Ramesh Chand Premraj Soni (HUF) v. ACIT

13 SOT 15Income Tax Appellate Tribunal#22353 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 346,713 Indian tax judgments — from 2021 to 2024.

Judgments citing Ramesh Chand Premraj Soni (HUF) v. ACIT

DCIT (Central), Bhopal vs. Shailendra Sharma, Bhopal

In the result the appeals of the assessee for the Assessment

ITA 305/IND/2023[2015-16]Status: DisposedITAT Indore24 Jun 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 142(1)Section 153A

…is done. An assessment can be considered as protective only when there is substantive assessment. Thus, assessment has to precede protective assessment 6.7 We also note that the ITAT Jodhpur in the case of Ramesh Chand Premraj Soni (HUF) VS. ACIT reported in 13 SOT 15 has held that if the 42 IT(SS) No.30 & 31/Ind/2023 ITA (SS) No.305/Ind/2023 Shailendra Sharma substantive assessment in the case of the assessee is struck down being barred by time, the additions made in the protective assessment cannot survive. The relevant extract is reproduced as under "In the instant case, there was no dispute with regard to…

Jt CIT (OSD), CC-3(1), Mumbai vs. Vallabhbhai Parsottambhai Surani, Surat

In the result, appeal filed by the Revenue is dismissed

ITA 498/MUM/2021[2007-08]Status: DisposedITAT Mumbai15 Sept 2023AY 2007-08

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon'Blejt. Commissioner Of Income Tax (Osd) V. Vallabhbhai Parsottambhai Surani Central Circle – 3(1) 1, Sundaram Bunglow Room No. 1924, 19Th Floor Lambe Hanuman Road Air India Building, Nariman Point Opp. Saiffe Society Mumbai – 400 021 Gujrat - 395006 Pan: Ajyps2262F (Appellant) (Respondent) C.O. No.164/Mum/2021 [Arising Out Of Ita No. 498/Mum/2021 (A.Y: 2007-08)] Vallabhbhai Parsottambhai Surani V. Jt. Commissioner Of Income Tax (Osd) 1, Sundaram Bunglow Central Circle – 3(1) Room No. 1924, 19Th Floor Lambe Hanuman Road Air India Building, Nariman Point Opp. Saiffe Society Mumbai – 400 021 Gujrat - 395006 Pan: Ajyps2262F (Appellant) (Respondent) Assessee Represented By : Shri Bharat Kumar Department Represented By : Dr. Mahesh Akhade

Section 132Section 139(1)Section 142Section 143(3)Section 153A

…l issue, Ld. AR of the assessee placed reliance on the decision of Ahmedabad Tribunal ITA No. 142/AHD/2016 A.Y. 2011-12 in which it is held as under:- “6.7 We also note that the ITAT Jodhpur in the case of Ramesh Chand Premraj Soni (HUF) Vs. ACIT reported in 13 SOT 15 has held that if the substantive assessment in the case of the assessee is struck down being barred by time, the additions made in the protective assessment cannot survive. The relevant extract is reproduced as under: “In the instant case, there was no dispute with regard to the facts that all the additions, which were the subject- matter of appeal…

Shri Pravinkumar Valjibhai Pujara, HUF, Patan vs. The Income Tax Officer, Ward-2, Patan

In the result, the appeal of the assessee is partly allowed

ITA 142/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad24 Jun 2021AY 2011-12

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 142/Ahd/2016 िनधा"रण वष"/Asstt. Year: 2011-12 Pravinkumar Valjibhai Pujara Huf, I.T.O, C-46, Lal Baug, Near Dargah, Vs. Ward-2, Radhanpur, Patan. Dist. Patan-385340

For Appellant: Shri Aseem Thakkar, A.RFor Respondent: Shri S.S. Shukla, Sr.D.R

Section 143(3)Section 69

…sessment can be considered as protective only when there is substantive assessment. Thus, substantive assessment has to precede protective assessment.” 6.7 We also note that the ITAT Jodhpur in the case of Ramesh Chand Premraj Soni (HUF) Vs. ACIT reported in 13 SOT 15 has held that if the substantive assessment in the case of the assessee is struck down being barred by time, the additions made in the protective assessment cannot survive. The relevant extract is reproduced as under: “In the instant case, there was no dispute with regard to the facts that all the additions, which were the subject-matter of appeal…