ANKIT PRANLAL PATEL,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

BHARATSINGH AMARSINGH RAJPUT,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

IMTIYAZ KARIMBHAI VHORA,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

SHRIKANTSINGH RAMDAYAL SHAKYA,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

WILSON MIKHAEL TOPNO,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

ARBINDA KUMAR SINGH,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

MAFATBHAI BHIKHABHAI PARMAR,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

JITENDRA KUMAR SHIMPI,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

MAHENDRA AMBALAL ROHIT,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Revision of orders prejudicial to revenue. 263. (1) The 99[Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer 1[or the Transfer Pricing Officer, as the case may be,] is erroneous

M/S GREENWELL ORCHARDS,AHMEDABAD vs. THE PR.CIT-3 , AHMEDABAD

In the result, appeal filed by the Assessee is allowed

u/s. 263 is liable to be quashed. 12.5. Our above view is further supported by the Rulings of the Hon’ble Supreme Court and High Court judgements on this subject which would throw useful light on the scope of enquiry under Explanation 2 to Section 263 of the Act, which are as follows: (a) CIT vs. Nirav Modi

TRUE SPARROW SYSYTEM PVT. LTD,VADODARA vs. THE PR. CIT-2, VADODARA

In the result, we hold that the Ld

263 of the Act to disallow the claim of assessee of Rs. 5,93,30,777/- u/s. 10AA of the Act. 4. Before ld. Pr. CIT, the A.R. of the assessee submitted that assessee satisfied all conditions enumerated u/s. 10AA of the Act and was eligible for I.T.A No. 765/Ahd/2019 A.Y. 2013-14 Page No. 4 True Sparrow System

ADANI INFRASTRUCTURE AND DEVELOPERS PRIVATE LIMITED,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumarshri T.R. Senthil Kumar

revision proceedings for compensation expenses incurred in the year under consideration without considering the fact that such expenditure was incurred as per contractual terms of Memorandum of Understanding and does not represent any penalty which attracts disallowance u/s 28 to 44DA of the Act. 4. In law and in the facts and circumstances of the Appellant's case, the PCIT

MADRESA MOHAMMADIYAN AND PANJATANIYA,DAHOD GUJARAT vs. CIT(E), AHMEDABAD, AHMEDABAD

In the result the appeal filed by the assessee is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Madressa Mohammadiyn & Cit(Exemption) Panjataniya, Madresa Raildings Nehru Bridge B/H. Tower Talav Road, Dahod. Ahmedabad. Pan : Brdmo 8620 D (Applicant) (Responent) : Shri Ankit Chokshi, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 26/09/2025 आदेश आदेश/O R D E R आदेश आदेश

disallowed only 15 percent. Invoking Explanation 2 to section 263 and clause (a) thereof, the PCIT held that the order is deemed to be erroneous and prejudicial to the interests of the Revenue as inquiries or verification which should have been made were not made, and that the Assessing Officer ought to have independently verified genuineness of the trust

MADHYA GUJARAT VIJ COMPANY LTD.,,VADODARA vs. THE PR. COMMISSIONER OF INCOME TAX, -2,, VADODARA

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2013-14 Madhya Gujarat Vij Co. Ltd., The Principal Commissioner Of Vs. Sardar Patel Vidyut Bhavan, Income-Tax-2, Race Course, Vadodara-390007 Vadodara Pan : Aadcm 7439 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Mehul K. Patel, Advocate Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.01.2024 घोषणा क" तारीख /Date Of Pronouncement: 02.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Vadodara-2 [Herein-After Referred To As “Pcit”] Dated 27.03.2019, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2013-14. 2. The Grounds Raised By The Assessee Are As Under:- “(1) That On Facts & In Law, The Learned Cit Has Grievously Erred In Assuming Jurisdiction U/S.263 Of The Act, Without Recording A Satisfaction As To How The Assessment Order Passed U/S 143(3) Of The Act Is Erroneous & Prejudicial To The Interest Of Revenue. (2) That On Facts & In Law, The Proceedings U/S.263 Are Void As The Original Assessment Order Was Passed U/S.143 (3) Of The Act After Due Inquiry & Application Of Mind / & Is Not Erroneous & Prejudicial To The Interest Of The Revenue.

revision of the assessment order was assumed u/s. 263 of the Act noting three irregularities in the same as under:- i) incorrect allowance of interest accrued but not paid on loans from PFC; ii) wrong claim of Bad Debts; iii) incorrect allowance of provision on account of Leave Encashment. These facts find mention at paragraph

SUN PHARMACEUTICAL INDUSTRIES,MUMBAI vs. JCIT 20(3), MUMBAI

In the result appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

u/s 80IE of the Act made on account of apportionment of selling & distribution expenses, R&D expenses, royalty expenses, managerial fee and remuneration to partners SPIL. 11.1 The AO during the assessment proceeding found that that the assessee firm is an eligible entity for deduction under section 80IE of the Act which is managed &controlled by the M/s SPIL

KEPLER HEALTHCARE PRIVATE LIMITED,AHMEDABAD vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaassessment Year : 2018-19 Kepler Healthcare Private Limited, The Pr. Commissioner Of C/O. M S Chhajed & Co., Ca, Vs Income Tax-1, Ahmedabad “Kamal Shanti, Nr. Sardar Patel Statute, Ahmedabad-380014 Pan : Aafck 1130 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri M.S. Chhajed, Ar Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 30/05/2024 घोषणा की तारीख /Date Of Pronouncement : 12/06/2024

u/s 263 of the Act. 8. The ld. PCIT has observed that the distribution of gifts, bags and other articles were in the nature of gifts and were required to be disallowed at 100% of such expenses; whereas the Assessing Officer had disallowed only 10% of the expense. No cogent reason has been given by the ld. PCIT

THE SPORTS CLUB OF GUJARAT LTD.,,AHMEDABAD vs. THE PR. CIT-4, AHMEDABAD

In the result, we are of the view that in light of the discussion above,

disallowed a sum of Rs.7,89,314/-claimed against the incomes chargeable under the head "Income from other sources". Thereafter, the appeal filed by the assessee before the CIT(A)-8, Ahmedabad stood fully allowed in favour of the assessee vide order dated 15.10.2019. 3.1 Ld. Pr. CIT issued notice u/s order passed u/s 263

VIJAY RAJNIKANT PATEL,AHMEDABAD vs. THE PR. CIT-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

disallowance u/s 4oA(s) of the Act. This is absolutely fresh unconnected issues, which the Pr. CIT has picked up. A revision u/s 263