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“legal representative”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(29)662 judgments

The decision most relied on for legal representative is 2 CIT v. Indrajit Singh Suri (33 Taxmann.com 281), cited in 100 judgments on BharatTax.

Leading authorities on legal representative

2 CIT v. Indrajit Singh Suri
33 Taxmann.com 281 · 2013 · High Court
100
citing judgments

The validity of reassessment proceedings initiated under Sections 147/148 against legal representatives of a deceased assessee requires a demonstrable 'reason to believe' that income escaped assessment, often based on third-party information such as alleged accommodation entries.

Savita Kapila v. ACIT
118 Taxmann.com 46 · 2020 · High Court
98
citing judgments

There is no legal requirement for a legal representative to report an assessee's death to the income tax department; consequently, a reassessment notice issued under Section 148 to a deceased person is invalid as it lacks proper jurisdiction.

Chandreshbhai Jayantibhai Patel v. ITO
101 Taxmann.com 362 · 2019 · High Court
46
citing judgments

A notice under section 148 of the Income-tax Act, 1961, is a jurisdictional notice and a condition precedent for reassessment. Such a notice issued against a deceased person is valid if the legal representative submits to the Assessing Officer without raising any objection.

CIT v. Amarchand N. Shroff
48 ITR 59 · 1963 · Supreme Court
40
citing judgments

Assessment proceedings initiated against a deceased person are void. Once an assessee dies, assessment proceedings can only continue in the name of their legal representative, to the extent of the deceased's estate.

202 ITR 932, CIT v. Durgawati
31 ITR 603 · 1957 · High Court
36
citing judgments

The same income cannot be assessed substantively in multiple hands. However, this principle does not prevent a single consolidated assessment order for multiple legal representatives.

CIT v. Jai Prakash Singh
219 ITR 737 · 1996 · Supreme Court
36
citing judgments

A procedural defect in serving notices, such as issuing them after the assessee's death without proper service on legal representatives, can invalidate reassessment proceedings and render assessment orders void. However, an omission or defect in serving notices does not erase a tax liability created by substantive provisions, though it may render an order irregular.

Rajender Kumar Sehgal v. ITO
260 Taxmann 412 · 2019 · High Court
25
citing judgments

A notice issued to a deceased assessee or their legal representatives beyond the period of limitation is without jurisdiction and cannot be saved by Section 292B.

ITO Ward 1(3)(7), Surat v. Durlabhbhai Kanubhai Rajpara
114 Taxmann.com 482 · 2020 · Supreme Court
24
citing judgments

An assessment or reassessment proceeding initiated or continued against a deceased person after their demise is illegal and void ab initio, as no valid notice can be issued to a dead individual.

Judgments citing legal representative

Subhash Chand Dhingra, New Delhi vs. ITO Ward 51(4), New Delhi

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 2914/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Apr 2024AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

For Appellant: Ms. Kavita, CAFor Respondent: Sh.Shyam Singh, Sr. DR
Section 144Section 148Section 69A

Kumar, Accountant Member Sh. Anubhav Sharma, Judicial Member ITA No. 2914/Del/2023 : Asstt. Year: 2017-18 Asha Dhingra Vs Assessing Officer (Appeals), Legal Representative of Late Sh. National Faceless Appeal Centre Subhash Chand Dhingra, (NFAC), Delhi 65/24, New Rohtak Road, Karol Bagh, New Delhi 110011 (APPELLANT) (RESPONDENT) PAN No. AIWPD0821C Assessee ... Fixed Deposits & SB Account, proceeds from LIC, rentals from House Property, etc. without giving a proper opportunity of being heard. 2 Asha Dhingra Legal Representative of Late Sh. Subhash Chand Dhingra 3. That the Ld. AO grossly erred on the facts as well as in law by adding

Shahaji Tukaram Patil, Sangli vs. ITO, Ward 5, Sangli

ITA 274/PUN/2024[2012-13]Status: DisposedITAT Pune17 Apr 2024AY 2012-13

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Amol KulkarniFor Respondent: Shri Manish Mehta
Section 143(3)Section 2Section 2(11)Section 2(29)

Patil is stated to be the wife of the deceased assessee Shri Shahaji Tukaram Patil. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2(11) 2 ITA.No ... 274/PUN./2024 of the Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal

Sri.Parayarukandy Vettath Gangadharan, Calicut vs. The DCIT Circle-1(1), Calicut

In the result, the instant appeal by the assessee is dismissed

ITA 157/COCH/2023[2007-08]Status: DisposedITAT Cochin12 Apr 2024AY 2007-08

Bench: Shri Sanjay Arora & Shri Manomohan Dasparayarukandy Vettath Gangadharan Dy. Cit, Circle - 1(1) Kerala Transport Company (Decd., Calicut Vs. Represented By Lrs.) K.T.C. Building, Ymca Calicut 673001 [Pan: Adhpg8318B] (Appellant) (Respondent)

For Appellant: Shri Suresh Kumar C., CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 147Section 148Section 149Section 150(1)Section 153Section 2(22)(e)Section 268A

Commissioner of Income Tax (Appeals), Income Tax Department [CIT(A)], vide his order dated 05.01.2023. The assessee, since deceased, is represented by his legal representatives, all of whom, his legal heirs, identified by succession certificate placed on record, have authorized Shri Suresh as their counsel before us. 2.1 The brief

Late Sh. Birdi Chand Through Legal Heir Mukesh Sharma, Jaipur vs. ITO, Ward-7(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 502/JPR/2023[2012-13]Status: DisposedITAT Jaipur09 Apr 2024AY 2012-13

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Anup Singh (Addl.CIT)
Section 139(1)Section 142(1)Section 143(3)Section 148Section 292BSection 54F

notice issued under s. 148 of the Act against a dead person is invalid, 8 Late Sh. Birdi Chand vs. ITO unless the legal representative submits to the jurisdiction of the AO without raising any objection 24. We are of the view that the same principle as referred to above ... void. To initiate proceedings under section 147 of the Act, issuance of notice under section 148 of the Act to the heirs and legal representatives of the deceased is mandatory, in the absence of which the proceedings cannot be continued by issuance of notices under section

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 322/NAG/2017[2007-2008]Status: DisposedITAT Nagpur21 Mar 2024AY 2007-2008

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 321/NAG/2017[2006-2007]Status: DisposedITAT Nagpur21 Mar 2024AY 2006-2007

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 320/NAG/2017[2005-2006]Status: DisposedITAT Nagpur21 Mar 2024AY 2005-2006

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 319/NAG/2017[2004-2005]Status: DisposedITAT Nagpur21 Mar 2024AY 2004-2005

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 318/NAG/2017[2003-2004]Status: DisposedITAT Nagpur21 Mar 2024AY 2003-2004

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Let Shri Raju Ramhari Kale L/H Smt Pratibha, Wife, Warud, Zilla Amravati vs. ACIT, Amravati Circal, Amravati

ITA 317/NAG/2017[2002-2003]Status: DisposedITAT Nagpur21 Mar 2024AY 2002-2003

Bench: Shri Satbeer Singh Godara

For Appellant: Shri Rajesh Loya, C.AFor Respondent: Shri Abhay Y Marathe
Section 143(3)Section 2Section 2(11)Section 2(29)

wife of the deceased assessee Shri Raju Ramhari 2 ITA.Nos.317 to 322/NAG./2017 Kale. Her case all along is that she is the “legal representative” of her husband in light of sec.2(29) of the Income Tax Act, 1961 read with the corresponding provision i.e., sec.2 ... Code of Civil Procedure, 1908. There could be hardly any dispute that the legislature has adopted the definition of a “legal representative” in sec.2(11) of the Code of Civil Procedure mutatis mutandis in the Income-tax law. The Code of Civil Procedure defines a “legal representative” as under : “Sec.2

Vijaybhai Laxmichand Demla L/H of Late Shri Laxmichand Pahlumal Demla, Bhavnagar vs. The ITO, Ward-1(1), Bhavnagar

In the result, the appeal filed by the Assessee is hereby allowed

ITA 1109/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad20 Mar 2024AY 2017-18

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115BSection 142(1)Section 144Section 159Section 271FSection 272A(1)(d)Section 69Section 69A

assessee filed an appeal before Ld. CIT(A) specifically raising Ground No. 4 that the Assessing Officer failed to bring on record all the legal Representatives of the deceased assessee. However the Ld. CIT(A) given two opportunities of hearing on 27.01.2021 and 24.07.2023 thereby without adjudicating the primary issue ... take the above facts on your record and oblige. 6.1. The Ld. Counsel placed on record, settled principle of law on the assessment of legal representatives by the Hon’ble Gujarat High Court in the case of Chooharmal Wadhuram Vs. CIT reported in (1971) 80 ITR 360, wherein

The Bombay Catholic Sabha, Mumbai vs. ITO Exemption Ward 2(4), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3793/MUM/2023[2016-17]Status: DisposedITAT Mumbai20 Mar 2024AY 2016-17

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.3793/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2016-17) The Bombay Catholic बिधम/ Ito (Exem)-2(4) Sabha Piramal Chamber, Lal Vs. St. Michael’S Church Baug, Parel, Mumbai- Compound, Mahhim (W), 400012. Mumbai-400016. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaatt3348L (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Mandar Vaidya Revenue By: Shri Ashok Kumar Ambastha (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 07/03/2024 घोषणा की तारीख /Date Of Pronouncement: 20/03/2024 आदेश / O R D E R Per Aby T. Varkey, Jm:

For Appellant: Shri Mandar VaidyaFor Respondent: Shri Ashok Kumar Ambastha (Sr. AR)
Section 11Section 11(2)

clarified and stated that the money in question would only be used for the purpose of making payments to the members or their legal representatives in case of their death, retirement or permanent disability. The Tribunal in the impugned order has also referred to the scheme floated by the respondent

Late Krishna Gopal Gupta (Thr. Son and Legal Heir Shri Mahendra Kumar Gupta), Jaipur vs. I.T.O. Ward 2 (1), Jaipur

In the result, the appeal of the assesee is allowed

ITA 2/JPR/2024[A.Y. 2007-08]Status: DisposedITAT Jaipur14 Mar 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri G.M. Mehta, CAFor Respondent: Smt. Monisha Choudhary, Addl CIT-DR
Section 148Section 250

held at concluding part of the order as under: 7. “Undoubtedly as per section 159 of the Act, where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner ... held at concluding part of the order as under: 7. “Undoubtedly as per section 159 of the Act, where a person dies, his legal representative shall be liable to pay any sum which the deceased would have been liable to pay if he had not died, in the like manner

Jagadish Kumar P.V (Legal Heir of Late Rema Padmaja Bai), Trivandrum vs. ACIT Circle 2(1), Trivandrum

In the result, the assessee’s appeal is partly allowed and partly allowed for statistical purposes

ITA 376/COCH/2023[2016-17]Status: DisposedITAT Cochin11 Mar 2024AY 2016-17

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmijagadish Kumar P.V. Asst. Cit, Circle - 2(1) (L/H Of Rema Padmaja Bai) Thiruvananthapuram Sree, T.C. 50/899(1), Kalady Vs. Hsra A-56, Karamana P.O. Thiruvananthapuram [Pan:Aempp5283J] (Appellant) (Respondent)

For Appellant: Shri Raja Kannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(3)Section 69

Assessment Year (AY) 2016-17. 2. The appeal is delayed by 26 days. The accompanying affidavit by the assessee’s spouse, her legal representative (LR), not seriously contested by the Revenue, suitably explains the delay. Further, Shri Kannan, the learned counsel for the assessee, who stands duly authorised

Malleswara Rao Alamuri (Late), Rep by Wife and L/R Alamuri Lakshmi, Vijayawada vs. Income Tax Officer, Ward-1(1), Vijayawada

In the result, appeal of the assessee is dismissed

ITA 123/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam28 Feb 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No. 123/Viz/2023 ("नधा"रण वष" / Assessment Year : 2017-18) (Late) Malleswara Rao Alumuri, Vs. Income Tax Officer, Rep. By Wife & L/R Alamuri Ward-1(1), Lakshmi, Vijayawada. D.No. 10-14/2-32, Akulavari Street, Mallikharjunapet, One Town, Vijayawada, Andhra Pradesh – 520001. Pan: Aldpa 7438 G (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri C. Subrahmanyam, Ar ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr

For Appellant: Sri C. Subrahmanyam, ARFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 263

delay along with the affidavit and the relevant contents of affidavit are extracted herein below for reference: “1. The petitioner is the wife and legal representative of Late Sri Malleswara Rao Alumuri. 2 …… 3 …… 4 …… 5 ….. 6. In consequent to the order passed U/s. 263 of the Act, AO passed ... India, VMC Campus, Vijayawada and called for the statement of account of the assessee. However, the assessee expired on 05/08/2018 and therefore his son / Legal Representative Shi Chinna Rao has responded to the notices issued by the Ld. AO and explained the sources along with the supporting documentary evidences with

Sara Suppliers Private Limited, Ahmedabad vs. The Asstt. Commissioner of Income Tax, Circle-4(1)(1), Ahmedabad

ITA 432/AHD/2022[2016-17]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2016-17

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकरअपीलसं./Ita No. 432/Ahd/2022 धििाधरणवरध/Asstt. Year: 2016-2017 Sara Suppliers Private Limited, The Asst. Commissioner Of 6, Patel Avenue, Vs. Income Tax, Near Gurudwara S.G Highway, Circle-4(1)(1), Ahmedabad-380054. Ahmedabad.

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsinh B. Parmar, A.RFor Respondent: Shri Sudhendu Das, CIT.D.R
Section 32(1)

whose name appear in the Register of Members on the Appointed Date or to such of their respective heirs, executors, administrators or other legal representative or other successors in title as may be recognized by the respective Board of Directors in the following manner: 2 (Two) fully paid Equity Shares

Vardhanapu Manikumari of Late Earnest Christopher Vardhanapu, Bhimavaram vs. Income Tax Officer, Ward-1, Bhimavaram

In the result, appeal of the assessee is allowed for statistical purpose

ITA 256/VIZ/2023[2014-15]Status: DisposedITAT Visakhapatnam20 Feb 2024AY 2014-15

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.256/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2014-15) Smt.Vardhanapu Manikumari Vs. Income Tax Officer L/R Of (Late) Earnest Christopher Ward-1 Vardhanapu Bhimavaram D.No.21-16-30A Dora Bangalow Mission Compound, West Godavari [Pan : Aeepv0600F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Dr.Aparna Villuri, DR
Section 12ASection 143(2)Section 143(3)Section 147Section 148Section 56Section 56(2)(vii)

order of the Ld.CIT(A), the assessee preferred an appeal before the Tribunal and filed a petition to bring on record Smt.Vardhanapu Manikumari as legal representative to pursue the case of 5 I.T.A. No.256/Viz/2023, A.Y.2014-15 Smt.Vardhanapu Manikumari, Bhimavaram (Late) Earnest Christopher Vardhanapu. The assessee raised the following grounds of appeal

Kifs International LLP, Ahmedabad vs. National Faceless Assessment Centre, Delhi Presently With ACIT, Central Circle-1(4), Ahmedabad

ITA 684/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad08 Feb 2024AY 2018-19

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

For Appellant: Shri Parimalsinh B. Parmar, A.RsFor Respondent: Shri Ritesh Parmar, CIT. DR & Shri
Section 143(3)Section 147Section 32Section 32(1)Section 43(6)

whose name appear in the Register of Members on the Appointed Date or to such of their respective heirs, executors, administrators or other legal representative or other successors in title as may be recognized by the respective Board of Directors in the following manner: 2 (Two) fully paid Equity Shares

Kifs International LLP, Ahmedabad vs. The ACIT, Circle-5(2)(1) Presently With ACIT, Central Circle-1(4), Ahmedabad

ITA 683/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 Feb 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

For Appellant: Shri Parimalsinh B. Parmar, A.RsFor Respondent: Shri Ritesh Parmar, CIT. DR & Shri
Section 143(3)Section 147Section 32Section 32(1)Section 43(6)

whose name appear in the Register of Members on the Appointed Date or to such of their respective heirs, executors, administrators or other legal representative or other successors in title as may be recognized by the respective Board of Directors in the following manner: 2 (Two) fully paid Equity Shares

Kifs International LLP, Ahmedabad vs. The ACIT, Circle-5(2)(1) Presently With ACIT, Central Circle-1(4), Ahmedabad

ITA 682/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad08 Feb 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

For Appellant: Shri Parimalsinh B. Parmar, A.RsFor Respondent: Shri Ritesh Parmar, CIT. DR & Shri
Section 143(3)Section 147Section 32Section 32(1)Section 43(6)

whose name appear in the Register of Members on the Appointed Date or to such of their respective heirs, executors, administrators or other legal representative or other successors in title as may be recognized by the respective Board of Directors in the following manner: 2 (Two) fully paid Equity Shares