THE ITO, (EXEMPTIONS), WARD-2,, AHMEDABAD vs. THE GUJARAT INSTITUTE OF HOUSING & ESTATE DEVELOPERS,, AHMEDABAD

In the result, the appeal of the Department is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

property shows and Cricket Tournaments, for the purpose of which assessee received contribution from both members and non-members. During the course of assessment, the Assessing Officer denied exemption under Sections 11 & 12 of the Act on the ground that the assessee does not have registration under Section 12AA

ROTARY CLUB SOCIAL SECURITIES FUND BHAVNAGAR,BHAVNAGAR vs. THE DIT(EXEMPTION),, AHMEDABAD

In the result, order of the ld

Bench: Shri Mahavir Prasad & Shri Amarjit Singh)

properties of Rana caste or community of Ahmedabad, doing acts to improve education of community to give medical help etc. - Tribunal found that beneficiaries of assessee were members of Rana community meaning thereby natives of Ahmedabad only and other members of community accepted by caste as per old customs and usage of community and staying in Ahmedabad - Tribunal held that

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

12A is continued and was affective for the year under appeal. 7.6. In the absence of any material changed, the revenue is not justified to take a different view of the matter as also submitted by the Learned AR. In this aspect he has relied upon a judgment passed by the Hon’ble Apex Court in the matter of Radhasoami

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

12A is continued and was affective for the year under appeal. 7.6. In the absence of any material changed, the revenue is not justified to take a different view of the matter as also submitted by the Learned AR. In this aspect he has relied upon a judgment passed by the Hon’ble Apex Court in the matter of Radhasoami

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

12A is continued and was affective for the year under appeal. 7.6. In the absence of any material changed, the revenue is not justified to take a different view of the matter as also submitted by the Learned AR. In this aspect he has relied upon a judgment passed by the Hon’ble Apex Court in the matter of Radhasoami

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

12A is continued and was affective for the year under appeal. 7.6. In the absence of any material changed, the revenue is not justified to take a different view of the matter as also submitted by the Learned AR. In this aspect he has relied upon a judgment passed by the Hon’ble Apex Court in the matter of Radhasoami

THE ACIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

property in chattel and not a contract of service. The decisions of CIT v ABG Heavy Industries Ltd. [2010] 322 ITR 323/189 Taxman 54 (Bom.), KMC Construction Ltd 51 SOT 214 (Hyd), Koya & Co. Construction (P.) Ltd. v. Asstt. CIT [2012] 51 SOT 203/21 taxmann.com 35 (Hyd.) (URO) and Radhe Developers v. Union of India

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

property in chattel and not a contract of service. The decisions of CIT v ABG Heavy Industries Ltd. [2010] 322 ITR 323/189 Taxman 54 (Bom.), KMC Construction Ltd 51 SOT 214 (Hyd), Koya & Co. Construction (P.) Ltd. v. Asstt. CIT [2012] 51 SOT 203/21 taxmann.com 35 (Hyd.) (URO) and Radhe Developers v. Union of India

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

property in chattel and not a contract of service. The decisions of CIT v ABG Heavy Industries Ltd. [2010] 322 ITR 323/189 Taxman 54 (Bom.), KMC Construction Ltd 51 SOT 214 (Hyd), Koya & Co. Construction (P.) Ltd. v. Asstt. CIT [2012] 51 SOT 203/21 taxmann.com 35 (Hyd.) (URO) and Radhe Developers v. Union of India

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. AJAY ENGG. INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

property in chattel and not a contract of service. The decisions of CIT v ABG Heavy Industries Ltd. [2010] 322 ITR 323/189 Taxman 54 (Bom.), KMC Construction Ltd 51 SOT 214 (Hyd), Koya & Co. Construction (P.) Ltd. v. Asstt. CIT [2012] 51 SOT 203/21 taxmann.com 35 (Hyd.) (URO) and Radhe Developers v. Union of India

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

property in chattel and not a contract of service. The decisions of CIT v ABG Heavy Industries Ltd. [2010] 322 ITR 323/189 Taxman 54 (Bom.), KMC Construction Ltd 51 SOT 214 (Hyd), Koya & Co. Construction (P.) Ltd. v. Asstt. CIT [2012] 51 SOT 203/21 taxmann.com 35 (Hyd.) (URO) and Radhe Developers v. Union of India

THE DY. CIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. THE NEW ENGLISH SCHOOL TRUST,, ANAND

In the result, appeal of the Revenue and CO of the assessee, both are dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.2889/Ahd/2016 With Cross Objection No.03/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2013-14

House Ta: Anand Dist: Anand. Ashram Road Ahmedabad 380 009. PAN : AAATT 2113 M अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent) Revenue by : Shri Prasoon Kabra, Sr.DR Assessee by : Shri Samir Parikh, AR सुनवाई क" तार"ख/Date of Hearing : 24/04/2018 घोषणा क" तार"ख /Date of Pronouncement: 10/05/2018 आदेश/O R D E R PER RAJPAL YADAV, JUDICIAL MEMBER: Revenue

SANKALP DISABLE ASSOCIATION,,AHMEDABAD vs. THE CIT(EXEMPTIONS),, AHMEDABAD

In the result, appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1938/Ahd/2017 "नधा"रण वष"/Asstt. Year:- Sankalp Disable Vs. Cit (Exemptions) Association Ahmedabad. 5Th Floor, Arthi Complex B/H. L.G. Show Room Opp: Krishna Centre Nr.Mithakhali Six Road Ahmedabad 380 006. Pan : Aalts 1604 H

housing scheme under "Sankalp Viklang Avas Yojana" : i) Shri Ramesh Patel Shri Kamlesh Patel ii) Sankalp Corporation iii) Sankalp Corporation Put. Ltd - iv) Sollywood Corporation Pvt. Ltd v) Solly wood Corporation vi) However, in the audit report the auditors have mentioned that these advances were interest bearing and interest at 12% is being charged on these advances. The submission made

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

12A) Nothing contained in sub-section (12) shall apply to any enterprise or undertaking which is transferred in a scheme of amalgamation or demerger on or after the 1st day of April, 2007. (13) Nothing contained in this section shall apply to any Special Economic Zones notified on or after the 1st day of April, 2005 in accordance with

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

12A) Nothing contained in sub-section (12) shall apply to any enterprise or undertaking which is transferred in a scheme of amalgamation or demerger on or after the 1st day of April, 2007. (13) Nothing contained in this section shall apply to any Special Economic Zones notified on or after the 1st day of April, 2005 in accordance with

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

12A) Nothing contained in sub-section (12) shall apply to any enterprise or undertaking which is transferred in a scheme of amalgamation or demerger on or after the 1st day of April, 2007. (13) Nothing contained in this section shall apply to any Special Economic Zones notified on or after the 1st day of April, 2005 in accordance with

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

12A) Nothing contained in sub-section (12) shall apply to any enterprise or undertaking which is transferred in a scheme of amalgamation or demerger on or after the 1st day of April, 2007. (13) Nothing contained in this section shall apply to any Special Economic Zones notified on or after the 1st day of April, 2005 in accordance with

M/S. DOSHION PRIVATE LTD.,,AHMEDABAD vs. ADDL.CIT, RANGE-1,, AHMEDABAD

Bench: Shri P.M. Jagtap, Vice- & Ms. Madhumita Roy

12A (House No.13), Sigma Corporate, 2096/Ahd/2014 DCIT (OSD), Range-1, 2010-11 B/h. Rajpath Club, Off. Ahmedabad S.G. Road, Bodakdev, Ahmedabad-380054 PAN : AAACD 8771 G M/s. Doshion Ltd., DCIT (OSD), Range-1, 2412/Ahd/2014 2010-11 Ahmedabad Ahmedabad PAN : AAACD 8771 G M/s. Doshion Pvt. Ltd., 1408/Ahd/2018 ACIT, Range-1, 2011-12 Ahmedabad Ahmedabad PAN : AAACD 8771 G M/s. Doshion