SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

condonation of delay in filling appeal. 4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, both appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ It(Ss)A No. 45 & Ita No.204/Ahd/2020 "नधा"रण वष"/Assessment Year: 2005-06 Rohitji Chanduji Thakore Dcit, Cent.Cir.2(1) Chandanami Nivas Vs Ahmedabad. Thakor Vas, Ambali Gam Ahmedabad. Pan : Adtpt 4435 C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr.Adv Parimal Singh B. Parmar, Ar Shri Vijay Govani, Ar Revenue By : Shri Virendra Ojha, Cit-Dr

153A of the Income Tax Act, 1961, whereas ITA No.204/Ahd/2020 emerges out of penalty proceedings initiated under section 271(1)(c) of the Act. IT(SS)A.No.45/Ahd/2020 and ITA No.1188 /Ahd/2019 3. Registry has pointed out that ITA No.45/Ahd/2020 is time barred by 132 days whereas ITA No.204/Ahd/2020 is time barred by 282 days. The assessee has filed

SMT. VANITA VASWANI,AHMEDABAD vs. THE PR. CIT (CENTRAL), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedassessment Years : 2010-11 Smt. Vanita Vaswani, The Pcit (Central), 2, Samprat Co-Op. Housing Vs Ahmedabad Society Limited, Opp. Rivera, 11, Prahladnagar, Ahmedabad - 380015 Pan : Aakpv 7868 D अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "त् "त् यथ" "त् "त् यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate Shri Parimalsinh B Parmar, Ar & Shri Vijay Govani, Ar Revenue By : Shri Virendra Ojha, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 28/07/2021 घोषणा क" तारीख /Date Of Pronouncement: 17/09/2021 आदेश/O R D E R आदेश आदेश आदेश Per Rajpal Yadav: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Learned Principal Commissioner Of Income Tax (Central), Ahmedabad Dated 28.03.2021, Passed Under Section 263 Of The Income Tax Act, 1961 (In Short “The Act”), For Assessment Year 2010-2011. The Assessee Has Taken 7 Grounds Of Appeal Which Read As Under:- “1. The Ld. Pcit (Central), Ahmedabad ("The Pcit") Has Erred On Facts & In Law In Invoking Jurisdiction U/S 263 Of The Income Tax Act, 1961 ("The Act") & Has Further Erred In Directing The Ld. Ao To Pass Fresh Assessment Order Incorporating The Market Value Of The Property As Per Section 50C Of The Act. 2. The Ld. Pcit Has Erred On Facts & In Law In Passing Order U/S 263 Of The Income Tax Act, 1961 In The Case Of The Appellant In Failing To Take Smt. Vanita Vaswani Vs. Pr. Cit Ay : 2010-2011 2

b) any books of account or documents, seized or requisitioned, or any information contained therein, a person other than the person referred to in section 153A, then, the books of account or documents or assets, seized or requisitioned shall be handed over to the Assessing Officer having jurisdiction over such other person ] —[and that Assessing Officer shall proceed against each

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani

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

delay is condoned. The appeals pertaining to 17 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. A.Y. 2010-11 are IT(SS)A No.569/Ahd/2019 filed by the assessee and IT(SS)A No.01/Ahd/2020 filed by the Revenue with CO No.47/Ahd/2020. 21. We have heard Shri Tushar Hemani