DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

property of the company and not of the Director from whose custody it was found. Therefore, in such non-descript and innocuous situation, where the quantum assessment itself is susceptible, the consequence in form of penalty would not, in our view justified. 9.4 Coming to the case of Snita Transport (P) Ltd vs. DCIT reported in 42 taxmann.com

THE ACIT CIRCLE-3(3), AHMEDABAD vs. SHRI CHANDRAKANT G PATEL, AHMEDABAD

Appeal of the Revenue is dismissed

house Coopers Pvt. Ltd. vs. CIT [2012] 348 1TR 306 (SC) that such inadvertence cannot be termed as an instance attracting the impugned penalty provision in Section 271(1)(c) of the Act. We repeat that the assessee'smultifolded errors hereinabove inter alia in not having declared only two sale transactions instead of three, not adjusting cost of indexation

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

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

271(1)(c) of the Act. 18. In appeal before ld. CIT(A), he dismissed the appeal of the assessee in respect of all grounds raised before him. In respect of loan of Rs. 2,80,000/-from M/s. Ram Lakhan Sharma, ld. CIT(A) noted that except the copy of ledger account of Mr. Ram Lakhan Sharma, the assessee

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

271(1)(c) of the Act. Having considered the record, we find that both the assessment order and the appellate order are reasoned and speak to the issues raised by the assessee. No specific instance has been pointed out to demonstrate any material submission having been overlooked. As regards Ground No. 4, it is well settled that initiation of penalty

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

271(1)(c) of the Act. Having considered the record, we find that both the assessment order and the appellate order are reasoned and speak to the issues raised by the assessee. No specific instance has been pointed out to demonstrate any material submission having been overlooked. As regards Ground No. 4, it is well settled that initiation of penalty

KIRITKUMAR FAKIRCHAND MEHTA,AHMEDABAD vs. ACIT, CIRCLE-5(2), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 349/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2015-2016 Kiritkumar Fakirchand Mehta, A.C.I.T., 2Nd Floor, P.K. House, Vs. Circle-5(2), B/H, Mj Library, Ahmedabad. Ellisbridge, Ahmedabad.

House, Vs. Circle-5(2), B/h, MJ Library, Ahmedabad. Ellisbridge, Ahmedabad. PAN: ABEPM2721P (Applicant) (Respondent) Assessee by : Shri Deepak R. Shah, A.R Revenue by : Shri V.K. Singh, Sr. DR सुनवाई की तारीख/Date of Hearing : 28/04/2022 घोषणा की तारीख /Date of Pronouncement: 31/05/2022 आदेश/O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: The captioned appeal has been filed

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

271(1)(c) of the Act has been altered by the Tribunal, there is no scope of levy of penalty in the instant facts. 10. We have heard the rival contentions and perused the material available on record. 11. We observe that initially, the assessee filed return of income claiming benefit of exemption under Sections

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement