BALARAM CONSTRUCTION LIMITED,BANASKANTHA vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal filed by the assessee is dismissed as non- maintainable

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Balaram Construction Ltd. The Pcit 309, 3Rd Floor, Shital-9 Vs Ahmedabad-1 Opp. Bihari Bagh, Palanpur Ahmedabad – 380 015 Banaskantha – 385 001 (Gujarat) (Gujarat) Pan: Aaacb 6264 C

u/s 263 of the Act. Balaram Construction Ltd. vs. PCIT AY 2018-19 3.2. The Ld.Counsel for the assessee was confronted at bar with the fact that having consciously chosen not to file the appeal against the order of the Ld.PCIT initially, how the filing of the appeal now by delay of 324 days was justified in any case

TIKI TAR INDUSTRIES BARODA LTD,VADODARA vs. THE PR. CIT-2, VADODARA

In the result, the appeal of the assessee is allowed as above

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2014-15 Tiki Tar Industries Baroda Ltd. Pr.Cit-2 8Th Floor, Neptune Tower Vs Vadodara. Baroda Productivity Council Alkapuri, Vadodara Pan : Aadct 8382 Q

u/s. 263 of the Act. Therefore, noting that there is no negligence or laxity attributable to the assessee for the delay in filing appeal, and to sub- serve the ends of justice we find that it is a fit case for condoning the delay of 262 days in the present appeal. The impugned delay in filing the present appeal

SHRI VIJAY D. PATEL,,AHMEDABAD vs. THE CIT-7,, AHMEDABAD

delay is accordingly condoned. I.T.A No. 2022/Ahd/2015 A.Y. 2008-09 Page No 3 Vijay D. Patel vs. CIT 3. Proceeding to adjudicate the issue before us ,it transpires from the order of the ld. PCIT, that the revisionary power was exercised on the order passed by the Assessing Officer in the case of the assessee in reassessment proceedings,u/s

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

condone the delay of 262 days in filing the appeal and proceed to hear the appeal on merit for the adjudication. 4. The only issue raised by the assessee is that the learned Principal CIT erred in holding the assessment framed by the AO under section 143(3) of the Act as erroneous insofar prejudicial to the interest of revenue

GUJARAT TECHNOLOGICAL UNIVERSITY,,AHMEDABAD, GUJARAT vs. COMMISSIONER OF INCOME TAX, EXEMPTION, AHMEDABAD, GUJARAT

In the result, the above ground of appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

revision power u/s 263 of the Act on an issue of allowability of exemption u/s 11 of the Act despite the fact that proceeding u/s 263 cannot be initiated on debatable issue. Gujarat Technological University vs. CIT(E) Asst. Year –2017-18 - 2– 5. The learned CIT(E) erred in fact and in law in initiating proceeding u/s 263

VINOD NARAYAN JOSHI,VADODARA vs. THE PR. CIT,-1, VADODARA

Bench: Shri Tr Senthil Kumar & Shri Makarand V. Mahadeokarआयकरअपीलसं./Ita No. 230 /Ahd/2021 धििाधरणवरध/Asstt. Year: 2011-2012 & आयकरअपीलसं./Ita No. 44/Ahd/2022 धििाधरणवरध/Asstt. Year: 2012-13 Vinod Narayan Joshi, The Principal Af-6, Utopian Corner, Commissioner Of बिाम Nr. Green Wood Bunglows, Income Tax, Vs. New Alkapuri, Vadodara-1, Vadodara-390021. Vadodara.

delay is condoned, and the appeals are admitted for adjudication on merits. Facts and Reasons for Reopening the Assessments 4. A.Y. 2011-12: The assessee, a salaried employee, filed his return of income on 26.08.2011, declaring an income of Rs.8,02,790/-. The return was ITA No.230 /Ahd/2021 & Ninod Narayan Joshi vs. PCIT Asst. Years

VINOD NARAYAN JOSHI,VADODARA vs. THE PR. CIT,-1, VADODARA

Bench: Shri Tr Senthil Kumar & Shri Makarand V. Mahadeokarआयकरअपीलसं./Ita No. 230 /Ahd/2021 धििाधरणवरध/Asstt. Year: 2011-2012 & आयकरअपीलसं./Ita No. 44/Ahd/2022 धििाधरणवरध/Asstt. Year: 2012-13 Vinod Narayan Joshi, The Principal Af-6, Utopian Corner, Commissioner Of बिाम Nr. Green Wood Bunglows, Income Tax, Vs. New Alkapuri, Vadodara-1, Vadodara-390021. Vadodara.

delay is condoned, and the appeals are admitted for adjudication on merits. Facts and Reasons for Reopening the Assessments 4. A.Y. 2011-12: The assessee, a salaried employee, filed his return of income on 26.08.2011, declaring an income of Rs.8,02,790/-. The return was ITA No.230 /Ahd/2021 & Ninod Narayan Joshi vs. PCIT Asst. Years

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,

condone the delay of 43 days in filing the appeal. 6. Before us, the ld. counsel for the assessee submitted that during the course of assessment proceeding, the ld. Assessing Officer had made inquiries in respect to membership fees and vide submission dated 24-11- 2017, the assessee gave an explanation regarding contributions received from members. He drew our attention

JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

u/s 263 as well as consequential orders passed subsequent to revision proceeding are Null and VOID and deserves to be quashed and set aside. The same please be held accordingly. 5. The order passed by the learned CIT (Appeals) is bad in law and contrary to the provisions of law and facts. It is submitted that the same be held

M/S. KOLET RESORT CLUB PRIVATE LIMITED,HYDERABAD vs. INCOME TAX OFFICER, WARD-2(1)(2), AHMEDABAD

In the result the appeal filed by the assessee is allowed

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

delay in filing the above appeal is hereby condoned considering Covid-19 Pandamic period and the appeal is taken up for hearing. 3. Brief facts of the case are that the assessee company filed its Return of Income for assessment year 2015-16 claiming total loss of Rs.23,02,232/-. The return was taken for limited scrutiny assessment and after

BHOGILAL BAHILALBHAI PATEL,VADODARA vs. THE PR. CIT -1, VADOADAR

In the result, the appeal of the assessee is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2015-16 Bhogilal Bhailalbhai Patel Vs. The Pr.Cit-1 475/2 Sagar Faliya Vadodara. At & Post Bhayali Vadodara 391 410. Pan : Bkkpp 3136 R

condone the impugned delay in filing appeal before the Tribunal, and proceed to adjudicate the matter on merit. 5. The assessee has challenged order raising the following grounds before us. “1. The Ld. Pr. CIT - 1, Vadodara has erred in law and in facts in holding that the assessment order passed by the Ld. A.O. u/s. 143(3) dated

AMRUTA FABRICS PVT. LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

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

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1110, 1111 & 1112/Ahd/2024 (िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) बनाम/ Amruta Fabrics Pvt. Ltd. The Pr. Cit 199, New Cloth Market, Ahmedabad-1 Vs. Opp. Raipur Darwaja, Sarangpur, Ahmedabad, Gujarat, 380002 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaica0877A (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Ms. Astha Maniar, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhendu Das, Cit. Dr 18/09/2024 Date Of Hearing Date Of Pronouncement 21/10/2024

delay in filing of these appeals is condoned. 3. The issue involved in all three appeals is identical and were heard together. Therefore, these appeals are being disposed of vide this common order. We will take ITA No.1110/Ahd/2024 for A.Y. 2013-14 as the lead case. 4. The brief facts of the case are that the assessee had filed

AMRUTA FABRICS PVT. LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

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

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1110, 1111 & 1112/Ahd/2024 (िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) बनाम/ Amruta Fabrics Pvt. Ltd. The Pr. Cit 199, New Cloth Market, Ahmedabad-1 Vs. Opp. Raipur Darwaja, Sarangpur, Ahmedabad, Gujarat, 380002 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaica0877A (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Ms. Astha Maniar, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhendu Das, Cit. Dr 18/09/2024 Date Of Hearing Date Of Pronouncement 21/10/2024

delay in filing of these appeals is condoned. 3. The issue involved in all three appeals is identical and were heard together. Therefore, these appeals are being disposed of vide this common order. We will take ITA No.1110/Ahd/2024 for A.Y. 2013-14 as the lead case. 4. The brief facts of the case are that the assessee had filed

VIVAA TRADECOM PVT. LTD,AHMEDABAD vs. THE PR. CIT-4, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyal"नधा"रणवष"/Assessment Year: 2015-16 Vs. Vivaa Tradecom Pvt. Ltd., Principal Commissioner Of Shade No. 20, Shree Shhakti Income-Tax-4, Estate & Workhouse, Piplaj Ahmedabad Pirana Road, Saijpur-Gopalpur, Ahmedabad-302405 [Pan : Aaica 3968 J] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sudhir Mehta, Ar Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई क! तार"ख/Date Of Hearing : 21.11.2024 घोषणा क! तार"ख /Date Of Pronouncement: 12.02.2025 आदेश/O R D E R Per Siddhartha Nautiyal:

revision the case and should not check again on re- appreciating the materials on record. 4. The Learned Principal Commissioner of Income Tax have erred in law and on facts to direct AO to carry out thorough inquiries on the issues noticed during the course of assessment proceedings in pursuant to the order u/s 263

SHRI RASHMINBHAI MOHANLAL MAJITHIA,AHMEDABAD vs. THE PR. CIT-4, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: The Appeal Is Heard & Decided.”

condoning assessee’s delay in filing the appeal.” 5. On merits, the counsel for the assessee drew our attention to the contents of the show cause notice issued by the Ld. Pr. CIT u/s 263 of the Act, which mentions that the reason for initiating 263 proceedings was that the Ld. Assessing Officer did not carry out a proper enquiry

KACHCHH HOSPITALITY PRIVATE LIMITED (FORMERLY KNOWN AS SANGHI INFRASTRUCTURE LIMITED ),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Bench: The Ld. Cit During Revision Proceedings. Therefore Requested To Condone The Delay & Set-Aside The Matter Back To The File Of Jurisdictional Assessing Officer To Consider The Same & Pass Orders On Merits Of The Case.

263 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2013-14. I.T.A No. 647/Ahd/2023 A.Y. 2013-14 Page No 2 Kachchh Hospitality Private Limited (Formerly known as Sanghi Infrastructure Ltd.) vs. ITO 2. The Registry has noted that there is a delay of 307 days in filing the appeal. The assessee

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

delay of 83 days in filing the present appeal is condoned and the appeal is admitted for adjudication on merits. 6. On merits, the brief facts of the case are that the assessee filed its return of income for Assessment Year 2018–19 on 30.10.2018 declaring a total income of ₹10,75,470/-. The assessment was completed under section

TEXRAJ REALTY PVT.LTD.,,AHMEDABAD vs. THE PR. CIT-4, AHMEDABAD

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

Bench: Shri P.M. Jagtap, Vice- & Shri T.R. Senthil Kumarassessment Year : 2015-16

condone the said delay and proceed to dispose of this appeal on merit. Texraj Realty Pvt Ltd Vs. PCIT AY : 2015-16 2 3. The assessee, in the present case, is a company which is engaged in real estate business. The return of income for the year under consideration was filed by it on 05.10.2015 declaring a total income

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