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.

234D of the Act s to be computed as per law and facts on the record. 4. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 3. The first issue raised by the Assessee is that the Ld. CIT-A erred in holding the assessment framed under section 143(3) read

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.

234D of the Act s to be computed as per law and facts on the record. 4. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 3. The first issue raised by the Assessee is that the Ld. CIT-A erred in holding the assessment framed under section 143(3) read

SOHIL ABDULKADARBHAI PIRWANI,BHAVNAGAR vs. THE ITO, WARD-1(8), BHAVNAGAR

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

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblesohil Abdulkadarbhai Pirwani, Income Tax Officer, Vs. 31 Adamjinagar Nari Cross Ward-1(8), Road, Bhavnagar. Vartej Bhavnagar, Bhavnagar-364002. Gujarat. [Pan :Ahopp6706 D] (Appellant) .. (Respondent) Appellant By : Shri Mohit Balani, Ar Respondent By: Shri B.P Srivastava, Sr. Dr Date Of Hearing 25.09.2025 Date Of Pronouncement 26.09.2025

Section 144B of the Act. 4. The Learned CIT(A) erred in law by failing to consider that the Ld. AO did not appreciate or consider various pieces of evidence and supporting documents available on record during the assessment proceedings. Further, the Ld. AO failed to properly analyze the relevant facts and legal provisions in the correct perspective and legal

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1)(1),, VADODARA vs. GUJARAT URJA VIKAS NIGAM LTD.,, BARODA

In the result, appeal I.T

bogus payment to them. In our case the payments are not in dispute and we have actually made payment of the expenditure. Reliance is also placed on the decision of ITAT Jaipur in case of Jaipur Vidyut Vitran Nigam Ltd. Vs. ITO (TDS) wherein the said views have affirmed by the Tribunal. Hence the provisions of section

GUJARAT URJA VIKAS NIGAM LTD.,,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

In the result, appeal I.T

bogus payment to them. In our case the payments are not in dispute and we have actually made payment of the expenditure. Reliance is also placed on the decision of ITAT Jaipur in case of Jaipur Vidyut Vitran Nigam Ltd. Vs. ITO (TDS) wherein the said views have affirmed by the Tribunal. Hence the provisions of section

DIPAKKUMAR PUSHKARRAY VYAS,AHMEDABAD vs. THE ITO, WARD-1(3)(1), AHMEDABAD

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

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2012-13

sections i.e. 234A, 234B,234C and 234D deserves to be deleted. I.T.A No. 105/Ahd/2025 Dipakkumar Pushkarray Vyas, A.Y. 2012-13 [22] That the appellant craves leave to add, amend or alter any of the grounds of appeal It is therefore prayed that the addition of Rs.41,99,500/- made by the Assessing officer should be deleted.” 3. The assessee filed

LKS BULLION (IMPORT AND EXPORT) PVT.LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(3), AHMEDABAD

In the result, the appeal by Assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.382/Ahd/2022 "नधा"रण वष" /Assessment Year : 2010-11 L.K.S. Bullion (Import & The Income Tax Officer बनाम/ Export) Pvt.Ltd. Ward-2(1)(3) 368, Lks House, Ahmedabad – 380 014 V/S. Khetarpal-Ni-Pole Manek Chowk Ahmedabad -380 001 (Gujarat) "थायी लेखा सं./Pan: Aaacl 7369 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar Revenue By : Shri Alpesh Parmar, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 05/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 08/08/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Dated 27/08/2022 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Ld.Cit(A)” In Short] Arising Out Of The Assessment Order Dated 18/12/2017 By The Assessing Officer (Ao) Under Section 143(3) R.W.S. 147 Of The Income L.K.S. Bullion (Import & Export) Pvt.Ltd. Vs. Ito Asst. Year : 2010-11

234D of the Act is unjustified. L.K.S. Bullion (Import and Export) Pvt.Ltd. vs. ITO Asst. Year : 2010-11 5 7. Initiation of penalty proceedings u/s 271 (1)(c) of the Act is unjustified.” On Ground No. 1 5. During the course of hearing before us, the Ld. Sr.Counsel for the assessee, took us through the detailed submission and order

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT LTD,WEST BENGAL vs. CENTRAL CIRCLE 2(3)AHMEDABAD, AHMEDABAD

In the result, Ground Nos

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

JET AIR AGENCIES PVT. LTD,WEST BENGAL vs. THE ACIT, CENTRA CIRCLE-2(3), AHMEDABAD

In the result, Ground Nos

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

234D & 244A the appellant wholly denied the payment of such liability in consequences of addition. ITA Nos.1594 to 1597/Ahd/2019 & 685/Ahd/2023 Jet Air Agencies Pvt. Ltd. vs. ACIT Asst.Years– 2010-11 to 2012-13 9. That the Commissioner of Income Tax (Appeal) erred on facts and in law in initiating issue of notice u/ 274 of the Act to initiate penalty

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRASPACE PRIVATE LIMITED,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

234D of the Act is unjustified. 10. Initiation of penalty proceedings u/s 271(l)(c) of the Act is unjustified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 49. The first issue raised by the assessee

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRA SPACE PRIVATE LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

234D of the Act is unjustified. 10. Initiation of penalty proceedings u/s 271(l)(c) of the Act is unjustified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 49. The first issue raised by the assessee

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRA SPACE PRIVATE LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

234D of the Act is unjustified. 10. Initiation of penalty proceedings u/s 271(l)(c) of the Act is unjustified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 49. The first issue raised by the assessee

JAS INFRASPACE PVT. LTD.,AHMEDABAD vs. DCIT, CIRCLE-2(2)(1),, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

234D of the Act is unjustified. 10. Initiation of penalty proceedings u/s 271(l)(c) of the Act is unjustified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 49. The first issue raised by the assessee

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

234D is not justified. 9 Initiation of penalty u/s 271(1)(c) of the Act is not justified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 45. The assessee vide letter dated

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

234D is not justified. 9 Initiation of penalty u/s 271(1)(c) of the Act is not justified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal.” 45. The assessee vide letter dated

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

purchases & sale prices are accepted, the parties are independent and not related to the assessee u/s.40A(2)(b) of the Act and there was no evidence that suppressed sale price difference came back to the assessee, the loss on sale could not be disallowed as loss arising from sham transaction or as bogus loss. Hence, the addition made