DY.COMMISSIONER OF INCOME TAX CIRCLE-1(3),, AHMEDABAD vs. KIFS PVT.LTD.,, AHMEDABAD

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

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

THE DY. CIT., CIRCLE-3,, AHMEDABAD vs. KHANDWALA INTEGRATED FINANCIAL SERVICES PVT. LTD, AHMEDABAD

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

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

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

6. In the light of the above discussion, we are of the view that since the assessee has demonstrated that there was sufficient reserves, share capital and interest-free advances stated to be to the tune of Rs.1988.26 lacs in A.Y. 2005-06 and Rs.1827.39 lacs for A. Y. 2006-07, then the decision of the CIT vs. Reliance Utilities

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR, AHMEDABAD vs. AIA ENGINEERING LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 397/Ahd/2024 िनधा"रण वष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Dcit Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J आयकर अपील सं / Ita No. 532/Ahd/2024 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Acit, Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" िनधा"रती की ओर से / Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar ""थ" की ओर से / Revenue By : Shri Pratik Sharma, Sr Dr & Shri Sudhendu Das, Cit-Dr तारीख/Date Of Hearing : 09.10.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 21.10.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

6) of section 43.] [Explanation 3.—For the purposes of this sub-section, the expressions "assets" and "block of assets" shall mean— (a) tangible assets, being buildings, machinery, plant or furniture; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. The above provision of section

M/S. SURZLON GLOBAL SERVICES LTD. ,AHMEDABAD vs. THE PR. CIT-3,, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 67-68/Ahd/2021 िनधा"रण वष"/Asstt. Years: 2016-2017 & 2017-2018 M/S. Suzlon Global Services Limited, Principal Commissioner 5 Suzlon, Shrimali Society, Vs. Of Income-Tax, Near Shree Krishna Centre, Ahmedabad. Nr. Judges Bunglow Cross Road, Ahmedabad-380009. Pan: Aaics1406R

6) of section 43.] 41[Explanation 3.—For the purposes of this sub-section, the expressions “assets” and “block of assets” shall mean— (a) tangible assets, being buildings, machinery, plant or furniture; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. 8.14 The above provision of section

THA ADDL. CIT, RANGE-1,, BARODA vs. M/S. GUJARAT FLUROCHEMICALS LIMITED.,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

THE ADDL.CIT, RANGE-1, BARODA vs. GUJARAT FLUOROCHEMEICALS LTD, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

GUJARAT FLUROCHEMICALS LIMITED,,BARODA vs. THE ADDL. CIT, RANGE-1,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT FLUROCHEMICALS LTD.,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

GUJARAT FLUOROCHEMEICALS LTD,,BARODA vs. THE DY.CIT.,CIRCLE-1(1)(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

GUJARAT FLUROCHEMICALS LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

GUJARAT FLUROCHEMICALS LIMITED,,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

6. Smt.Harsha N.Mehta Vs. DCIT [ 43 SOT 332 (Mumbai)] Section 28(i), read with section 45, of the Income-tax Act, 1061 - Business income - Chargeable as - Assessment year 2005-06 - During relevant assessment year, assessee filed her return showing income from sale and purchase of shares under head 'Capital Gains

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

43 5,59,73,415/-as against the returned Capital loss of Rs. 1,23,78,585/-. In view of the above detailed discussion, the AO is directed to tax on protective basis Capital Gains worth Rs.435,59,73,415/-. "Needless to mention here that during the DRP proceedings, the assesse was show caused as to why not Capital Gains

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

43 5,59,73,415/-as against the returned Capital loss of Rs. 1,23,78,585/-. In view of the above detailed discussion, the AO is directed to tax on protective basis Capital Gains worth Rs.435,59,73,415/-. "Needless to mention here that during the DRP proceedings, the assesse was show caused as to why not Capital Gains

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain