ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

condone delay petitions. Since the Division Bench of this Court has already considered the very same issue, that has been raised in this writ petition, the benefit granted to those petitioners must also enure to the benefit of this writ petitioner also. Accordingly, the impugned order dated 01.11.2019 is hereby quashed on the ground that the same is barred

THE ITO, WARD-1(2)(3), AHMEDABAD vs. MOHAMMEDARIF IBRAHIMBHAI SHAIKH, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

condone the delay. 6. So far as the maintainability of the proceeding initiated under Section 147 of the Act is concerned, the crux of the submission made by the Ld. A.R. is this that the same is based on change of opinion. No new and/or any tangible material was available with the Ld. AO to come to a conclusion that

THE ITO, WARD-1(2)(3), AHMEDABAD vs. MOHAMMEDARIF IBRAHIMBHAI SHAIKH, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

condone the delay. 6. So far as the maintainability of the proceeding initiated under Section 147 of the Act is concerned, the crux of the submission made by the Ld. A.R. is this that the same is based on change of opinion. No new and/or any tangible material was available with the Ld. AO to come to a conclusion that

AARK INFOSOFT PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2017-18 Vs. Aark Infosoft Private Limited, The Acit, 45, Shetrunjay, 2Nd Floor, Above Circle-1(1)(1), Central Bank Of India, Bhattha Ahmedabad Cross Road, Paldi, Ahmedabad Gujarat-380007 Pan : Aahca 9986 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Divyang Shah, Ar Revenue By : Shri Santosh Kumar, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 08.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 21.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 27.07.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Are As Under:- “1. Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Issuing A Notice U/S 143(2) Of The Act? 2. Whether On The Facts & In Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Making Disallowance Of Employees' Contribution To Pf & Esic Of Rs.5,51,657/- U/S 36(1) (Va) Of The Act?

delayed in terms of the time prescribed u/s 143(2) of the Act. Section 143(2) prescribes the time limit as under:- “143… (2) Where a return has been furnished under section 139, or in response to a notice under sub-section (1) of section 142, the Assessing Officer or the prescribed income-tax authority, as the case

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

HEALTH FOUNDATION & RESEARCH CENTRE,DAHOD vs. THE ACIT, CIRCLE-2, EXEMPTION, AHMEDABAD

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

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

3) of Health Foundation & Research Centre vs. ACIT 2 the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], for the Assessment Year 2017–18. Brief Facts of the Case 2. The assessee is a charitable trust duly registered under section 12A of the Act since 16.04.1984 and is also enjoying approval under section

SHRI KHAMBHAT TALUKA SARVAJANIK KELAVANI MANDAL,ANAND vs. THE ITO, WARD-EXEMPTION, VADODARA

In the result, appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

condone the delay. He submitted that when the accountant had been negligent before the AO and also before the Ld. CIT(A), which resulted in ex-parte orders, the assessee should have taken precaution to ensure that the present appeal was filed within time. According to the Ld. CIT(A), the assessee cannot escape by merely passing on the blame

YOGESH JASHUBHAI PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(4) NOW WARD- 1(2)(1), AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.158/Ahd/2023, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.159/Ahd/2023, Asst.Year 2011-12 Yogesh Jashubhai Patel, The Income Tax Officer Harivallabh Society बनाम/ Ward-3(4) V/S. Naroda Now Ward-1(2)(1) Opp. Devi Cinema Ahmedabad – 380 051 Ahmedabad – 382 345 "थायी लेखा सं./Pan: Audpp 9058 L (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/01/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.158/Ahd/2023:

delay be condoned and appeal should be taken up for hearing. 2. On the facts and in the circumstances of the case and in law, the learned AO erred in in Law and in fact in passing the order u/s. 271(1)(c) of the Act in haste and hurry disregarding facts of the case and without providing sufficient time

YOGESH JASHUBHAI PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(4) NOW WARD- 1(2)(1), AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.158/Ahd/2023, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.159/Ahd/2023, Asst.Year 2011-12 Yogesh Jashubhai Patel, The Income Tax Officer Harivallabh Society बनाम/ Ward-3(4) V/S. Naroda Now Ward-1(2)(1) Opp. Devi Cinema Ahmedabad – 380 051 Ahmedabad – 382 345 "थायी लेखा सं./Pan: Audpp 9058 L (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/01/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.158/Ahd/2023:

delay be condoned and appeal should be taken up for hearing. 2. On the facts and in the circumstances of the case and in law, the learned AO erred in in Law and in fact in passing the order u/s. 271(1)(c) of the Act in haste and hurry disregarding facts of the case and without providing sufficient time

RANDHEJA DUDH UTPADAK SAHAKARI MANDLI LTD.,GANDHINAGAR vs. THE ITO, WARD-3 NOW WARD-1, GANDHINAGAR

The appeal of the assessee is allowed

Bench: Smt.Annapurna Guptaasstt. Year : 2017-18 Randheja Dudh Utpadak The Ito, Ward-3 Sahakari Mandli Ltd. Vs Now Ward-1 To-Randheja Gandhinagar. Tal: Gandhinagar Pin : 382 620 Pan : Aacar 5164 K (Applicant) (Responent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Ketan Gajjar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 27/06/2024 आदेश/O R D E R आदेश आदेश आदेश The Present Appeal Has Been Filed By The Assessee Against Order Passed By The Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre, Delhi [In Short Referred To As Ld.Cit(A)] Under Section 250 Of The Income Tax Act, 1961 Dated 22.11.2021 Pertaining To Asst.Year 2017-18. 2. The Registry Has Notified That The Appeal Of The Assessee Is Barred By Limitation By 581 Days. In Order To Explain The Reasons For The Impugned Delay, The Ld.Counsel For The Assessee Submitted That The Cit(A)/Nfac Order Was Passed Against The Assessee On 22.11.2021. However, Due To Covid-19 Pandemic Limitation For Filing Appeal Before The Court Of Law Was Extended Till February, 2022. Therefore, After Expiry Of The Limitation For Filing Of The Appeal On Feb., 2022, The Assessee Was Required To File Appeal Within 60 Days Of The Same I.E. By April, 2022. But The Assessee Could File The Appeal On

condone the impugned delay of 581 days in filing appeal ITA No.649 /Ahd/2023 5 before the Tribunal, and proceed to take up the appeal of the assessee for adjudication on merit. 7. The grievance of the assessee against the impugned order are given in the grounds of appeal, which read as under: “1. That on facts

ALPESHBHAI BALDEVBHAI RABARI,MEHSANA vs. THE ITO, WARD-1, MEHSANA

In the result, the appeal of the assessee is treated as allowed for statistical purpose

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2017-2018 Alpeshbhai Baldevbhai Rabari Ito, Ward-1 3, Rabarivas, Palaj Vs. Mehsana. Mehsana 384 410 Gujarat. Pan : Bwgpr 0788 H (Applicant) (Responent) : Shri Dhrunal Bhatt, Ar Assessee By : Shri Kalpesh Rupavatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025

142(1) of the Act. Consequently, the Assessing Officer proceeded to complete the assessment ex parte under section 144 of the Act. In the said order, the AO noted that substantial amounts aggregating to Rs. 54,69,131/- stood credited in the assessee’s bank accounts during the relevant period. Since the assessee did not furnish any explanation or evidence

THE VISNAGAR NAGRIK SAHAKARI BANK LTD.,MEHSANA vs. THE ACIT, CIRCLE-GANDHINAGAR (PREVIOUSLY DCIT, PATAN CIRCLE, PATAN), GANDHINAGAR

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

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

3) Date of 19.06.2025 19.06.2025 19.06.2025 CIT(A)’s order u/s 250 4. For the lead year, i.e. A.Y. 2013–14, the assessee filed its return of income on 16.09.2013 declaring total income at Nil. Subsequently, revised returns were filed on 31.03.2014 and 31.03.2015, each time declaring Nil income. The return was initially processed under section 143(1). The case

THE VISNAGAR NAGRIK SAHAKARI BANK LTD (UNDER LIQUIDATION),MEHSANA vs. THE ACIT, CIRCLE-GANDHINAGAR (PREVIOUSLY DCIT, PATAN CIRCLE, PATAN), GANDHINAGAR

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

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.738, 1414 & 1415/Ahd/2025 िनधा"रण वष" /Assessment Years : (2013-14, 2014-15 & 2015-16) The Visnagar Nagarik Sahakari The Assistant Commissioner Bank Ltd.,(Under Liquidation) बनाम Of Income Tax, / Market Yard, Circle Gandhinagar. V/S. Visnagar, (Previously Dcit, Mehsana-384315, Patan Circle, Patan) "थायी लेखा सं./Pan: Aaaft8764C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri A P Nanavaty, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] These Three Appeals By The Assessee Are Directed Against The Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “The Cit(A)”], All Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Arising From The Assessments Framed By The Assistant / Deputy Commissioner Of Income-Tax, Circle, Patan [Hereinafter Referred To As “The Assessing Officer Or Ao”] Under Section 143(3) Of The Act.

3) Date of 19.06.2025 19.06.2025 19.06.2025 CIT(A)’s order u/s 250 4. For the lead year, i.e. A.Y. 2013–14, the assessee filed its return of income on 16.09.2013 declaring total income at Nil. Subsequently, revised returns were filed on 31.03.2014 and 31.03.2015, each time declaring Nil income. The return was initially processed under section 143(1). The case

SOLEONE TRADELINKS PRIVATE LIMITED,AHMEDABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 4(1)(1), AHMEDABAD, CIRCLE 4(1)(1), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

condonation, of delay is contrary to the principles of natural justice and deserves to be set aside. 2. The Ld. CIT(A) has erred in not adjudicating the appellant's grounds on merits and mechanically dismissing the appeal on technical grounds. It is prayed that the matter be restored for fresh adjudication on merits. 3. The Ld. CIT(A) failed

MANSHA TEXTILES PVT. LTD.,VADODARA vs. THE ITO, WARD-2(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2012-13 Mansha Textiles P. Ltd. The Ito, Ward-2(1)(1) 1, Vikram Society Vadodara. Gotri Road, Vadodara Pan : Aadcm 0191 J (Applicant) (Responent) Assessee By : Ms.Urvashi Shodhan, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 09/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 13/10/2025 आदेश आदेश/O R D E R आदेश आदेश

142(1) were issued on 07.10.2014 and 30.10.2014 calling for audited accounts, audit report and other particulars. 2.2 On verification of Form 26AS and the details on the ITD system, the AO found that rent aggregating to Rs. 57,57,850/- stood reflected against the assessee from the following payers along with tax deduction at source amounting to Rs.5

CHINTAN BHARATBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(1), AHMEDABAD

In the result, impugned order is set-aside and appeal by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 678/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2017-18)

delay is condoned. 3. The appellant has challenged the penalty levied under Section 272A(1)(d) of the Act to the tune of Rs.30,000/-. 4. The facts of the case is this that during the course of assessment proceeding notices under Section 142

JIVRAJBHAI RAMABHAI CHAUDHARY,BANASKANTHA vs. THE INCOME TAX OFFICER, WARD-3, PALANPUR

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

Bench: Smt.Annapurna Guptaasstt.Year :2017-18 Jivarajbhai Ramabhai Chaudhary Income Tax Officer Patel Vas, Village : Hadta, Jadiya Vs Ward-3 Tal. Dhanera Palanpur. Dist: Banaskantha Gujarat. Pan : Azzpp 6148 A (Applicant) (Responent) : Shri Jimi Patel, Ar Assessee By : Ms.Neeju Gupta, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 27/11/2024 घोषणा क" तारीख /Date Of Pronouncement: 29/11/2024 आदेश आदेश/O R D E R आदेश आदेश

delay is condoned, and I proceed to dispose of the appeal on its merits. 4. Taking up now the appeal of the assessee for adjudication, the issue arising in the present appeal relates to addition made to the income of the assessee on account of cash found deposited in his bank account to the tune of Rs.14,98,000/- during

THE ANKLAV MERCANTILE CO-OP CREDIT SOCIETY LTD.,ANAND vs. DCIT CIRCLE 1(1)(1), VADODARA, VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

condoning delay in fulfilling appeal. 3. The Ld. CIT(A) has erred in law and on facts in not adjudicating addition made U/s 68 of the Act by Ld. A.O. of Rs.8,17,68,248/- as unexplained cash credit. 4. The Ld. CIT(A) has erred in law and on facts not adjudicating addition made

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

142(1) regarding the activities, declaring the disputed total same income transactions income as in the and verify computatio original the n, and the return filed authenticity return filed under section ITA Nos.1095 & 1096/Ahd/2024 Dilipkumar Pashabhai Prajapati vs. ITO Asst. Years : 2016-17 & 2017-18 of the credits in response 139(1), in the books. to section without 148. additional