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

penalty u/s 271(1)(c) of the Act on addition of " 45,80,841/- made on account of higher profit attributable to project office (PO). The brief facts in relation to this Grounds of Appeal are that during the year under consideration, the Appellant under its contract with Center for High Technology ('CHT') was required to render certain supervisory services

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

penalty u/s 271(1)(c) of the Act on addition of " 45,80,841/- made on account of higher profit attributable to project office (PO). The brief facts in relation to this Grounds of Appeal are that during the year under consideration, the Appellant under its contract with Center for High Technology ('CHT') was required to render certain supervisory services

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

271(1)(c) of the Act. 9. The AO has erred in facts and in law in initiating penalty proceeding u/s 271BA of the Act. 10. Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal. 3. At the very outset, the learned Authorised Representative

THE ACIT,(OSD),RANGE-1,, AHMEDABAD vs. CLP POWER INDIA PVT. LTD.,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

establish that assessee has wrongly claimed expenditure of capital nature as revenue item. It was contended that the action of the assessee lacks bonafide and is thus covered by Explanation 1 to Section 271(1)(c) of the Act. 4. The learned AR for the assessee, on the other hand, submitted that the CIT(A) has examined the issue

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

permanently closed. It be so held now. 5 Confirming levy of interest u/s 234A/234B/234C & 234D is not justified. 6 Initiation of penalty u/s 271(1)(c) of the Act is not justified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any other grounds of appeal at the time of or before the hearing

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

permanently closed. It be so held now. 5 Confirming levy of interest u/s 234A/234B/234C & 234D is not justified. 6 Initiation of penalty u/s 271(1)(c) of the Act is not justified. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any other grounds of appeal at the time of or before the hearing

M/S. JOY GLOBAL (UK) LIMITED,(EARLIER KNOWS AS JOY MINING MACHINERY LIMITED OR 'JMML'),KOLKATTA vs. THE ACIT (INT. TAXN.)-2,, AHMEDABAD

In the result, we allow the Grounds of Appeal of the assessee

penalty proceedings u/s 271(1)(c) of the IT Act, 61 are also initiated for concealment of income on this issue for A.Y.2016-17. I.T.A No. 1483/Ahd/2019 A.Y. 2016-17 Page No 5 M/s. Jay Global (UK) Ltd. vs. ACIT (Int. Taxn. 5. This Draft Assessment order was carried to Dispute Resolution Panel (hereinafter referred to as “DRP”) by the assessee

DHARMIN N THAKKAR (HUF),AHMEDABAD vs. THE ITO, WARD-4(2)(1), AHMEDABAD

In the result, the appeal filed by the Assessee are hereby rejected and is dismissed

Permanent Account Number whose total turnover exceeds or likely to exceed five lakh rupees in any previous year. The assessee has not filed any valid justification for non-compliance on this issue nor has he furnished any evidence in support of the fact that the business was being carried out by him since the Assessment Year 2015-16. However

ELECTROTHERM (INDIA) LIMITED,,AHMEDABAD vs. THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal preferred by the assessee is allowed and the appeal filed by the Revenue is partly allowed

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

271(1)(c) of the Act and therefore the learned AO be directed to drop the penalty proceedings. 4. The appellant craves liberty to add, amend, alter and delete any grounds of appeal before the final hearing” 3. Ground No. 1 relates to addition on account of employees contribution to PF under Section 36(1)(va) to the tune

THE JCIT(OSD), CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. ELECTROTHERM (INDIA) LIMITED,, AHMEDABAD

In the result, the appeal preferred by the assessee is allowed and the appeal filed by the Revenue is partly allowed

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

271(1)(c) of the Act and therefore the learned AO be directed to drop the penalty proceedings. 4. The appellant craves liberty to add, amend, alter and delete any grounds of appeal before the final hearing” 3. Ground No. 1 relates to addition on account of employees contribution to PF under Section 36(1)(va) to the tune

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

u/s. 271(1)(c) on various grounds on which the enhancement was made, 15. The Appellant craves leave to add to, alter, amend or delete any ground of appeal at or before the hearing of this appeal. 5. The 1st issue raised by the assessee in ground No. 1 is general and does not require any separate adjudication. Therefore

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1),, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

u/s. 271(1)(c) on various grounds on which the enhancement was made, 15. The Appellant craves leave to add to, alter, amend or delete any ground of appeal at or before the hearing of this appeal. 5. The 1st issue raised by the assessee in ground No. 1 is general and does not require any separate adjudication. Therefore

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-1,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

u/s. 271(1)(c) on various grounds on which the enhancement was made, 15. The Appellant craves leave to add to, alter, amend or delete any ground of appeal at or before the hearing of this appeal. 5. The 1st issue raised by the assessee in ground No. 1 is general and does not require any separate adjudication. Therefore

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

u/s. 271(1)(c) on various grounds on which the enhancement was made, 15. The Appellant craves leave to add to, alter, amend or delete any ground of appeal at or before the hearing of this appeal. 5. The 1st issue raised by the assessee in ground No. 1 is general and does not require any separate adjudication. Therefore

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under