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.

132A of the Act. The object of Section 153A is to bring under tax the undisclosed income which is found during the course of search or pursuant to search or requisition. Therefore, only in a case where the undisclosed income is found on the basis of incriminating material, the AO would assume the jurisdiction to assess or reassess the total

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020. The relevant extracts of the ruling are reproduced for ready reference: “12. The grounds of appeal taken by the assessee are not in consonance with the Rule 8 of the Income Tax (Appellate

RAVJIBHAI GORDHANBHAI PRAJAPATI,,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2),, AHMEDABAD

In the result, the appeals filed by the assessees in ITA

Bench: Shri Kul Bharatassessment Year: 2012-13 Sureshbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0781K Assessment Year: 2012-13 Rajivbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0713R

271(1)(c) of the I.T. Act and the penalty is to be levied on the income assessed over and above the income returned under section 153A, if any. 8. Further, reliance is placed on the judgement of the Hon’ble Delhi High Court rendered in the case of Principal CIT-19 Vs. Neeraj Jindal (2017) 79 taxmann.com 96 (Delhi

SHRI SURESHBHAI GORDHANBHAI PRAJAPATI,,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2),, AHMEDABAD

In the result, the appeals filed by the assessees in ITA

Bench: Shri Kul Bharatassessment Year: 2012-13 Sureshbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0781K Assessment Year: 2012-13 Rajivbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0713R

271(1)(c) of the I.T. Act and the penalty is to be levied on the income assessed over and above the income returned under section 153A, if any. 8. Further, reliance is placed on the judgement of the Hon’ble Delhi High Court rendered in the case of Principal CIT-19 Vs. Neeraj Jindal (2017) 79 taxmann.com 96 (Delhi

SHRI VITTHALBHAI GORDHANBHAI PRAJAPATI,,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2),, AHMEDABAD

In the result, the appeals filed by the assessees in ITA

Bench: Shri Kul Bharatassessment Year: 2012-13 Sureshbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0781K Assessment Year: 2012-13 Rajivbhai Gordhanbhai Dcit, बनाम/ Prajapati Cc-1(2) 308/43, Prajapati Vas Ahmedabad Vs. S.G. Highway Thaltej Ahmedabad-59 (Appellant) (Revenue ) P.A. No.Aprpp0713R

271(1)(c) of the I.T. Act and the penalty is to be levied on the income assessed over and above the income returned under section 153A, if any. 8. Further, reliance is placed on the judgement of the Hon’ble Delhi High Court rendered in the case of Principal CIT-19 Vs. Neeraj Jindal (2017) 79 taxmann.com 96 (Delhi

ATUL N. SHAH,AHMEDABAD vs. THE JT.CIT, RANGE-4(2), AHMEDABAD

In the result, both the appeals of the assessee are allowed

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita Nos. 952 & 953/Ahd/2023 िनधा"रण वष"/Assessment Year: 2013-14 बनाम बनाम बनाम बनाम Atul N. Shah, 45, Mahalaya Bungalows, Jcit, Vs. Nr. High Court, Sola, Range 4(2), Ahmedabad-380060 Ahmedabad Pan : Ajqps 4627 Q अपीलाथ"/ (Appellant) "त्यथ"/ (Respondent) िनधा" रती की ओर से / Assessee By : Shri Dhrunal Bhatt, Ar "#थ% की ओर से / Revenue By: Shri Atul Pandey, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 29/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 23/08/2024 आदेश आदेश/O R D E R आदेश आदेश

132A on 27/01/2015. (SMC) ITA Nos. 952 & 953/Ahd/2023 Atul N Shah Vs. JCIT AY : 2013-14 6 Statement of Mr Kaushik J Shah, Director of Sudama Resorts Pvt Ltd, was recorded u/s 131(1A) where he confessed to arranging finance for the members of Sudama Resorts Pvt Ltd. He admitted to cheques being obtained from the Financiers. He however

ATUL N. SHAH,AHMEDABAD vs. THE JT.CIT, RANGE-4(2), AHMEDABAD

In the result, both the appeals of the assessee are allowed

Bench: Smt.Annapurna Guptaआयकर अपील सं / Ita Nos. 952 & 953/Ahd/2023 िनधा"रण वष"/Assessment Year: 2013-14 बनाम बनाम बनाम बनाम Atul N. Shah, 45, Mahalaya Bungalows, Jcit, Vs. Nr. High Court, Sola, Range 4(2), Ahmedabad-380060 Ahmedabad Pan : Ajqps 4627 Q अपीलाथ"/ (Appellant) "त्यथ"/ (Respondent) िनधा" रती की ओर से / Assessee By : Shri Dhrunal Bhatt, Ar "#थ% की ओर से / Revenue By: Shri Atul Pandey, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 29/07/2024 घोषणा क" तारीख /Date Of Pronouncement: 23/08/2024 आदेश आदेश/O R D E R आदेश आदेश

132A on 27/01/2015. (SMC) ITA Nos. 952 & 953/Ahd/2023 Atul N Shah Vs. JCIT AY : 2013-14 6 Statement of Mr Kaushik J Shah, Director of Sudama Resorts Pvt Ltd, was recorded u/s 131(1A) where he confessed to arranging finance for the members of Sudama Resorts Pvt Ltd. He admitted to cheques being obtained from the Financiers. He however

RAVINDRABHAI LAKSHMANRAV MANE,AHMEDABAD vs. ITO, WARD-5(3)(5), AHMEDABAD

In the result the appeals filed by the assessee in IT[SS]A Nos

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved. I.T.(SS)A Nos. 51 to 53/Ahd/2019 & Ors. A.Ys

RAVINDRABHAI LAKSHMANRAV MANE,AHMEDABAD vs. ITO, WARD-5(3)(5), AHMEDABAD

In the result the appeals filed by the assessee in IT[SS]A Nos

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

132A of the Act, 1961. However, the completed/unabated assessments can be re-opened by the AO in exercise of powers under sections 147/148 of the Act, subject to fulfilment of the conditions as envisaged/mentioned under sections 147/148 of the Act and those powers are saved. I.T.(SS)A Nos. 51 to 53/Ahd/2019 & Ors. A.Ys

DEPUTY COMMISIONER OF INCOME TAX CENTRAL CIRCLE 1(4) AHMEDABAD, AHMEDABAD vs. FALGUNI SURYAKANT THAKAR , AHMEDABAD

In the result, the appeal filed by the Revenue in quantum appeal in IT(SS)A No

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

penalty order dated 27-06-2022 under section 271(1)(c) of the Act. 3. Aggrieved against the order, assessee filed an appeal before Ld. CIT(A) challenging the jurisdiction of assessment relating to the Asst. Year 2009-10. The Ld. CIT(A) by a detailed order held that the initiation of proceedings u/s. 153C for the Asst. Year