M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, 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.-2, 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, INT.TAXA.-2, 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

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

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

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

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

ROTOMAG MOTORS & CONTROLS (P) LTD.,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

Appeal is allowed

u/s. 234A/B/C and 244A of the\nAct.\n17. The learned CIT(A) has erred in law and on facts of the case in confirming\naction of the Id. AO in initiating penalty proceedings under Section\n274.r.w.s 271(1)(c) of the Act.\n18.The appellant craves leave to add, amend, alter, edit, delete, modify or\nchange

BRIJESHKUMAR NATVARLAL PATEL,AHMEDABAD vs. ITO, WARD-1(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

penalty proceedings u/s 271(1)(c) of the Act is unjustified. 7. Charging of interest u/s 234A, 234B, 234C of the Act are unjustified.” 3. The solitary issue in the present appeal relates to addition made to the income of the assessee on account of investment made in a property purchased in the impugned year amounting to Rs.66.95 Lakhs

SHRI RUSHABHDEV SWETAMBAR MURTIPUJAK JAIN SANGH,AHMEDABAD vs. THE ITO, WARD-2 (EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

Permanent Account Numbers, namely AAATR2081G (old PAN) and AAATR5288B (new PAN). The old PAN had been surrendered with the Department on 26.07.2012, and all subsequent returns of income had been filed only under the new PAN. The assessee argued that the Assessing Officer, having issued the notice under section 148 on the surrendered PAN, had assumed jurisdiction over