PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

139(1)\n30.09.2013\n30.11.2014\n2 Returned Income in Rs.\n13,49,70,010\n1,85,84,840\n3 Notice u/s 143(2)\n04.09.2014 28.08.2015\n4 Date of Order u/s 143(3)\n28.03.2016\n28.11.2016\n5 Disallowance u/s 14A in Rs.\n9,33,104\n19,06,383\n6 Addition - Notional Interest on advance\n26,65,085\ngiven to related party

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

139(1) of the Act. It was the contention of the AO that the amount of consideration not utilized for the purpose of construction/investment in the property should have been deposited in the capital gain account scheme as required under section 54F of the Act. It was also observed by the AO that the assessee in his balance-sheet

CHIRAG ISHWARBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-3(3)(6), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1182 & 1192/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-11 Chirag Ishwarbhai Patel, I.T.O., 49 Dharamanth Prabhu Society, Vs. Ward-3(3)(6), Near Adishawar Society, Ahmedabad. Nikol Road, Naroda, Ahmedabad.

purchases from him, reopening notice against assesses was justified" 2.4. Further, the appellant has also not brought any specific evidences suggesting that this issue was considered in original Assessment Proceedings. The Hon'ble Gujarat High Court in the case of Praful Chunilal Patel v/s ACIT, 236 ITR 832 (Guj) has held as under: j "Section 147 of the Income

CHIRAG ISHWARBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-7(2)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1182 & 1192/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-11 Chirag Ishwarbhai Patel, I.T.O., 49 Dharamanth Prabhu Society, Vs. Ward-3(3)(6), Near Adishawar Society, Ahmedabad. Nikol Road, Naroda, Ahmedabad.

purchases from him, reopening notice against assesses was justified" 2.4. Further, the appellant has also not brought any specific evidences suggesting that this issue was considered in original Assessment Proceedings. The Hon'ble Gujarat High Court in the case of Praful Chunilal Patel v/s ACIT, 236 ITR 832 (Guj) has held as under: j "Section 147 of the Income

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

139(1)\n30.09.2013\n30.11.2014\n2\nReturned Income in Rs.\n13,49,70,010\n1,85,84,840\n3\nNotice u/s 143(2)\n04.09.2014\n28.08.2015\n4\nDate of Order u/s 143(3)\n28.03.2016\n28.11.2016\n5\nDisallowance u/s 14A in Rs.\n9,33,104\n19,06,383\n6\nAddition - Notional Interest on advance\n26,65,085\ngiven to related party

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

139(1)\nΑ.Υ. 2013-14\nΑ.Υ. 2014-\n15\n30.09.2013\n30.11.2014\n2 Returned Income in Rs.\n13,49,70,010\n1,85,84,840\n3 Notice u/s 143(2)\n04.09.2014\n28.08.2015\n4 Date of Order u/s 143(3)\n28.03.2016\n28.11.2016\n5 Disallowance u/s 14A in Rs.\n9,33,104\n19,06,383\n6 Addition - Notional Interest on advance

THE ACIT, CENTRAL CIRCLE-2(1), AHMEDABAD vs. M/S. DINESHCHANDRA R AGRAWAL INFRACON PVT. LTD., AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 85/Ahd/2021 िनधा"रणवष"/Asstt. Year: 2013-14

139(1) of the Act. Accordingly, the assessee has already disclosed the impugned amount of income of Rs. 11,87,02,925/- in response to the notice issued under Section 153-A of the Act. Therefore, on the same amount of income, there cannot be levied any penalty under the provisions of section 271(1

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

bogus by the Maharashtra VAT department. To our understanding, based upon the information received from the 3rd party, until and unless it is confronted to the assessee, no adverse inference can be drawn. There can be various reasons for the cancellation of the registration such as ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

bogus in nature. Nevertheless, the assessee was claiming depreciation on such fixed assets year after year including the year under consideration. However, the AO following the order of the earlier years has also disallowed the depreciation on such fixed assets at Rs. 2,74,83,963/- and added to the total income of the assessee. 113. Aggrieved assessee preferred

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

bogus in nature. Nevertheless, the assessee was claiming depreciation on such fixed assets year after year including the year under consideration. However, the AO following the order of the earlier years has also disallowed the depreciation on such fixed assets at Rs. 2,74,83,963/- and added to the total income of the assessee. 113. Aggrieved assessee preferred

HIRAL TAPANKUMAR CHUDGAR,VADODARA, GUJARAT vs. INCOME TAX OFFICER, WARD 1(3)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeal filed by the assessee in ITA No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

1. On the facts and circumstances of the case, as well as the applicable law, the learned A.O. has erred in reopening the assessment under Section 147 of the Income Tax Act, 1961, by issuing a notice under Section 148. Further, CIT(Appeals) has erred in dismissing the appeal. The reopening of the assessment is unjustified and contrary

HIRAL TAPANKUMAR CHUDGAR,VADODARA, GUJARAT vs. INCOME TAX OFFICER, WARD 1(3)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeal filed by the assessee in ITA No

Bench: Shri T.R. Senthil Kumar, Judicial Member And\nShri Makarand Vasant Mahadeokar, Accountant Member\nITA Nos 43 & 44/Ahd/2025\nAssessment Years: 2017-18 & 2018-19\nHiral Tapankumar\nChudgar\n201/A, Premdarshan,\nBehind Jay Ambe School,\nSamasavli Raod, Vemali,\nVadodara-390008,\nGujarat\nPAN: ANCPC4000H\n(Appellant)\nIncome Tax Officer\nWard-1(3)(1),\nVs Vadodara\n(Respondent)\nAssessee Represented:\nShri Deepak Shah, A.R.\nRevenue Represented:\nShri Abhijit, Sr.D.R.\nDate of hearing\n: 18-06-

bogus\naccommodation entries. Purchase was made through BSE platform.\nTransaction was through banking channel after all, Investment in share\nscrip is capital in nature. If at all one has to tax then it has to be Capital\nGain and not entire investment. For taxation of capital gain there has to be\ntransfer of capital within the meaning

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

1 to section 263. 5. The Ld. PCIT has erred, both in law and on facts, in passing an ex-parte order which is in gross violation of principles of natural justice. 6. Ld. PCIT has erred in not considering various facts, submissions, explanations clarifications furnished by assessee during the course of original assessment proceedings and further erred

SHRI BALDEVBHAI ATMARAM PATEL,,GANDHINAGAR vs. THE DY.CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR

In the result, assessee’s appeal is allowed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

139(4). Assessee filed late return, in the return of income, the assessee neither claimed any exemption u/s 54F, 54B rather he has shown only net capital gain. Such benefits were also denied to him. Further that, while calculating the capital gain, the assessee shown to have incurred expenditure of Rs.3,66,249/- towards cost of improvement

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

139(1), in the books. to section without 148. additional explanations. Show 27/03/20 To explain Furnish Filed a Cause 22 the specific response on Notice substantial documenta 29-12-2021 under credit ry evidence but did not Section transactions and provide 147 (SCN) with M/s clarificatio sufficient Orange ns evidence or Tradex Pvt. regarding clarification Ltd., flagged the source

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

139(1), in the books. to section without 148. additional explanations. Show 27/03/20 To explain Furnish Filed a Cause 22 the specific response on Notice substantial documenta 29-12-2021 under credit ry evidence but did not Section transactions and provide 147 (SCN) with M/s clarificatio sufficient Orange ns evidence or Tradex Pvt. regarding clarification Ltd., flagged the source