INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

section 145(3) and applied a GP rate of 12.5%, resulting in substantial additions. The CIT(A), however, granted partial relief by restricting the GP ITA No.254 to 256 and 274 to 276 /Ahd/2024 10 rate to 6%, which has been challenged in cross appeals. Before the CIT(A), the assessee submitted that it is engaged in the business

THE DCIT, CIRCLE-8,, AHMEDABAD vs. SHIVAM WATER TREATERS PVT. LTD.,, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

145(1) is an enabling provision. It is intended to enable the Assessing Officer to make the correct assessment which is the paramount object. It is not intended to confer any right or benefit upon an erring assessee. Thus, this section is intended to make the correct assessment in compliance with the law and not to by-pass the statutory

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE ACIT, (OSD), CIRCLE-8,, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

145(1) is an enabling provision. It is intended to enable the Assessing Officer to make the correct assessment which is the paramount object. It is not intended to confer any right or benefit upon an erring assessee. Thus, this section is intended to make the correct assessment in compliance with the law and not to by-pass the statutory

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-8, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

145(1) is an enabling provision. It is intended to enable the Assessing Officer to make the correct assessment which is the paramount object. It is not intended to confer any right or benefit upon an erring assessee. Thus, this section is intended to make the correct assessment in compliance with the law and not to by-pass the statutory

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(1),, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

145(1) is an enabling provision. It is intended to enable the Assessing Officer to make the correct assessment which is the paramount object. It is not intended to confer any right or benefit upon an erring assessee. Thus, this section is intended to make the correct assessment in compliance with the law and not to by-pass the statutory

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

section 145(3) and applied a GP rate of 12.5%, resulting in substantial additions. The CIT(A), however, granted partial relief by restricting the GP rate to 6%, which has been challenged in cross appeals. Before the CIT(A), the assessee submitted that it is engaged in the business of manufacturing copper and copper-based products and had made purchases

DCIT CIRCLE-3(3), AHMEDABAD vs. SHRI ALPESHKUMAR C.PATEL, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकर अपील सं./Ita No. 1908/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2011-2012 Alpeshkumar C. Patel, A.C.I.T., 503, Milestone Building, Vs. Circle-3(3), Drive In Road, Ahmedabad. Thaltej, Ahmedabad-380052. Pan: Aeapp9489G

section 145(3) of the Act. Thereafter, the AO estimated the profit from work contract at Rs. 95,58,606/- being net profit margin of 12% on total receipt and made addition of Rs. 89,05,774/- after adjusting income of Rs. 6,52,832/- declared by the assessee from impugned labour contract. 19. On appeal by the assessee

THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. SANKALP RECREATION PVT. LTD., AHMEDABAD

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

145 are dismissed, and the CIT(A)’s order on these issues is upheld. Grounds Relating to Unaccounted Receipts and Unaccounted Expenses IT(ss)A No.64/Ahd/2022 along with 10 other appeals (By assessee and By Revenue) Sankalp recreation Pvt.Ltd. vs. ACIT. Asst. Years : 2013-14 to 2019-20 17 8. The concise grounds of both assessee and revenue are tabulated

SANKALP RECREATION PRIVATE LIMITED,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

145 are dismissed, and the CIT(A)’s order on these issues is upheld. Grounds Relating to Unaccounted Receipts and Unaccounted Expenses IT(ss)A No.64/Ahd/2022 along with 10 other appeals (By assessee and By Revenue) Sankalp recreation Pvt.Ltd. vs. ACIT. Asst. Years : 2013-14 to 2019-20 17 8. The concise grounds of both assessee and revenue are tabulated

AXIS BANK LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-1 NOW CIRCLE-1(1)(1), AHMEDABAD

In the result appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedsl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 311/Ahd/2016 2010-11 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 2. 2176/Ahd/2016 2011-12 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 3. 2173/Ahd/2016 2011-12 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 4. 165/Ahd/2017 2012-13 Axis Bank Limited, D.C.I.T., Ahmedabad. Circle-1(1)(1) Ahmedabad. Pan: Aaacu2414K 5. 287/Ahd/2017 2012-13 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 6-7 520 & 2013-14 Axis Bank Limited, D.C.I.T., 521/Ahd/2018 & Ahmedabad. Circle-1(1)(1) 2014-15 Ahmedabad. Pan: Aaacu2414K 8-9 604 & 605/ 2013-14 D.C.I.T., Axis Bank Limited, Ahd/2018 & Circle-1(1)(1) Ahmedabad. 2014-15 Ahmedabad. Pan: Aaacu2414K

3 months but less than 6 months ought to have been recognized as income under rule 6EA of Income Tax Rule. Thus the AO made the addition of Rs. 11.16 crores to the total income of the assessee. 32. Aggrieved assessee preferred an appeal to the learned CIT (A) who has also confirmed the order of the AO by observing

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

145(3) of the Act requires the AO to pinpoint specific defects that make the accounts unreliable. However, in this case, the AO’s rejection was based primarily on suspicion and unverified documentation rather than clear accounting discrepancies or statutory non-compliance. The CIT(A) ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee