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 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

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

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

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

132A of the Act, 1961.\nHowever, the completed/unabated assessments can be re-opened by the AO\nin exercise of powers under Sections 147/148 of the Act, subject to fulfilment\nof the conditions as envisaged/mentioned under sections 147/148 of the Act\nand those powers are saved.\nThe question involved in the present set of appeals and review petition is\nanswered accordingly

TECHNODOT ENGINEERS PVT. LTD,GANDHINAGAR vs. THE DCIT, CIRCLE-2(2), AHMEDABAD

Appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokari.T(Ss).A. Nos.147&148/Ahd/2019 (A.Ys.: 2005-06 & 2006-07) Smt. Neelu Sanjay Gupta, Vs. Deputy Commissioner Of L/H. Of Late Shri Sanjay Gupta Income Tax, B-202, Dhananjay Tower, Central Circle-2(2), Anand Nagar Road, Satellite, Ahmedabad Ahmedabad-380015 [Pan No.Adypg0351K] (Appellant) .. (Respondent) I.T(Ss).A. Nos.21 To 23/Ahd/2020 & 15/Ahd/2022 & Ita No. 93/Ahd/2020) (A.Ys.: 2007-08, 2008-09 & 2006-07 & 2010-11 To 2011-12) M/S. Technodot Engineers Ltd., Vs. Deputy Commissioner Of C/O. Cambay Hotel & Resorts, Income Tax, Plot No. 22, 23, 24 Gidc, Central Circle-2(2), Sector-25, Gandhinagar-382010 Ahmedabad [Pan No.Aabct5392A] (Appellant) .. (Respondent)

271(1)(b) was levied on November 27, 2012. The assessee's appeal against the penalty was dismissed by the CIT (A) on May 9, 2013, for failure to comply fully with the notices. The assessee's non-cooperative attitude led to the case being referred for a special audit under Section 142(2A) of the Income

M/S. ATRI DEVELOPERS,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(3),, AHMEDABAD

Appeal is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

penalty u/s 271(l)(c) of the Act.” Revenues’s appeal ITA No.2855/A/2016: “1. The Ld. CIT(A) has erred in law and on facts in allowing the relief of Rs.5,98,26,995/- out of total addition of Rs.6,78,33,882/- made on account of undisclosed income. 1.1 The Ld. CIT(A) has erred