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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

37. On a conspectus of Section 153A(1) of the Act, read with the provisos thereto, and in the light of the law explained in the aforementioned decisions, the legal position that emerges is as under: i. Once a search takes place under Section 132 of the Act, notice under Section 153 A(1) will have to be mandatorily issued

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

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

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

delay of 86 days is condoned, and the appeal is admitted for adjudication on merits. Brief Facts of the Case 4. The assessee company, Atul Ltd., is engaged in the business of manufacturing dyes, specialty chemicals, agrochemicals, bulk drugs, commodity chemicals, and power generation. For AY 2017–18, the assessee filed its return of income on 29.11.2017 declaring total income

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

37 as against section 69C r.w.s. 115BBE of the Act in relation to the solitary addition made while framing the assessment cannot be a ground to invoke provisions of section 263 of the Act. 4. The Ld. PCIT has erred, both in law and on facts, in not appreciating that provisions of section 263 could not have been invoked

RURAL DEVELOPMENT FOUNDATION,ANAND vs. CPC, BENGALURU JURIS. AO- THE ITO, WARD-EXEMPTION, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.927/Ahd/2025 िनधा"रण वष" /Assessment Year : 2019-20 Rural Development Cpc, Bengaluru बनाम/ Foundation Juris.Ao – The Ito Ward- V/S. Aitc, 2Nd Floor Exemption Narayan Complex Vadodara – 390 007 Nr.Shubh Laxmi Shopping Centre Station Road Anand – 388 001 "थायी लेखा सं./Pan: Aabtr 1090 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Ms. Arti N. Shah, Ar Revenue By : Shri Rameshwar P. Meena, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 17/10/2025 घोषणा की तारीख /Date Of Pronouncement: 29/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has 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 21/02/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2019-2020. 2. The Assessee Has Raised The Following Grounds Of Appeal: Rural Development Foundation Vs. Cpc, Bengaluru Juris Ao The Ito, Ward-Exemption Asst. Year : 2019-20

1,13,37,985/- and grant exemption as per law. However, the CPC, Bengaluru, rejected the rectification petition vide order dated 27.06.2023, holding that such an issue did not fall within the ambit of a “mistake apparent from record” under section 154 of the Act. 4. Aggrieved by the said order, the assessee preferred an appeal before the CIT(Appeals

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

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

condoning the delay was not correctly exercised by the Commissioner Income Tax. 15.1 Similarly co-ordinate Bench of this Tribunal in the case ITO -Vs- Ramji Mandir Religious And Charitable Trust reported in (2023) 69 CCH 0288 Ahd Trib distinguished the Apex Court judgement and held as follows: I.T.A Nos. 342/Ahd/2023 & 5 Ors. A.Ys. 2016-17 to 2018-19 Page

JT.CIT(E),CIRCLE -2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

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

condoning the delay was not correctly exercised by the Commissioner Income Tax. 15.1 Similarly co-ordinate Bench of this Tribunal in the case ITO -Vs- Ramji Mandir Religious And Charitable Trust reported in (2023) 69 CCH 0288 Ahd Trib distinguished the Apex Court judgement and held as follows: I.T.A Nos. 342/Ahd/2023 & 5 Ors. A.Ys. 2016-17 to 2018-19 Page

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

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

condoning the delay was not correctly exercised by the Commissioner Income Tax. 15.1 Similarly co-ordinate Bench of this Tribunal in the case ITO -Vs- Ramji Mandir Religious And Charitable Trust reported in (2023) 69 CCH 0288 Ahd Trib distinguished the Apex Court judgement and held as follows: I.T.A Nos. 342/Ahd/2023 & 5 Ors. A.Ys. 2016-17 to 2018-19 Page

JT.CIT(EXEMPTION)CIRCL-2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY, VADODARA

In the result, the appeal of the Department is dismissed

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

condoning the delay was not correctly exercised by the Commissioner Income Tax. 15.1 Similarly co-ordinate Bench of this Tribunal in the case ITO -Vs- Ramji Mandir Religious And Charitable Trust reported in (2023) 69 CCH 0288 Ahd Trib distinguished the Apex Court judgement and held as follows: I.T.A Nos. 342/Ahd/2023 & 5 Ors. A.Ys. 2016-17 to 2018-19 Page

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

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

condoning the delay was not correctly exercised by the Commissioner Income Tax. 15.1 Similarly co-ordinate Bench of this Tribunal in the case ITO -Vs- Ramji Mandir Religious And Charitable Trust reported in (2023) 69 CCH 0288 Ahd Trib distinguished the Apex Court judgement and held as follows: I.T.A Nos. 342/Ahd/2023 & 5 Ors. A.Ys. 2016-17 to 2018-19 Page