Love Shoppers Limited, Ahmedabad vs. Add. CIT, Range -2(1), Ahmedabad
In the result, the appeal of the assessee is allowed
ITA 427/RJT/2023[2016-17]Status: DisposedITAT Rajkot04 Feb 2025AY 2016-17
Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.427/Rjt/2023 ("नधा"रण वष" / Assessment Year: (2016-17) (Physical Hearing) M/S. Love Shoppers Ltd. Vs. Add. Cit, Range 2(1) 10Th Floor, Broadway Business Ahmedabad Centre, Opp. Mayors Bunglow, Nr. Law Garden, Ellisbridge Ahmedabad 380006 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaacl5963A (Assessee) (Respondent)
For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 143(3)Section 269SSection 269TSection 26SSection 271Section 271DSection 271E
…gly, it is submitted that no penalty liable as it is transaction between closely related party. In support this contention, the reliance is placed on the decision of the jurisdictional Hon'ble Gujarat High Court in the case of CIT Vs. Shree Ambica Flour Mills 6 DTR 169 (Guj), Wherein Hon'ble court while considering similar issue of imposition of penalty u/s. 271D and 271E of the Act observed that the transactions between sister concerns are not covered by either provision of section 269SS or 269T of the Act. The Hon'ble High Court also taking into note the object behind bringing section 26SS and section 269T for…
