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16 results for “condonation of delay”+ Permanent Establishmentclear

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Chennai136Karnataka128Delhi126Mumbai109Kolkata49Jaipur45Amritsar37Hyderabad34Cochin30Bangalore28Pune17Ahmedabad16Cuttack15Raipur14Guwahati14Lucknow13Indore10Chandigarh7Surat7Rajkot6SC6Telangana5Rajasthan5Varanasi4Jodhpur3Nagpur3Visakhapatnam1Calcutta1Andhra Pradesh1Orissa1Patna1Allahabad1

Key Topics

Section 27136Section 12A(1)(ac)11Section 143(3)11Addition to Income10Section 271(1)(c)9Condonation of Delay9Section 12A8Section 2748Penalty

M/S. JOY GLOBAL (UK) LTD. (FORMERLY AS JOY MINING MACHINERY LTD.),KOLKATA vs. THE DCIT (INT. TAXA.)-1, AHMEDABAD

In the result, we allow the Grounds of Appeal of the assessee

ITA 16/AHD/2021[2017-18]Status: DisposedITAT Ahmedabad21 Sept 2022AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri Bandish Soparkar, AR &For Respondent: Shri Alok Kumar, CIT DR
Section 143(1)Section 143(3)Section 144C(13)Section 234BSection 44DSection 9(1)(vi)Section 92E

Permanent Establishment of the assessee company in India for A.Y. 2017-18. The said payment was made to the assessee company by SECL for maintenance spares which is taxable under Section 44DA of the Act read with Article 13(6) read with Article 7 of the India-UK DTAA. In the meanwhile, the assessee after receiving Draft Assessment Order under

7
Section 2506
Transfer Pricing6
Section 9(1)(vi)5

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1391/AHD/2019[2009-10]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2009-10
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

condone the delay of 880 days of the Department in filing CO before us. Accordingly, CO filed by the Department is hereby dismissed. 15. In the result, CO filed by the Department is hereby dismissed. 16. In the result, for assessment year 2007-08, appeal of the assessee is allowed and CO filed by the Department is dismissed. Assessment Year

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1390/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2008-09
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

condone the delay of 880 days of the Department in filing CO before us. Accordingly, CO filed by the Department is hereby dismissed. 15. In the result, CO filed by the Department is hereby dismissed. 16. In the result, for assessment year 2007-08, appeal of the assessee is allowed and CO filed by the Department is dismissed. Assessment Year

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1392/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2010-11
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

condone the delay of 880 days of the Department in filing CO before us. Accordingly, CO filed by the Department is hereby dismissed. 15. In the result, CO filed by the Department is hereby dismissed. 16. In the result, for assessment year 2007-08, appeal of the assessee is allowed and CO filed by the Department is dismissed. Assessment Year

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

ITA 1389/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad13 Oct 2022AY 2007-08
For Appellant: Shri S.N. Soparkar, Shri Parin ShahFor Respondent: None
Section 250Section 271Section 271(1)(c)Section 274

condone the delay of 880 days of the Department in filing CO before us. Accordingly, CO filed by the Department is hereby dismissed. 15. In the result, CO filed by the Department is hereby dismissed. 16. In the result, for assessment year 2007-08, appeal of the assessee is allowed and CO filed by the Department is dismissed. Assessment Year

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

delay of 86 days is condoned, and the appeal is admitted for adjudication on merits. Brief Facts of the Case 4. The assessee company, Atul Ltd., is engaged in the business of manufacturing dyes, specialty chemicals, agrochemicals, bulk drugs, commodity chemicals, and power generation. For AY 2017–18, the assessee filed its return of income on 29.11.2017 declaring total income

MAA SHARDA KOTHARI FOUNDATION,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 93/AHD/2025[NA]Status: DisposedITAT Ahmedabad15 Jul 2025

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : - Maa Sharda Kothari Foundation Commissioner Of 7, Mahavir Bungalows Vs. Income Tax Nr.Prernatirth Derasar (Exemption) Jodhpur Gam Vejalpur Ahmedabad 380 015. Ahmedabad. Pan : Aaatm 7202 Q (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By Revenue By : Shri Rignesh Das, Cit-Dr

For Respondent: Shri Rignesh Das, CIT-DR
Section 12ASection 12A(1)(ac)

delay of 319 days in filing the appeal is hereby condoned, and the appeal is admitted for adjudication on merits. 3 Facts of the Case 5. The assessee is a registered public charitable trust established under a trust deed and duly registered on 31.05.2002. The trust bears Registration or Incorporation No. E/15324/AHMEDABAD and is stated to be engaged in charitable

KRIPALU MUNI MANDAL TRUST,KALOL,PANCHMAHAL vs. CIT (EXEMPTION), AHMEDABAD

In the result, both the appeals filed by the assessees are allowed for statistical purposes

ITA 1607/AHD/2025[2025-26]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2025-26

Bench: Ms.Suchitra Raghunath Kamble & Makarand V.Mahadeokarasstt.Year : 2025-26 Kripalu Muni Mandal Trust The Ito, Ward At Malav, Taluka Kalol Vs. Exemption. Dist: Panchmahal. Vadodara. Pan : Aaatk 7859 F Asstt.Year : 2025-26 Shri Kripalu Samadhi Mandir Trust The Ito, Ward At, Post Malav Taluka Kalol Vs Exemption. Malav, Kalol. . Vadodara. Pan : Aapts 9485E (Applicant) (Responent) : Shri Nishit Shah, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Rignesh Das, CIT-DR
Section 10Section 12ASection 12A(1)(ac)Section 80G(5)(iv)

delay of 85 days in both appeals is hereby condoned. ITA No.1607 and 1608/Ahd/2025 3 3. Facts of the Cases: 3.1 Both the assessees, namely Kripalu Muni Mandal Trust and Shri Kripalu Samadhi Mandir Trust, are long-standing charitable institutions registered under section 12A of the Act, since 2004, and engaged in charitable and religious activities. Consequent to the amendment

SHRI KRIPALU SAMADHI MANDIR TRUST,KALOL vs. THE CIT (EXEMP), AHMEDABAD

In the result, both the appeals filed by the assessees are allowed for statistical purposes

ITA 1608/AHD/2025[2025-26]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2025-26

Bench: Ms.Suchitra Raghunath Kamble & Makarand V.Mahadeokarasstt.Year : 2025-26 Kripalu Muni Mandal Trust The Ito, Ward At Malav, Taluka Kalol Vs. Exemption. Dist: Panchmahal. Vadodara. Pan : Aaatk 7859 F Asstt.Year : 2025-26 Shri Kripalu Samadhi Mandir Trust The Ito, Ward At, Post Malav Taluka Kalol Vs Exemption. Malav, Kalol. . Vadodara. Pan : Aapts 9485E (Applicant) (Responent) : Shri Nishit Shah, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Rignesh Das, CIT-DR
Section 10Section 12ASection 12A(1)(ac)Section 80G(5)(iv)

delay of 85 days in both appeals is hereby condoned. ITA No.1607 and 1608/Ahd/2025 3 3. Facts of the Cases: 3.1 Both the assessees, namely Kripalu Muni Mandal Trust and Shri Kripalu Samadhi Mandir Trust, are long-standing charitable institutions registered under section 12A of the Act, since 2004, and engaged in charitable and religious activities. Consequent to the amendment

BRIJESHKUMAR NATVARLAL PATEL,AHMEDABAD vs. ITO, WARD-1(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1333/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Nov 2025AY 2015-16

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Parin Shah, ARFor Respondent: Smt. Mamta Singh, Sr.DR
Section 148Section 234ASection 250Section 250(6)Section 271(1)(c)Section 69A

condonation of the delay submitting that he had permanently shifted to Florida, USA in 2001 and he was running a convenience store at a gas station. That he had become an American citizen in ITA No. 1333/Ahd/2025 [Brijeshkumar Natvarlal Patel vs. ITO] A.Y. 2015-16 - 4 – 2009 and as per the Indian Taxation Laws, he was an NRI since then

INTERNATIONAL EDUCATION & RESEARCH FOUNDATION,AHMEDABAD vs. THE DCIT, INT-TAXA-1, AHMEDABAD

In the result, the issue is restored to the file of Assessing Officer with the aforesaid and directions

ITA 182/AHD/2020[2017-18]Status: DisposedITAT Ahmedabad08 Mar 2024AY 2017-18

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Ramesh Kumar, Sr. D.RFor Respondent: Shri Ramesh Kumar, Sr. D.R
Section 195Section 201Section 9(1)(vi)

delay of 176 days in filing of the present appeal is hereby condoned. 4. The brief facts of the case are the assessee, International Education And Research, Foundation is engaged in the running of an educational school, under the name of “Mahatma Gandhi, International School”. During the course of 201 proceedings, the Assessing Officer observed that foreign remittances were made

INTERNATIONAL EDUCATION & RESEARCH FOUNDATION,AHMEDABAD vs. THE DCIT, INT-TAXA-1, AHMEDABAD

In the result, the issue is restored to the file of Assessing Officer with the aforesaid and directions

ITA 183/AHD/2020[2018-19]Status: DisposedITAT Ahmedabad08 Mar 2024AY 2018-19

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Respondent by: Shri Ramesh Kumar, Sr. D.RFor Respondent: Shri Ramesh Kumar, Sr. D.R
Section 195Section 201Section 9(1)(vi)

delay of 176 days in filing of the present appeal is hereby condoned. 4. The brief facts of the case are the assessee, International Education And Research, Foundation is engaged in the running of an educational school, under the name of “Mahatma Gandhi, International School”. During the course of 201 proceedings, the Assessing Officer observed that foreign remittances were made

RAYMON PATEL GELATINE PVT.LTD.,,BARODA vs. THE INCOME TAX OFFICER,WARD-4(2),, BARODA

In the result, appeals of the assessee are partly allowed

ITA 1591/AHD/2012[2005-06]Status: DisposedITAT Ahmedabad12 Oct 2022AY 2005-06

Bench: Mrs.Annapurna Gupta & Miss Suchitra Kamble

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri Atul Pandey, Sr.DR
Section 143(3)Section 147Section 250(6)Section 40

condone the delay. The order was pronounced in the Open Court and hearing of the appeal is being proceeded with. 6. The facts of the present case are that regular assessment under section 143(3) was framed on the assessee for the impugned year on 24.12.2007 determining total income at Rs.16,20,928/-. Thereafter the case of the assessee

RAYMON PATEL GELATINE PVT.LTD.,,BARODA vs. THE INCOME TAX OFFICER,WARD-4(2),, BARODA

In the result, appeals of the assessee are partly allowed

ITA 2078/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad12 Oct 2022AY 2008-09

Bench: Mrs.Annapurna Gupta & Miss Suchitra Kamble

For Appellant: Shri M.K. Patel, AdvocateFor Respondent: Shri Atul Pandey, Sr.DR
Section 143(3)Section 147Section 250(6)Section 40

condone the delay. The order was pronounced in the Open Court and hearing of the appeal is being proceeded with. 6. The facts of the present case are that regular assessment under section 143(3) was framed on the assessee for the impugned year on 24.12.2007 determining total income at Rs.16,20,928/-. Thereafter the case of the assessee

THE SPORTS CLUB OF GUJARAT LTD.,,AHMEDABAD vs. THE PR. CIT-4, AHMEDABAD

In the result, we are of the view that in light of the discussion above,

ITA 360/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad28 Apr 2022AY 2015-16
For Appellant: Shri S.N. Soparkar, Sr. A.R. &For Respondent: Shri James Kurian, CIT-D.R
Section 143(3)Section 263

established principle of Law by Hon. Supreme Court, Hon. Gujarat High Court, Hon. ITAT, Ahmedabad and in Appellant's own case since its inspection since 66-67 and therefore also, the C1T has erroneously held that entrance fees of Rs.8,63,92,930/- is revenue receipt and taxable as income of the Appellant. It is therefore submitted that relieves claimed

ANIL MANILAL PATEL,ANAND vs. I.T.O WARD-1, ANAND, ANAND

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

ITA 379/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad15 Jul 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Anil Manilal Patel Ito, Ward-1 Hariom Bungalows Vs. Anand. Dr.Kurion Road B/H. Civil Court Anand. Pan : Azopp 5693 B (Applicant) (Responent) : Shri Chirag Shah, Ar Assessee By Revenue By : Shri Uday Kishanrao Kakne, Sr.Dr

For Respondent: Shri Uday Kishanrao Kakne, Sr.DR
Section 133(6)Section 139(1)Section 142(1)Section 144Section 250Section 271ASection 69

permanent resident of the USA for many years and used to visit India occasionally. He claimed that during the period relevant to the assessment, he was out of the country and had no knowledge of the proceedings initiated under section 142(1), and that all notices remained uncomplied due to absence and lack of access to the Income Tax portal