TORRENT POWER GRID LIMITED,AHMEDABAD vs. THE PR.CIT-3, AHMEDABAD

In the result, the appeal filed by the assessee is hereby allowed

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

charitable trust for which the assessee has claimed 50% of the total donation paid as deduction u/s. 800 of the Act. Prior to the Finance (No.2) Act, 2014, the said expenditure was claimed as 'business expenditure' u/s. 37(1) of the Act where after the insertion of Explanation 2 to section 37(1) of the Act, the CSR expenses referred

AIA ENGIONEERING LTD.,AHMEDABAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, AHMEDABAD-1, AHMEDABAD

In the result, the appeals filed by the assessee are hereby allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

charitable trust for which the assessee has claimed 50% of the total donation paid as deduction u/s. 800 of the Act. Prior to the Finance (No.2) Act, 2014, the said expenditure was claimed as 'business expenditure' u/s. 37(1) of the Act where after the insertion of Explanation 2 to section 37(1) of the Act, the CSR expenses referred

AIA ENGINEERING LTD.,AHMEDABAD vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, AHMEDABAD-1, AHMEDABAD

In the result, the appeals filed by the assessee are hereby allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

charitable trust for which the assessee has claimed 50% of the total donation paid as deduction u/s. 800 of the Act. Prior to the Finance (No.2) Act, 2014, the said expenditure was claimed as 'business expenditure' u/s. 37(1) of the Act where after the insertion of Explanation 2 to section 37(1) of the Act, the CSR expenses referred

SEQUEL LOGISTICS PRIVATE LIMITED,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal filed by the assessee is hereby allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

charitable trust for which the assessee has claimed 50% of the total donation paid as deduction u/s. 800 of the Act. Prior to the Finance (No.2) Act, 2014, the said expenditure was claimed as 'business expenditure' u/s. 37(1) of the Act where after the insertion of Explanation 2 to section 37(1) of the Act, the CSR expenses referred

SHRI SHAMLAJI AAROGYA SEVA TRUST,GODHRA vs. THE PR. CIT (CENTRAL), SURAT AT -VADODARA

In the result, the appeal of the Assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.138/Ahd/2022 "नधा"रण वष" /Assessment Year : 2017-18 Shri Shamlaji Aarogya Seva Trust The Pr.Cit (Central) बनाम/ Kanelav Road Surat At Vadodara Dhahod Road V/S. Godhra – 389 001 "थायी लेखा सं./Pan: अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri H. Phani Raju, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 29/08/2024 घोषणा क" तार"ख /Date Of Pronouncement: 04 /09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Passed By The Ld.Principal Commissioner Of Income Tax (Central), Surat [Hereinafter Referred To As "Pcit"] Under Section 263 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], For The Assessment Year (Ay) 2017-18, Wherein The Pcit Held That The Assessment Order Passed By The Assessing Officer (Hereinafter Referred To As “Ao”) Under Section 143(3) Of The Act, Dated 16.11.2019, Was Erroneous & Prejudicial To The Interests Of

u/s. 264 of the Act to avoid double taxation. ITA No.138/Ahd/2022. Shri Shamlaji Aarogya Seva Trust vs. The Pr.CIT(Central) Asst. Year : 2017-18 8 7. We have heard the rival contentions and perused the material available on records. Section 263 of the Act empowers the Ld.PCIT to revise any assessment order if it is erroneous and prejudicial

SHALBY LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Years: 2020-21

revision proceedings. The A.O after examining the evidences and other material considering the same after due application of mind has passed the assessment order 4 The Learned Pr Commissioner of Income Tax, Ahmedabad 3 has erred in invoking revisionary powers u/s 263 of the Act for making disallowance of Donation of Rs.3 Crores given to political parties claimed

SHRI JAIN MEDICAL & EDUCATIONAL TRUST,BHUJ vs. ACIT(EXEMPT), CIRCLE-2, AHMEDABAD

The appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalshri Jain Medical & The Asstt. Commissioner Of Vs. Educational Trust, Income Tax (Exemption), C/O Sarda & Sarda (Ca), Circle-2, Sakar 1St Floor, Dr.Radha- Ahmedabad Krishnan Road, Opp. Rajkumar College, Rajkot-360001 [Pan :Aaatj 1467 C] (Appellant) .. (Respondent) Appellant By : Adjournment Application Filed Respondent By: Shri Prateek Sharma, Sr. Dr Date Of Hearing 05.08.2025 Date Of Pronouncement .08.2025

charitable trust registered u/s 12A of the Act and approved u/s 80G of the Act. The trust is engaged in imparting education and running various educational institutions. The assessee filed its return of income for the year under consideration on 13.11.2018, declaring total income at Rs. Nil after claiming exemption u/s 11 of the Act. The case was selected

SURAT URBAN DEVELOPMENT AUTHORITY,SUDA BHAWAN, NANPURA vs. CIT(EXEMPTION), AHMEDABAD, AAYKAR BHAWAN (VEJALPUR)

In the result, the appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2018-19 Surat Urban Development The Cit(Exemption) Authority (Suda) Vs Vejalpur, Ahmedabad. Suda Bhawan Nanpura, Surat. Pan : Aaals 0197 G (Applicant) (Responent) Assessee By : Shri Rasesh Shah, Ar : Shri Prathvi Raj Meena, Cit Revenue By सुनवाई की तारीख/Date Of Hearing : 08/01/2025 घोषणा की तारीख /Date Of Pronouncement: 02/04/2025 आदेश/O R D E R

u/s 143(3) r.w.s 144B of the Income tax Act, by accepting the return of income of Rs.Nil prima facie appeared to be erroneous and prejudicial to the interest of the revenue within the meaning of Section 263 of the Income tax Act, 1961.” 5. Accordingly jurisdiction under section 263 of the Act was assumed by the ld.Pr.CIT for revision

THE DY. COMMR. OF INCOME TAX, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. JAMNAGAR AREA DEVELOPMENT AUTHORITY, JAMNAGAR

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Smt. Madhumita Roy

263 of the Act 2428/Ahd/2017 -Do- 2014-15 -Do- -Do- 143(3) of the Act 2. The issue involved being common in all the four appeals filed by the Revenue, all such appeals were heard together and disposed of by the common order. 3. We shall adopt the facts concerning AY 2009-10 in ITA No. 2425/Ahd/2017 for the purposes

LALITADEVI N. TIBREWALA,,AHMEDABAD vs. THE PR. CIT, , AHMEDABAD

In the result, the appeal of the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 318/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2012-2013 Lalitadevi N. Tibrewala, Pr. Commissioner Of 6, Professor Colony, Vs. Income Tax, Nr. Vijay Cross Roads, Ahmedabad-5 Navrangpura, Ahmedabad-380009. Pan: Aappt0073M

Charitable Trust v. Dy. CIT reported in 280 ITR 357 has held that : “3. The Supreme Court in Vedabai v. Shantaram Baburao Patil [2002] 253 ITR 798held as under : "In exercising discretion under section 5 of the Limitation Act the Courts should adopt a pragmatic approach. A distinction must be made between a case where the delay is inordinate

GUJARAT FISHERIES CENTRE CO .OPERATIVE ASSOCIATION LIMITED,,AHMEDABDA vs. ITO, WRAD-5(2)(2),, AHMEDABAD

In the result, the appeal of the assessee is dismissed

revision u/s 263 of The Income tax Act, 1961. 2. The learned Pr. CIT has erred in law and in facts in Assessing the Total Income at Rs. 1,02,11,170/- as against the originally assessed income of Rs. 1,06,410/- 3. The learned Pr. CIT has erred in law and in facts in rejecting the claim

GUJARAT ROHIT SAMAJ TRUST,AHMEDABAD vs. DCIT, CPC, BANGALORE

In the result the appeal filed by the assessee is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.2161/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2015-16 Gujarat Rohit Samaj Trust, D.C.I.T, 33, New Chandranagar Society, Vs. Cpc, B/H Supath-Ii, Bangalore. Union Bank Old Wadaj, Ahmedabad-380013. Pan: Aaatg7340R

charitable trust and not a Association of Person (A.O.P) as treated by Dy CIT(CPC)/Banglore as well as Hon'ble CIT(A)-9/A'bad which is erroneous and unjustifiable. 3) That the Dy CIT (CPC), Banglore has passed the order u/s 143(1) of the I T Act determined total income of Rs 82,360/- which is below

SAKAR HEALTHCARE LTD.,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result both the appeals of the assessee are dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

263 of the LT. Act, 1961 since the issues sought to be revised have been examined in the assessment proceedings hence the same being illegal and bad in law requires to be quashed. 3. The Learned Pr. Commissioner of Income-Tax, Ahmedabad -3 has erred in not appreciating the fact that all information and related material and evidences had been

SAKAR HEALTHCARE LTD.,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result both the appeals of the assessee are dismissed

Bench: us in both the appeals and for the sake of convenience we are reproducing grounds raised in ITA No.1172/Ahd/2025 pertaining to A.Y. 2020-21:

263 of the LT. Act, 1961 since the issues sought to be revised have been examined in the assessment proceedings hence the same being illegal and bad in law requires to be quashed. 3. The Learned Pr. Commissioner of Income-Tax, Ahmedabad -3 has erred in not appreciating the fact that all information and related material and evidences had been

IDEAL SHEET METAL STAMPINGS AND PRESSINGS PRIVATE LIMITED,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

charitable trust was examined and inquired by the Id AO and based on evidences and reply by the appellant, the deduction u/s.80G was rightly allowed. The provisions of Ideal Sheet Metal Stampings & Pressings Pvt. Ltd, vs. PCIT-1 Page 3 of 7 section 263 to revise the said assessment order are wrongly invoked. It be so held

KALPESH DHANJIBHAI MAKASANA,SURENDRANAGAR vs. PR. CIT, AHMEDABAD-3, AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Charitable Trust, Wadhwan through banking channel and also furnished other details as required by the assessing officer. On due verification of the details, the assessing officer accepted the Returned Income and passed the assessment order u/s 143(3) dated 20-09-2022. Perusal of the above assessment order, Ld. PCIT found that the assessee had shown income from salary

GUJARAT MINERAL DEVELOPMENT CORPORATION LIMITED,KHANJI BHAVAN vs. PR. COMMISSIONER OF INCOME TAX-1, AAYAKAR BHAWAN(VEJALPUR), AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21

U/s 263 of The Income Tax Act, 1961 dated 07/03/2025. 2. Your appellant craves leave to add, to alter or to amend the grounds of appeal if occasion arises. 7. The learned Authorised Representative (AR) vehemently opposed the assumption of jurisdiction by the PCIT under section 263 of the Act and submitted that the assessment order was neither erroneous

GUJARAT TECHNOLOGICAL UNIVERSITY,AHMEDABAD, VADODARA. vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 EXEMPTIONS, AHMEDABAD, GUJARAT.

In the result, the appeal of the assessee is allowed

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1187/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-10 Gujarat Technological University, The Dcit, Nr. Vishwakarma Govt. Engg. College, बनाम/ Circle-1, V/S. Near Visar Three Roads, Exemptions, Chandkheda Society Area S.O, Ahmedabad Gandhinagar, Ahmedabad-382424. (Gujarat) "थायी लेखा सं./Pan: Aaalg1109L अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Ms. Amrin Pathan, Ar Revenue By : Shri Rignesh Das, Sr-Dr सुनवाई की तारीख/Date Of Hearing : 14/08/2025 घोषणा की तारीख /Date Of Pronouncement: 19/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “The Cit(A)”] Dated 14.03.2025, For The Assessment Year (A.Y.) 2019–20, Arising Out Of The Rectification Order Passed By The Centralized Processing Centre (Cpc), Bengaluru, Under

revised return, both before the CIT(E), Ahmedabad, on 05.02.2024 and before the CBDT on 12.02.2024. The CIT(E) rejected the condonation application vide order dated 16.02.2024 passed under section 119(2)(b). 8. The CIT(A) recorded that the sole issue in appeal was the rejection of the claim of exemption under section 11 in the rectification order