BIREN DHIRAJLAL SHAH,GANDHINAGAR vs. THE ITO WARD-1, GANDHINAGAR

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

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकरअपीलसं./Ita Nos.192-193/Ahd/2021 धििाधरणवरध/Asstt. Year: 2011-12 Shri Biren Dhirajlal Shah, Income Tax Officer, Plot No.441-1, Sector-22, Vs. Ward-1, Nr. Police Chowkey, Gandhinagar. Gandhinagar.

156 taxmann.com 361 (Madras) wherein it is held that where assessee had not given ‘sufficient cause’ for condoning huge delay of 1072 days in filing appeal, delay could not be condoned. 6. We have perused the records and heard the rival submissions of both the sides. There was a delay of 1607 days in filing the appeal by the assessee

TEJAS KARSHANBHAI DARI,AHMEDABAD vs. THE ITO, WARD-5(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed

156 demand notice which itself shows that order can be appealed with. On his advice, the assessee is now preferring this appeal. Hence in this view of the facts the assessee most humbly request that delay in filing appeal may kindly condoned.” 3.1 However, the ld. CIT(A) rejected assessee’s application for condonation of delay in filing the appeal

AADI REAL ESTATE DEVELOPERS PRIVATE LIMITED ,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

The appeal of the assessee is allowed for statistical purposes

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2012-13 Aadi Real Estate Developers Vs. Income Tax Officer, Private Limited, Ward 1(1)(1), 402, Sheel Complex, Mayur Ahmedabad Colony, Mithakhali, Navrangpura, Ahmedabad-380009 Pan : Aajca 1796 R अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Deepak Shah, Ar Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 16.10.2024 घोषणा क" तारीख /Date Of Pronouncement: 25.10.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against Order Of The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 25.05.2022 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2012-13. 2. The Brief Facts Relating To The Case Are That The Assessee Is A Private Limited Company & Had Filed ‘Nil’ Return Of Income For The Impugned Assessment Year, I.E. Ay 2012-13. Subsequently, On Information Received From Ddit (Inv.), Unit-1 (3), Ahmedabad, By The Assessing Officer That The Assessee Was A Beneficiary Of Accommodation Entry Taken Through Dummy Companies Run & Controlled By One Jignesh Shah, Which Information Was Revealed Consequent To Search Action Conducted On Jignesh Shah, The Case Of The Aadi Real Estate Developers Pvt Ltd Vs. Ito Ay : 2012-13 2

156 taxmann.com 643 (Madras) has held that the question of limitation is not based on technical consideration, but is on the principles of public policy and equity, and the substantial justice is paramount consideration and pivotal for deciding the issue of condonation of delay. The Hon’ble High Court in the said judgment referred to the decision

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

156, Sheth Shri Circle-2, Exemption, Girdharlal Marg, Raliyati Road, Ahmedabad Dahod, Gujarat - 389151 "थायी लेखा सं./PAN: AATH0867J अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Sakar Sharma, AR Revenue by : Shri Hargovind Singh, Sr.DR सुनवाई की तारीख/Date of Hearing : 05/06/2025 घोषणा की तारीख /Date of Pronouncement: 10/06/2025 आदेश/O R D E R PER MAKARAND V. MAHADEOKAR

RAVINDRABHAI LAKSHMANRAV MANE,AHMEDABAD vs. ITO, WARD-5(3)(5), AHMEDABAD

In the result the appeal filed by the assessee in IT(SS)A No

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

section 143(3) r.w.s. 153B(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2015-16 and ITA Nos.140/Ahd/2020 are filed by the assessee as against the exparte appellate order dated 21.11.2019 passed by the I.T.(SS)A No. 54/Ahd/2019 & Ors. A.Ys. 2015-16 Page No 2 Ravindrabhai Lakshmanrav

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

Section 5 of the Limitation Act provides for extension of prescribed period of limitation in certain cases and confers jurisdiction upon the court to admit any application or any appeal after the prescribed period if it is satisfied that the appellant or applicant had sufficient cause for not preferring such appeal or application within the prescribed period. The applicant having

RAVINDRABHAI LAKSHMANRAV MANE,AHMEDABAD vs. ITO, WARD-5(3)(5), AHMEDABAD

In the result the appeals filed by the assessee in IT[SS]A Nos

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 271(1)(c) of the Act relating to the Assessment Years 2010-11 & 2013-14. Since common issues are involved in all these appeals, the same are disposed of by this common order. 2. The Registry has noted that there is a delay of 326 days in filing the quantum appeals and 1 day delay in filing the penalty

RAVINDRABHAI LAKSHMANRAV MANE,AHMEDABAD vs. ITO, WARD-5(3)(5), AHMEDABAD

In the result the appeals filed by the assessee in IT[SS]A Nos

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 271(1)(c) of the Act relating to the Assessment Years 2010-11 & 2013-14. Since common issues are involved in all these appeals, the same are disposed of by this common order. 2. The Registry has noted that there is a delay of 326 days in filing the quantum appeals and 1 day delay in filing the penalty

VOLARK LEASING IFSC PVT. LTD,GUJARAT vs. ACIT/DCIT, CIRCLE, GANDHINAGAR, GUJARAT, GUJARAT

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

156 taxmann.com 550 (ITAT Delhi)] “33. We have heard both the parties and perused the material available on record. It is seen from the facts of the case, it is clear that although the assessee did not file Form No. 10CCB along with the return of income on or before the due date prescribed

ARUNA KISHOR FOUNDATION,VADODARA vs. CIT(EXEMPTION), AHMEDABAD

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

delay of 156 days in ITA No. 323/Ahd/2025 and 151 days in ITA No. 324/Ahd/2025 is condoned. Facts of the Case 5. The assessee is a company registered under section

ARUNA KISHOR FOUNDATION,VADODARA vs. CIT(EXEMPTION), AHMEDABAD

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

delay of 156 days in ITA No. 323/Ahd/2025 and 151 days in ITA No. 324/Ahd/2025 is condoned. Facts of the Case 5. The assessee is a company registered under section

ARUNA KISHORE FOUNDATION,VADODARA vs. CIT(EXEMPTION), AHMEDABAD

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

delay of 156 days in ITA No. 323/Ahd/2025 and 151 days in ITA No. 324/Ahd/2025 is condoned. Facts of the Case 5. The assessee is a company registered under section

ARUNA KISHOR FOUNDATION,VADODARA vs. CIT(EXEMPTION), AHMEDABAD

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

delay of 156 days in ITA No. 323/Ahd/2025 and 151 days in ITA No. 324/Ahd/2025 is condoned. Facts of the Case 5. The assessee is a company registered under section

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

RAJESH AMARSINH PRAJAPATI,AHMEDABAD vs. ITO, WARD-3(2)(4), AHMEDABAD

In the result, appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

section a subdued and subordinate content:- 80 ITR 57(Ker.) 156 ITR 323 (SC) 179 ITR 580 (Cal.) 175 ITR 384 (Ail) 200 ITR 697 (Bom.) 208 ITR 649 (SC)” Mere unsubstantiated explanation would not absolve assesses, burden is on him to prove has been held 208 ITR 668 (Bom.) & 185 ITR 49 (SC). In the circumstances, I agree with

JATIN DILIPBHAI JANI,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee in ITA

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

156 taxmann.com 19 (Pat) held that even if the return filed in response to the notice under section 148 of the Act is after a delay of eight and a half months, there ought to have been notice issued under section 143(2) of the Act for a valid assessment ,as requirement of issuance of notice could not be dispensed

JATIN DILIPBHAI JANI,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee in ITA

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

156 taxmann.com 19 (Pat) held that even if the return filed in response to the notice under section 148 of the Act is after a delay of eight and a half months, there ought to have been notice issued under section 143(2) of the Act for a valid assessment ,as requirement of issuance of notice could not be dispensed

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