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)(c

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)(c

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)(c

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)(c

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)(c

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)(c

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)(c

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

Section 271(l)(c) of the Act cannot be invoked while levying penalty in relation to the transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

Section 271(l)(c) of the Act cannot be invoked while levying penalty in relation to the transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

Section 271(l)(c) of the Act cannot be invoked while levying penalty in relation to the transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

Section 271(l)(c) of the Act cannot be invoked while levying penalty in relation to the transfer pricing adjustment, when the said Explanation was neither referred nor relied upon at the time of initiation of the penalty proceedings under the Act. I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 18 Shell Global Solutions International B.V. vs. DCIT

I- SERVE SYSTEM PVT. LTD.,,GANDHINAGAR vs. DY. COMMISSIONER OF INCOME TAX, GANDHINAGAR CIRCLE,, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Shri P. M. Jagtap & Ms. Suchitra Kamble

condonation of the said delay on the following grounds:- [I-Serve Systems Pvt. Ltd. Vs. DC IT] A.Y. 2010-11 Assessment Order was passed under section 144 of the Act on 21.01.2013 determining total income at Rs.1,59,41,190/-. The Assessing Officer invoked penalty proceedings under section 271(1)(c

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

M/S. WORLD TRADE IMPEX LTD.,,BARODA vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, CIRCLE-5,, BARODA

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

condone the delay occurred in filing the impugned appeal by the assessee and proceed to hear the appeal on merit for the adjudication. ITA nos.1580/AHD/2016 & 639/Ahd//2012 A.Y. 2003-04 7 6. The first issue raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 70,50,096/- on account of cessation

WORLD TRADE IMPEX LTD.,,BARODA vs. THE ACIT.,CIRCLE-4,, BARODA

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

condone the delay occurred in filing the impugned appeal by the assessee and proceed to hear the appeal on merit for the adjudication. ITA nos.1580/AHD/2016 & 639/Ahd//2012 A.Y. 2003-04 7 6. The first issue raised by the assessee is that the learned CIT(A) erred in confirming the addition of Rs. 70,50,096/- on account of cessation

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

section 271(l)(c) of the Act without recording mandatory satisfaction as contemplated under the Act at the time of framing the assessment order. 5. Both the lower authorities have passed the orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE ADIT(EXEMPTION),, AHMEDABAD

In the result, the appeal of the assessee is allowed

section 271(l)(c) of the Act without recording mandatory satisfaction as contemplated under the Act at the time of framing the assessment order. 5. Both the lower authorities have passed the orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

section 271(l)(c) of the Act without recording mandatory satisfaction as contemplated under the Act at the time of framing the assessment order. 5. Both the lower authorities have passed the orders without properly appreciating the fact and that they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which