Avani Dipakbhai Shah, Vadodara vs. The ACIT, Circle Intl. Txn., Vadodara
The appeal of the assessee is allowed
ITA 707/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad17 Oct 2025AY 2017-18
Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha
For Appellant: Shri Jigar Adhyaru, ARFor Respondent: Shri Rameshwar P Meena, Sr. DR
Section 132Section 153CSection 271F
…be useful to discuss some relevant judicial precedents on the subject. ITA Nos. 705 to 707/Ahd/2025 Avani Dipakbhai Shah vs. ACIT Asst. Years –2014-15, 2016-17 & 2017-18 - 6– 12. In the case of Commissioner of Income-tax vs. Kanubhai Muljibhai Patel [2008] 306 ITR 179 (Gujarat), the High Court held that where assessee filed return of income for assessment year 1979-80 on 23-3-1982 showing amount received on sale of agricultural land as exempt in view of Bombay High Court's decision in Manubhai A. Shet v. ITO which was delivered only in July, 1980, a bona fide belief as to exemption of said income could be ente…