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

RUDRA GLOBAL INFRA PRODUCTS LTD.,BHAVNAGAR vs. THE ACIT, CIRCLE-1, BHAVNAGAR

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

147 of the Act. Under the facts and circumstances of the case, the action of reopening is without jurisdiction and in not permissible either in law or on facts. 2. The Ld. CIT(A) has erred in law and on facts of the case in upholding the disallowance of alleged bogus purchases of Rs. 39,00,60,232/- made

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

section 147 of the Act based on information received from the Investigation Wing of the Department, indicating that the assessee had entered into transactions with accommodation entry providers, including M/s. RCI Industries and Technologies Ltd. and others. It was further revealed during the proceedings that the assessee had made purchases from entities flagged in GST investigations as bogus

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

purchases from entities flagged in GST investigations as bogus suppliers. The Assessing Officer (AO) issued notice under section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s. 147

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

purchases from entities flagged in GST investigations as bogus suppliers. The Assessing Officer (AO) issued notice under section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s. 147

INCOME TAX OFFICER, WARD-1(8), 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

purchases from entities flagged in GST investigations as bogus suppliers. The Assessing Officer (AO) issued notice under section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s. 147

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

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

section 147 of the Act based on information received from\nthe Investigation Wing of the Department, indicating that the\nassessee had entered into transactions with accommodation\nentry providers, including M/s. RCI Industries and Technologies\nLtd. and others. It was further revealed during the proceedings\nthat the assessee had made purchases from entities flagged in\nGST investigations as bogus

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

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

purchases from entities flagged in\nGST investigations as bogus suppliers. The Assessing Officer\n(AO) issued notice under section 148 and framed the\nreassessment under section 143(3) r.w.s. 147

THE ITO, WARD-1(2)(3), AHMEDABAD vs. MOHAMMEDARIF IBRAHIMBHAI SHAIKH, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

147 of the Act. The case in hand is nothing but mere change of opinion. Thus, respectfully relying upon the ratio laid down by the Hon’ble Apex Court in the absence of any tangible material the reopening of assessment is found to be not sustainable in law and thus hereby quashed. ITA No. 1115/Ahd/2019 (A.Y. 2012-13):- 13. Once

THE ITO, WARD-1(2)(3), AHMEDABAD vs. MOHAMMEDARIF IBRAHIMBHAI SHAIKH, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

147 of the Act. The case in hand is nothing but mere change of opinion. Thus, respectfully relying upon the ratio laid down by the Hon’ble Apex Court in the absence of any tangible material the reopening of assessment is found to be not sustainable in law and thus hereby quashed. ITA No. 1115/Ahd/2019 (A.Y. 2012-13):- 13. Once

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT TERCE LABORATORIES LTD.,, AHMEDABAD

The appeal of the Revenue are allowed

147 of the Act for the said year. 2. It was common ground that identical issue was involved in all the appeals, relating to disallowance of sales promotion expenses incurred by the assessee. It was pointed out that the said disallowances was made in identical set of facts and circumstances finding the expenses to be bogus and the Ld.CIT

THE ITO, WARD-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT TERCE LABORATORIES LTD.,, AHMEDABAD

The appeal of the Revenue are allowed

147 of the Act for the said year. 2. It was common ground that identical issue was involved in all the appeals, relating to disallowance of sales promotion expenses incurred by the assessee. It was pointed out that the said disallowances was made in identical set of facts and circumstances finding the expenses to be bogus and the Ld.CIT

THE ITO, WARD-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT TERCE LABORATORIES LTD.,, AHMEDABAD

The appeal of the Revenue are allowed

147 of the Act for the said year. 2. It was common ground that identical issue was involved in all the appeals, relating to disallowance of sales promotion expenses incurred by the assessee. It was pointed out that the said disallowances was made in identical set of facts and circumstances finding the expenses to be bogus and the Ld.CIT

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

section 147 of the Act. We shall first discuss the Revenue’s ground of appeal. 7. Before us, the Ld. DR submitted that from the instant set of facts, it is very clear that it is a case of bogus sub- contracting expenses created by the assessee. He submitted that as per the statements which were recorded

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

section 147 of the Act. We shall first discuss the Revenue’s ground of appeal. 7. Before us, the Ld. DR submitted that from the instant set of facts, it is very clear that it is a case of bogus sub- contracting expenses created by the assessee. He submitted that as per the statements which were recorded

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRATECH TRANSMISSION PVT. LTD, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

section 147 of the Act. We shall first discuss the Revenue’s ground of appeal. 7. Before us, the Ld. DR submitted that from the instant set of facts, it is very clear that it is a case of bogus sub- contracting expenses created by the assessee. He submitted that as per the statements which were recorded

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

section 147 of the Act. We shall first discuss the Revenue’s ground of appeal. 7. Before us, the Ld. DR submitted that from the instant set of facts, it is very clear that it is a case of bogus sub- contracting expenses created by the assessee. He submitted that as per the statements which were recorded