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.

B, Jadav Chambers, Nos.259- 2010-11 Ashram Road, A.C.I.T, 9-10. 260/Ahd/2022 & Ahmedabad-380009. Central Circle-(1)(2), 2011-12 Ahmedabad. PAN: ASQPS7606E (Applicant) (Respondent) Assessee by : Ms Nupur Shah, A.R Revenue by : Shri Ashok Kumar Suthar, Sr.DR सुनवाईकीतारीख/Date of Hearing : 19/01/2024 घोषणाकीतारीख/Date of Pronouncement: 10/04/2024 आदेश/O R D E R PER BENCH: The captioned appeals have

SAROJBEN NATVARBHAI PATEL,CHHOTAUDEPUR vs. THE ITO, WARD-3(1)(4), VADODARA

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

Section 149 of Act.\n4. The learned CIT(A) and the AO erred in fact and in law in reopening the\nproceedings u/s. 148 of the Act simply relying upon the information received from\nthe investigation wing of the Income Tax Department.\n5. The learned CIT(A) and the AO erred in fact and in law in making the order

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. SANJAY PRATAPRAI MEHTA, BHAVNAGAR

In the result, appeal of the Department is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

B. Parmar, A.R. Date of Hearing 17.04.2024 Date of Pronouncement 24.04.2024 O R D E R PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER: This appeal has been filed by the Revenue against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), passed for Assessment Year 2014-15 deleting the levy of penalty under Section 271

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution Panel, therefore the Assessing Officer passed the final assessment order u/s. 143(3) r.w.s. 92CA(3) r.w.s. I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 3 Priya Blue Industries

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution Panel, therefore the Assessing Officer passed the final assessment order u/s. 143(3) r.w.s. 92CA(3) r.w.s. I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 3 Priya Blue Industries

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution Panel, therefore the Assessing Officer passed the final assessment order u/s. 143(3) r.w.s. 92CA(3) r.w.s. I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 3 Priya Blue Industries

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution Panel, therefore the Assessing Officer passed the final assessment order u/s. 143(3) r.w.s. 92CA(3) r.w.s. I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 3 Priya Blue Industries

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution Panel, therefore the Assessing Officer passed the final assessment order u/s. 143(3) r.w.s. 92CA(3) r.w.s. I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 3 Priya Blue Industries

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-.\n2. 2. As the assessee has not chosen to challenge the TPO's order\nbefore Dispute Resolution Panel, therefore the Assessing Officer\npassed the final assessment order u/s.143(3) r.w.s.92CA(3) r.w.s.\n153A of the Act determining the income as Rs.22,06,39,716/- by\ndisallowing\n[c] Unexplained rental

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

b] Corporate Guarantee given to AE of Rs.86,80,387/-.\n\n2. 2. As the assessee has not chosen to challenge the TPO's order\nbefore Dispute Resolution Panel, therefore the Assessing Officer\npassed the final assessment order u/s.143(3) r.w.s.92CA(3) r.w.s.\n\n153A of the Act determining the income as Rs.22,06,39,716/- by\ndisallowing

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

penalty u/s. 271(1)(c) of the Act. 10. The Ld. CIT(A) has erred in not considering various facts and in not appreciating the facts and law in their proper perspective. 11. The Appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

penalty u/s. 271(1)(c) of the Act. 10. The Ld. CIT(A) has erred in not considering various facts and in not appreciating the facts and law in their proper perspective. 11. The Appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

penalty u/s. 271(1)(c) of the Act. 10. The Ld. CIT(A) has erred in not considering various facts and in not appreciating the facts and law in their proper perspective. 11. The Appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

penalty u/s. 271(1)(c) of the Act. 10. The Ld. CIT(A) has erred in not considering various facts and in not appreciating the facts and law in their proper perspective. 11. The Appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before

M/S. CHECKMATE FACILITY & ELECTRONIC SOLUTION PVT. LTD.,AHMEDABAD vs. THE DY. COMM. OF INCOME TAX, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

149/-. b) Your Appellant submits that full disclosure was made by the Appellant and not accepting a claim or disallowing expenditure does not amount to furnishing inaccurate particulars of Income and Penalty u/s. 271(l)(c ) cannot be levied. It is therefore submitted that relief claimed above be allowed and the order of the Assessing Officer be modified accordingly. Your

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

149, section 151 and section 153, where the\nAssessing Officer is satisfied that,—\n(a) any money, bullion, jewellery or other valuable article or thing,\nseized or requisitioned, belongs to; or\n(b) any books of account or documents, seized or requisitioned,\npertains or pertain to, or any information contained therein,\nrelates to,\na person other than the person referred

THE UNITED BUILDERS CORPORATION ,,AHMEDABAD vs. DY.CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

The appeal of the assessee is allowed for statistical\npurposes

271(1)(c) of the Act.\n2. At the outset itself it was stated that the issue\nfor\nadjudication in the appeals filed by the two assessees was common\nand identical arising from assessment framed on them u/s 153C\nr.w.s 153A of the Act on account of additions made to their incomes\nfrom documents found during search action undertaken u/s

THE MODERN CONSTRUCTION CO. PVT. LTD.,AHMEDABAD vs. ITO, WARD-2(1)(4), AHMEDABAD

The appeal of the assessee is allowed for statistical\npurposes

271(1)(c) of the Act.\n2. At the outset itself it was stated that the issue for\nadjudication in the appeals filed by the two assessees was common\nand identical arising from assessment framed on them u/s 153C\nr.w.s 153A of the Act on account of additions made to their incomes\nfrom documents found during search action undertaken u/s