based on a previous co-ordinate bench ruling. The Tribunal also dismissed the Revenue's grounds regarding MEIS receipts being capital in nature and not taxable under Section 115JB, following its own prior decisions.

DEPUTY COMMISIONER OF INCOME TAX CENTRAL CIRCLE 1.4 AHMEDABAD, AHMEDABAD vs AMBICA ASHISH TRADE LINK LLP, AHMEDABAD

ITA 2248/AHD/2025[2021-22]Status: Disposed27 Mar 2026AY 2021-22Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

AMBICA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2354/AHD/2025[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

AMBICA ASHISH TRADE LINK LLP,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2351/AHD/2025[2021-22]Status: Disposed27 Mar 2026AY 2021-22Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

ITA 2339/AHD/2025[2012-2013]Status: Disposed27 Mar 2026AY 2012-2013Allowed

The Tribunal restored the matter to the Assessing Officer for de-novo adjudication, allowing the assessee an adequate opportunity to present its case. This was done in the interest of justice, considering the assessee's inability to properly present its case before lower authorities.

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

ITA 2412/AHD/2025[2013-2014]Status: Disposed27 Mar 2026AY 2013-2014Allowed

The Tribunal restored the matter to the Assessing Officer for de-novo adjudication, allowing the assessee an adequate opportunity to present its case. This was done in the interest of justice, considering the assessee's inability to properly present its case before lower authorities.

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

ITA 2413/AHD/2025[2014-2015]Status: Disposed27 Mar 2026AY 2014-2015Allowed

The Tribunal restored the matter to the Assessing Officer for de-novo adjudication, allowing the assessee an adequate opportunity to present its case. This was done in the interest of justice, considering the assessee's inability to properly present its case before lower authorities.

DEPUTY COMMISIONER OF INCOME TAX CENTRAL CIRCLE 1.4 AHMEDABAD, AHMEDABAD vs AMBICA ASHISH TRADE LINK LLP, AHMEDABAD

ITA 2247/AHD/2025[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1), VADODARA, VADODARA vs ALEMBIC PHARMACEUTICALS LIMITED, VADODARA

ITA 1675/AHD/2024[2020-21]Status: Disposed27 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that the disallowance of weighted deduction under Section 35(2AB) for R&D expenses was to be decided based on a previous co-ordinate bench ruling. The Tribunal also dismissed the Revenue's grounds regarding MEIS receipts being capital in nature and not taxable under Section 115JB, following its own prior decisions.

BAHUCHARKRUPA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2363/AHD/2025[2024-25]Status: Disposed27 Mar 2026AY 2024-25Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

JAYENDRA BIPINCHANDRA PATEL,GANDHINAGAR vs ITOWARD-7(2)(1), AHMEDABAD

ITA 190/AHD/2026[2021-22]Status: Disposed27 Mar 2026AY 2021-22Allowed

The Tribunal held that the compensation received under the BSNL VRS-2019 scheme should be treated as exempt under Section 10(10B) of the Income Tax Act, 1961. Relying on coordinate bench decisions, the Tribunal found the assessee eligible for full tax exemption on the received compensation.

AMBICA ASHISH TRADE LINK LLP,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2353/AHD/2025[2023-24]Status: Disposed27 Mar 2026AY 2023-24Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

JAYENDRA BIPINCHANDRA PATEL,GANDHINAGAR vs ITOWARD-7(2)(1), AHMEDABAD

ITA 189/AHD/2026[2020-21]Status: Disposed27 Mar 2026AY 2020-21Allowed

The Tribunal held that the compensation received under the BSNL VRS-2019 scheme should be treated as exempt under Section 10(10B) of the Income Tax Act, 1961. Relying on coordinate bench decisions, the Tribunal found the assessee eligible for full tax exemption on the received compensation.

BAHUCHARKRUPA TRADING CO.,AHMEDABAD vs THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

ITA 2360/AHD/2025[2021-22]Status: Disposed27 Mar 2026AY 2021-22Partly Allowed

The Tribunal held that while unaccounted transactions were established, the profit estimation needed adjustment. The net profit rate applied to these transactions was reduced from 5% to 4% for most assessees.

ANIL RAMBHAI MEVADA,AHMEDABAD vs ACIT, CENTRAL CIRCLE 2(3), AHMEDABAD, AHMEDABAD

ITSSA 110/AHD/2025[2019-20]Status: Disposed26 Mar 2026AY 2019-20Partly Allowed

The Tribunal held that the addition of Rs. 19,67,39,459/- made by the AO on account of alleged on-money received on sale of lands in Survey Nos. 340/1 and 341 was not correct. The CIT(A) had deleted this addition, finding that the seized material did not establish the receipt of brokerage and that the AO's assumptions were not supported by evidence. The Tribunal agreed with the CIT(A)'s finding that the seized material did not have the name of the assessee and that the AO had not established the correctness of the land deals through Shri Suresh R. Thakkar. Regarding the addition of Rs. 6,87,75,000/- for land in Survey No. 736/2, the Tribunal noted that the CIT(A) had sustained an addition of Rs. 1.08 crores against the AO's Rs. 6.87 crores. The Tribunal, referring to its decision in the case of Deepak Rambhai Mevada (IT[SS]A No.109/Ahd/2025), restricted the addition to Rs. 36,66,667/- on account of the cash component paid towards the purchase of land bearing Survey No. 736/2. The Tribunal dismissed the Revenue's ground regarding the admissibility of WhatsApp chat evidence, noting it was not argued seriously and was in support of earlier grounds. The addition of Rs. 16.50 crores on account of alleged undisclosed cash/capital contribution in Safalya Infralink LLP was deleted by the CIT(A) and the Tribunal found no reason to interfere, as the AO failed to provide corroborative evidence and reassessment proceedings in related cases were dropped. The ratio for the land in Survey No. 736/2 was applied to Anil Rambhai Mevada.

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), AHMEDABAD, AHMEDABAD vs ANIL RAMBHAI MEVADA, AHMEDABAD

ITSSA 120/AHD/2025[2019-20]Status: Disposed26 Mar 2026AY 2019-20Partly Allowed

The Tribunal held that the addition of Rs. 19,67,39,459/- made by the AO on account of alleged on-money received on sale of lands in Survey Nos. 340/1 and 341 was not correct. The CIT(A) had deleted this addition, finding that the seized material did not establish the receipt of brokerage and that the AO's assumptions were not supported by evidence. The Tribunal agreed with the CIT(A)'s finding that the seized material did not have the name of the assessee and that the AO had not established the correctness of the land deals through Shri Suresh R. Thakkar. Regarding the addition of Rs. 6,87,75,000/- for land in Survey No. 736/2, the Tribunal noted that the CIT(A) had sustained an addition of Rs. 1.08 crores against the AO's Rs. 6.87 crores. The Tribunal, referring to its decision in the case of Deepak Rambhai Mevada (IT[SS]A No.109/Ahd/2025), restricted the addition to Rs. 36,66,667/- on account of the cash component paid towards the purchase of land bearing Survey No. 736/2. The Tribunal dismissed the Revenue's ground regarding the admissibility of WhatsApp chat evidence, noting it was not argued seriously and was in support of earlier grounds. The addition of Rs. 16.50 crores on account of alleged undisclosed cash/capital contribution in Safalya Infralink LLP was deleted by the CIT(A) and the Tribunal found no reason to interfere, as the AO failed to provide corroborative evidence and reassessment proceedings in related cases were dropped. The ratio for the land in Survey No. 736/2 was applied to Anil Rambhai Mevada.

STATE BANK OF INDIA BHAVNAGAR PARA BRANCH,BHAVNAGAR vs ITO TDS WARD 1, AHMEDABAD, AHMEDABAD

ITA 453/AHD/2026[2016-17]Status: Disposed26 Mar 2026AY 2016-17Allowed

The Tribunal held that the assessee could not be treated as an assessee in default as it was bound by the interim directions of the Madras High Court, which prevented tax deduction. Therefore, the demand under Section 201(1) and interest under Section 201(1A) were deleted.

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(3), AHMEDABAD, AHMEDABAD vs DEEPAK RAMBHAI MEVADA, AHMEDABAD

ITSSA 119/AHD/2025[2020-21]Status: Disposed26 Mar 2026AY 2020-21Partly Allowed

The Tribunal held that the addition of Rs. 19,67,39,459/- made by the AO on account of alleged on-money received on sale of lands in Survey Nos. 340/1 and 341 was not correct. The CIT(A) had deleted this addition, finding that the seized material did not establish the receipt of brokerage and that the AO's assumptions were not supported by evidence. The Tribunal agreed with the CIT(A)'s finding that the seized material did not have the name of the assessee and that the AO had not established the correctness of the land deals through Shri Suresh R. Thakkar. Regarding the addition of Rs. 6,87,75,000/- for land in Survey No. 736/2, the Tribunal noted that the CIT(A) had sustained an addition of Rs. 1.08 crores against the AO's Rs. 6.87 crores. The Tribunal, referring to its decision in the case of Deepak Rambhai Mevada (IT[SS]A No.109/Ahd/2025), restricted the addition to Rs. 36,66,667/- on account of the cash component paid towards the purchase of land bearing Survey No. 736/2. The Tribunal dismissed the Revenue's ground regarding the admissibility of WhatsApp chat evidence, noting it was not argued seriously and was in support of earlier grounds. The addition of Rs. 16.50 crores on account of alleged undisclosed cash/capital contribution in Safalya Infralink LLP was deleted by the CIT(A) and the Tribunal found no reason to interfere, as the AO failed to provide corroborative evidence and reassessment proceedings in related cases were dropped. The ratio for the land in Survey No. 736/2 was applied to Anil Rambhai Mevada.

INCOME TAX OFFICER (TDS-3), AHMEDABAD, AHMEDABAD vs TARUN SANTRAMDAS VARMA, AHMEDABAD

ITA 2549/AHD/2025[2015-16]Status: Disposed26 Mar 2026AY 2015-16Dismissed

The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision. It found no prejudice in admitting official documents as additional evidence and agreed that the lands were agricultural and outside the scope of Section 194-IA, thus not requiring TDS deduction.

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1166/AHD/2025[2015-16]Status: Disposed26 Mar 2026AY 2015-16Allowed

The Tribunal held that the reopening of assessment was invalid as it was based on a change of opinion without any fresh material. The Tribunal followed various High Court judgments stating that reopening is impermissible in such circumstances.

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

ITA 1165/AHD/2025[2014-15]Status: Disposed26 Mar 2026AY 2014-15Allowed

The Tribunal held that the reopening of assessment was invalid as it was based on a change of opinion without any fresh material. The Tribunal followed various High Court judgments stating that reopening is impermissible in such circumstances.