SHRI MAHESH P. GANDHI,AHMEDABAD vs. THE ACIT., CIRCLE-10,, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita Nos.1022 To 1025/Ahd/2018 िनधा"रण वष"/Asstt. Year: (1992-1993 To 1995-1996) Shri Mahesh P. Gandhi, A.C.I.T., D-404, 5Th Floor, Vs. Circle-10, Dharnidhar Tower, Ahmedabad. Paldi, Ahmedabad.

condone the delay of 2337 days in filing the appeal and proceed to hear the appeal on merit for the adjudication. 13. Coming to issue raised by the assessee in the grounds of appeal. The issue in the instant case raises two situations as detailed under: 1- Whether the assessment made under section 143(3) read with section

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD2(1)(1), AHMEDABAD, AHMEDABAD

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

delay in filing of all five appeals is condoned, and the appeals are admitted for adjudication on merits. 4. Facts of the Case 4.1 The facts, as emerging from the orders of the Assessing Officer and the CIT(A), are substantially common across all the assessment years under consideration. 4.2 The assessee is an individual engaged in small business

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

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

delay in filing of all five appeals is condoned, and the appeals are admitted for adjudication on merits. 4. Facts of the Case 4.1 The facts, as emerging from the orders of the Assessing Officer and the CIT(A), are substantially common across all the assessment years under consideration. 4.2 The assessee is an individual engaged in small business

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

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

delay in filing of all five appeals is condoned, and the appeals are admitted for adjudication on merits. 4. Facts of the Case 4.1 The facts, as emerging from the orders of the Assessing Officer and the CIT(A), are substantially common across all the assessment years under consideration. 4.2 The assessee is an individual engaged in small business

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

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

delay in filing of all five appeals is condoned, and the appeals are admitted for adjudication on merits. 4. Facts of the Case 4.1 The facts, as emerging from the orders of the Assessing Officer and the CIT(A), are substantially common across all the assessment years under consideration. 4.2 The assessee is an individual engaged in small business

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

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

delay in filing of all five appeals is condoned, and the appeals are admitted for adjudication on merits. 4. Facts of the Case 4.1 The facts, as emerging from the orders of the Assessing Officer and the CIT(A), are substantially common across all the assessment years under consideration. 4.2 The assessee is an individual engaged in small business

ISHIT KAMLESHBHAI SHETH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

delayed but\ntruthful compliance, particularly where no tax loss arises and the\nincome is fully traceable in departmental systems.\n16\nIn view of the above discussion and respectfully applying the\nratio laid down in the judicial precedents referred to hereinabove, we\nare of the considered opinion that the present case does not warrant\nthe imposition of penalty under section 270A

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEHAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section