ESPEE PHARMA CHEM PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-2(1)(1), AHMEDABAD

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

Bench: Ms. Suchitra Raghunath Kamble & Shri Narendra Prasad Sinhaassessment Year:2019-20

section 151A of the Act, thereby making the entire proceedings and resultant impugned orders void ab initio. Espee Pharma Chem Pvt Ltd vs.ITO, A.Y 2019-20 3 3. In confirming the addition made of Rs. 42,95,000/- towards bogus purchase u/s 69C by passing an order u/s 148 of the Act, without providing the approval granted

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby\nallowed

153C of the Act as\nproceedings have been initiated based upon documents found during the\ncourse of search at the premises of third party.\n4. In law and in the facts and circumstances of the appellant's case, the\nLd. CIT(A) has erred in upholding addition of alleged unexplained unsecured\nloan for Rs.40,02,325/- when appellant has established

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

153C of the Act as proceedings have been initiated based upon documents found during the course of search at the premises of third party. 4. In law and in the facts and circumstances of the appellant's case, the Ld. CIT(A) has erred in upholding addition of alleged unexplained unsecured loan for Rs.40,02,325/- when appellant has established

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

153C of the Act as proceedings have been initiated based upon documents found during the course of search at the premises of third party. 4. In law and in the facts and circumstances of the appellant's case, the Ld. CIT(A) has erred in upholding addition of alleged unexplained unsecured loan for Rs.40,02,325/- when appellant has established

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

153C of the Act as proceedings have been initiated based upon documents found during the course of search at the premises of third party. 4. In law and in the facts and circumstances of the appellant's case, the Ld. CIT(A) has erred in upholding addition of alleged unexplained unsecured loan for Rs.40,02,325/- when appellant has established

XCELRIS LABS LIMITED,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, appeal filed by the assessee is dismissed

section 43(1) of the I.T Act.\nIt is therefore prayed that impugned penalty order may please\nbe cancelled.\n5.\nThe learned Commissioner of Income Tax (Appeals) grossly\nerred in law and on facts of the case in confirming the action\nof the AO in imposing the impugned penalty with respect to the\naddition/disallowance of appellants legitimate claim of\ndepreciation

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

bogus in the hands of the borrower. Lenders like Hafsabibi Suleman Kothi and Abedabibi Mehboob Foda are close relatives of the promoters. The fact that they may show lower annual income in their tax returns does not preclude them from having accumulated capital or savings from various sources or from group entities like AK Traders. The bank statements of these

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

bogus in the hands of the borrower. Lenders like Hafsabibi Suleman Kothi and Abedabibi Mehboob Foda are close relatives of the promoters. The fact that they may show lower annual income in their tax returns does not preclude them from having accumulated capital or savings from various sources or from group entities like AK Traders. The bank statements of these

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

bogus in the hands of the borrower. Lenders like Hafsabibi Suleman Kothi and Abedabibi Mehboob Foda are close relatives of the promoters. The fact that they may show lower annual income in their tax returns does not preclude them from having accumulated capital or savings from various sources or from group entities like AK Traders. The bank statements of these

SHAH RAKESH BHIKHABHAI (HUF),AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

153C However, it cannot be utilised as a colourable device to reassess the assessee De Novo under the garb of provisions of section 263. The revenue cannot be granted license to reassess the assessee again and again upon the same issue in a time barred assessment which is already concluded by the assessing officer after applying his mind and conducting

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)

153C of the Act. 1.2 Having regard to the facts and circumstances of the appellant's case, the Hon'ble ITAT may please hold the assessment order u/s. 147 to be invalid. I.T.A No. 33/Ahd/2023 A.Y. 2013-14 Page No 5 Narmada Concast Pvt. Ltd. vs. DCIT 2. In law and in the facts and circumstances of the appellant

ROHIT PRAKASHCHANDRA SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(2)(3),, AHMEDABAD

In the result, appeal preferred by the assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2014-15

153C of the Act. Further, the Hon’ble Supreme Court has held in the case of Abhisar Builders P Ltd. (150 taxmann.com 257) that the proceeding under Section 147/148 of the Act can be initiated in order to consider the documents seized in the course of search. Therefore, this objection of the assessee is rejected. Rohit Prakashchandra Shah

HASMUKH UGARCHAND GADHECHA, HUF,AHMEDABAD vs. THE ITO, WARD-5(2)(2), AHMEDABAD

The appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.591/Ahd/2025 िनधा"रण वष" /Assessment Year : 2013-14 Hasmukh Ugarchand The Ito बनाम/ Gadhecha, Huf Ward-5(2)(2) V/S. 3Rd Floor, Anjalee House Ahmedabad – 380 015 Cg Road Navrangpura Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aaahg 7194 K (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Hargovind Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/11/2025 घोषणा की तारीख /Date Of Pronouncement: 09/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 26/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2013-2014. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Hasmukh Ugarchand Gadhecha, Huf Vs. Ito Asstt.Year : 2013-14 2 “1. That The Ld.Cit(A) Erred In Law & In The Facts Of The Case In Confirming The Order Of The Ao In Reopening Assessment U/S.147 Of The Act.

bogus purchases, was under the circumstances, was examined by the AO. Further, the said addition made on account of low GP rate was confirmed by the Ld.CIT(A), however the same stood deleted by the ITAT in further appeal. Therefore, the aforesaid issue of low GP having been examined during the original assessment proceedings, it cannot be said that

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYKAR BHAWAN ASHRAM ROAD, AHMEDABAD vs. SURESHKUMAR PERIWAL (PAN AFTPP6547D, AHEMDABAD

In the result, both the appeals of the Revenue are dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kambleit(Ss)A No. 153/Ahd/2023 (Assessment Year: 2017-18) Sureshkumar Periwal Deputy Commissioner Of Vs. Prop. Of M/S. Shyam Bullion, Income-Tax, 113, First Floor, National Central Circle-1(2), Plaza, Opp. Lal Bungalows, Ahmedabad Cg Road, Ahmedabad [Pan : Aftpp 6547 D] (Appellant) .. (Respondent) Sureshkumar Periwal Deputy Commissioner Of Vs. Prop. Of M/S. Shyam Bullion, Income-Tax, 113, First Floor, National Central Circle-1(2), Plaza, Opp. Lal Bungalows, Ahmedabad Cg Road, Ahmedabad [Pan : Aftpp 6547 D] (Appellant) .. (Respondent) Appellant By: Shri V. Nandakumar, Cit-Dr & Shri Kavan Limbasiya, Sr. Dr Respondent By : Shri Biren Shah, Ar Date Of Hearing 12.03.2025 Date Of Pronouncement 22.04.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

153C of the Act as on 31.12.2019 determining the total income of assessee at Rs.1,03,56,890/-, by making an addition of Rs.87,90,500/- u/s. 68 of the Act on account of unexplained credit in the books of accounts. 4. Meanwhile, a survey under section 133A of the Act was carried out at the business premises

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

153C of the Act. 2. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi has erred in confirming the order passed by the Assessing Officer u/s. 143(3) r.w.s.147 r.w.s.144B of the Act which is illegal and bad in law. 3. The Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi has erred