DHARMENBHAI MAHENDRABHAI SUTARIA,HUF,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.

u/s 271(1)(c) of the Act would be set aside. 9.5.7 In the case of CIT v. SAS Pharmaceuticals 11 taxmann.com 207 (Delhi), the Delhi High Court held that for imposing penalty under section 271(1)(c), concealment of particulars of income or furnishing of inaccurate particular of income by assessee has to be in income-tax return filed

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4. The appellant craves for liberty to add fresh ground(s) of appeal and also to amend, alter, modify any of the grounds of appeal.” 28. The limited issue for consideration for the impugned assessment year is the levy of penalty of Rs. 59,34,456/- under Section 271(1)(c) of the Act by the Assessing Officer and such

SADBHAV ENGINEERING LTD.,AHMEDABAD vs. DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD, DCIT, CENTRAL CIRCLE 1(3), AHMEDABAD

In the result, all the appeals of the assessee are partly allowed\nand that of the Revenue are dismissed

section 153A of the Act is to be treated as return\nfiled under section 139(1) of the Act. The Ld.Counsel for the assessee\nhas borrowed this proposition to contend that accordingly fresh\nclaims can be made in returns filed u/s 153A of the Act. But, we find,\nthat these decisions have been rendered while addressing completely\ndifferent issue, relating

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

AVANI DIPAKBHAI SHAH,VADODARA vs. THE ACIT, CIRCLE INTL. TXN., VADODARA

The appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

4– of Shri Harsh D. Shah under section 69 of the Act, it was not conclusively established who was the real beneficiary of the loan transaction. Accordingly, to safeguard the interest of the Revenue, the Assessing Officer completed the assessment under section 153C read with section 144 on 19.05.2022, adding ₹7,32,68,860/- to the total income

SHRI NAGIN A VAGHELA,VADODARA vs. THE DCIT, CENTRAL CIRCLE-3, VADODARA

In the result, the appeal of the assessee is dismissed for A

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyali.T(Ss).A. Nos.449/Ahd/2019 & 44/Ahd/2020 (A.Ys.: 2011-12 & 2012-13) Deputy Commissioner Of Income Vs. Shri Nagin A. Vaghela, Tax, 11, Purva Bunglow, Nr. Central Circle-3, Manglam Duple, Sama, Vadodara Vadodara [Pan No.Aakpw5302R] (Appellant) .. (Respondent)

132 of the Income Tax Act, 1961, was carried out on the Vaghela Group, including the assessee, on August 30, 2013. Following the search, proceedings under section 153A of the Act were initiated. On February 4, 2014, a notice under section 153A was issued to the assessee, requiring the filing of return of income for Assessment Year

SHRI NAGIN A VAGHELA,VADODARA vs. THE ACIT, CENTRAL CIRCLE-3, VADODARA

In the result, the appeal of the assessee is dismissed for A

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyali.T(Ss).A. Nos.449/Ahd/2019 & 44/Ahd/2020 (A.Ys.: 2011-12 & 2012-13) Deputy Commissioner Of Income Vs. Shri Nagin A. Vaghela, Tax, 11, Purva Bunglow, Nr. Central Circle-3, Manglam Duple, Sama, Vadodara Vadodara [Pan No.Aakpw5302R] (Appellant) .. (Respondent)

132 of the Income Tax Act, 1961, was carried out on the Vaghela Group, including the assessee, on August 30, 2013. Following the search, proceedings under section 153A of the Act were initiated. On February 4, 2014, a notice under section 153A was issued to the assessee, requiring the filing of return of income for Assessment Year

AMISH PRAVINCHANDRA VYAS,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, the question is answered in the negative, i

Bench: Ld. CIT(A) who has confirmed the levy of penalty u/s.271(1)(c) of the Act and dismissed the assessee appeal.

section 271(1)(c) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2013-14. 2. Brief facts of the case is that the assessee is an individual having salary income. There was a search action u/s. 132 of the Act in the premises of the assessee on 04-08-2015 wherein

SUJAN INFRASTRUCTURE PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2006-07. 2. The grounds of appeal raised by the Assessee are as follows:- 1. The learned CIT(A) has erred in law and on facts of the case in confirming initiation of penalty proceedings u/s 271