THE ACIT, CIRCLE-3,, AHMEDABAD vs. KIFS SECURITIES LIMITED,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3),, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

KIFS SECURITIES PVT. LTD.,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

1 and therefore, disallowance under section 14A was justified. 7. We do not find any merit in this submission. Judgment of this Court in Abhishek Industries (supra) was on the issue of allowability of interest paid on loans given to sister concerns, without interest. It was held that deduction for interest was permissible when loan was taken for business purpose

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 relevant provisions of law, the learned A.O. has erred in reopening the assessment under Section 147 of the Income Tax Act, 1961, by issuing notice under Section 148 of the Act. Further CIT(Appeals) has erred in dismissing the appeal. The reopening of the assessment is unjustified

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-

capital gain of Rs.29,55,558/-\nfrom the security transaction in Kushal Ltd. and Rs 4,26,069/- for the\npurchase transaction treated as unexplained investment. The facts and\nevidence clearly demonstrate that there is no unexplained money or\ninvestment under Sections 69A or 69 of the Income Tax Act, 1961, and no\nincome has escaped assessment. Further CIT(Appeals

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEHAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

149 taxmann.com 399/293 Taxman 141/454 ITR 212 (SC) ii. Pr.CIT-4 v. Saumya Construction (P) Ltd., (2016) 387 ITR 529 (Guj- HC) iii. CIT vs. Kabul Chawla, [2016] 380 ITR 573 (Del HC) 50 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. 53. The Ld. Sr. Counsel further