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

5. Having regard to the reasons stated in the application and affidavit, and there being nothing on record to suggest that the delay was deliberate, intentional or due to any mala fide conduct on the part of the assessee, we are satisfied that the assessee was prevented by sufficient and reasonable cause from filing the appeal within the prescribed time

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

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)

5. Regarding the application of Section 115888 on the addition made concerning the source of investment in Kushal Ltd., the A.O. has wrongly invoked this section. The facts and evidence clearly indicate that there is no unaccounted or unexplained money under Sections 694 or 69 of the Income Tax Act, 1961, and no income has escaped assessment. Since there

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

139 (1) of the Act. But M/s Master Developers has filed the returns of income in response to the notice issued under section 148 of the Act, declaring the income which has been elaborated in the preceding paragraph. Indeed, the returns were filed by the M/s Master Developers subsequent to the assessment order dated 30-03-2015 declaring the income

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

139 (1) of the Act. But M/s Master Developers has filed the returns of income in response to the notice issued under section 148 of the Act, declaring the income which has been elaborated in the preceding paragraph. Indeed, the returns were filed by the M/s Master Developers subsequent to the assessment order dated 30-03-2015 declaring the income

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

139 (1) of the Act. But M/s Master Developers has filed the returns of income in response to the notice issued under section 148 of the Act, declaring the income which has been elaborated in the preceding paragraph. Indeed, the returns were filed by the M/s Master Developers subsequent to the assessment order dated 30-03-2015 declaring the income

INCOME TAX OFFICER, WARD-3(1)(1), AHMEDABAD., VEJALPUR vs. 7NR RETAIL LIMITED, NAVRANGPURA

In the result, the appeal filed by the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

139(1) of the Act, declaring total income of ₹26,35,294/-. However, based on information from a search conducted under section 132 in the case of Jignesh Shah and Sanjay Shah Group, a group which was involved in providing bogus accommodation entries, the AO reopened the assessment under section 147 of the Act. In response, the assessee re-filed

NARMADA CONCAST PRIVATE LIMITED,BHAVNAGAR vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

5. Findings of AO: The above information has been analysed personally by the undersigned. In this case, while analyzing the above information, I have reason to I.T.A No. 33/Ahd/2023 A.Y. 2013-14 Page No 9 Narmada Concast Pvt. Ltd. vs. DCIT conclude that the assessee had entered into High Value financial transactions of Rs. 1,00,00,224/- facilitating bogus

ARVIND AMBALAL PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(2)(1) (OLD WARD-5(2)(2)), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2017-18

bogus Sundry Creditors under Section 68 of the Act amounting to Rs.33,32,967/-. 4. Being aggrieved by the Assessment Order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. The Ld. AR submitted that as regards to ground no.1, the assessee has deposited the SBN of Rs.73,41,500/- during

FURNISH HOME,AHMEDABAD vs. THE ITO, WARD-3(3)(1) OLD WARD-3(3)(2), AHMEDABAD

The appeal of the asessee is allowed, whereas, Revenue’s appeal is dismissed

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

bogus. No discrepancy was pointed out either in the quantitative details of stock or in the valuation of inventory. 4. Analysis and Decision: Section 69 of the Act is attracted only where an investment is made and not recorded in the books of account maintained by the assessee. In the present case, the appellant has conclusively demonstrated that

INCOME-TAX OFFICER WARD-3(3)(1),AHMEDABAD, AHMEDABAD vs. FURNISH HOME, AHMEDABAD

The appeal of the asessee is allowed, whereas, Revenue’s appeal is dismissed

Bench: the Ld. CIT(A), wherein detailed submissions supported by the books of accounts, statutory returns, confirmation and other documentary evidences were filed. A remand report of the AO was sought on the same by the Ld. CIT(A) after considering which, Ld. CIT(A) deleted

bogus. No discrepancy was pointed out either in the quantitative details of stock or in the valuation of inventory. 4. Analysis and Decision: Section 69 of the Act is attracted only where an investment is made and not recorded in the books of account maintained by the assessee. In the present case, the appellant has conclusively demonstrated that

GANDHINAGAR DISTRICT CO.OP.MILK PRODUCERS UNION LIMITED,GANDHINAGAR vs. THE ACIT, CIRCLE GANDHINAGA, GANDHINAGAR

In the result, appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

139 (Guj) in support of the above proposition. 7. Secondly, the Ld. Counsel for the assessee argued before us that the AO has not quantified ‘amount of escapement of income chargeable to tax’: As per Clause (b) of sub-Section (1) of Section 149 of the Act, no notice under Section 148 shall be issued for an assessment year

THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. SHRI RAJENDRA J KESHWANI (HUF), AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.30/Ahd/2021 िनधा"रण वष" /Assessment Year : 2015-16 The Dcit Shri Rajendra J. Keshwani बनाम/ Central Circle-1(1) (Huf) V/S. Ahmedabad-380 009 44, Asopalav Bungalows Nr.Muktidham Jain Temple Thaltej, Ahmedabad "थायी लेखा सं./Pan: Aaehk 1973 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Kavan Limbasiya, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/02/2025 घोषणा की तारीख /Date Of Pronouncement: 18/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

bogus and added it under Section 68. 4. The CIT(A), after considering the assessee’s submissions and available documentary evidence, deleted the addition by observing that the assessee had provided complete documentary proof, including Purchase invoices, Demat account statements, Broker’s confirmation, Contract notes, Bank statements showing payment via account payee cheque and STT payment records

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

VERTOOL CONSULTANCY LLP,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

139(9) of the Act. 4. The Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi has erred in confirming the assessment order passed by the Assessing officer u/s. 143(3) r.w.s. 147 r.w.s. 144B of the Act without serving upon the appellant assessee, a notice u/s. 143(2) of the Act even though the appellant assessee

YOGESH HARGOVINDBHAI JOSHI L/H OF BHAVNABEN Y. JOSHI,AHMEDABAD vs. THE ITO, WARD-6(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar, Vice- & Ms.Suchitra R. Kambleassessment Year : 2012-13 Yogesh Hargovindbhai Joshi Vs. The Ito, Ward-6(1)(1) L/H. Of Bhavnaben Y. Joshi Ahmedabad. 8, Manav Pursusharth Society Opp: Hirabhai Tower Uttamnagar, Maninagar Pan : Adupj 2208 C (Applicant) (Responent) : Shri Parin Shah, Ar Assessee By Revenue By : Shri Abhijit, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 08/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश/O R D E R आदेश आदेश आदेश

139 of the Act for the assessment year 2012-13 on 20.7.2012 declaring total income at Rs.66,12,118/-. As per the survey conducted by Directorate of Income-tax (Investigation), Unit-2(3), Kolkatta on 13.6.2014 on Shri Rajesh Kedia and his associates, the Revenue observed that a syndicate of persons in connivance with stock-brokers and exit entry providers

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

purchases of different scripts at a value of Rs. 80,78,04,800.00 against the gross sales of ₹ 93,19,71,306.00. The assessee has also shown the closing inventory at ₹ 5,67,62,457.00. Likewise, the assessee has filed the return of income under section 139(1) of the Act declaring an income

JHAVERI TRADING AND INVESTMENT PVT.LTD.,AHMEDABAD vs. THE DCIT, CENT. CIR. 1(1), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकर अपील सं./Ita Nos. 401 To 403/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2012-2013 To 2014-2015) & आयकर अपील सं./Ita Nos. 399 & 400/Ahd/2023 "नधा"रण वष"/Asstt. Years: (2010-2011 & 2011-12)

purchases of different scripts at a value of Rs. 80,78,04,800.00 against the gross sales of ₹ 93,19,71,306.00. The assessee has also shown the closing inventory at ₹ 5,67,62,457.00. Likewise, the assessee has filed the return of income under section 139(1) of the Act declaring an income