SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

E R PER T.R. SENTHIL KUMAR, JUDICIAL MEMBER: All the three appeals are relating to the Assessment Year (AY) 2009-10. Cross-appeals are filed by the Assessee (in ITa No.1741/Ahd/2009) and Revenue (in ITA No.1785/Ahd/2019 respectively as against the appellate order dated 27-09-2019 passed by the Commissioner of Income Tax (Appeals)-2, Vadodara ITA Nos.1741 & 1750/Ahd/2019

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act on account of the transfer / pricing adjustment of Rs. 29,43,61,998 made in relation to the services rendered to Hazira LNG Private Limited

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act on account of the transfer / pricing adjustment of Rs. 29,43,61,998 made in relation to the services rendered to Hazira LNG Private Limited

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act on account of the transfer / pricing adjustment of Rs. 29,43,61,998 made in relation to the services rendered to Hazira LNG Private Limited

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

2. On the facts and in the circumstances of the case and in law, the learned CIT(A) has erred in confirming levy of penalty under Section 271(l)(c) of the Act on account of the transfer / pricing adjustment of Rs. 29,43,61,998 made in relation to the services rendered to Hazira LNG Private Limited

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.

E R PER BENCH: The captioned appeals have been filed at the instance of the different Assessee against the separate orders of the Ld. Commissioner of Income-Tax (Appeals), Ahmedabad, arising in the matter of penalty order passed u/s 271(1)(c) of the Income Tax Act 1961 (here-in-after referred to as "the Act") relevant to the Assessment

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.

E R PER BENCH: The captioned appeals have been filed at the instance of the different Assessee against the separate orders of the Ld. Commissioner of Income-Tax (Appeals), Ahmedabad, arising in the matter of penalty order passed u/s 271(1)(c) of the Income Tax Act 1961 (here-in-after referred to as "the Act") relevant to the Assessment

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.

E R PER BENCH: The captioned appeals have been filed at the instance of the different Assessee against the separate orders of the Ld. Commissioner of Income-Tax (Appeals), Ahmedabad, arising in the matter of penalty order passed u/s 271(1)(c) of the Income Tax Act 1961 (here-in-after referred to as "the Act") relevant to the Assessment

PASL WINDTECH PVT.LTD.,,AHMEDABAD vs. ITO, WARD-3(1)(2),, AHMEDABAD

In the result, appeal filed by the Assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad)

penalty proceedings u/s 271 (l)(c) of the Act is not justified. 3. It was noticed that assessee company has taken loan of Rs. 83,00,000/- from M/s. Patel Alloy Steel Pvt. Ltd. (PASPL). As per the data available the assessee company was itself holding 22.19% shares of PASPL. It was further noticed that the remaining 72.67% shares

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

E R PER BENCH: These are appeals filed by the Assessee for various assessments years against levy of penalty by Ld. CIT(A)-3, Ahmedabad vide separate orders dated 27.12.2018, 27.12.2019 and 27.02.2019. Since common facts and issues for consideration are before us for all the years under consideration, all the appeals are being disposed

THE ACIT CIRCLE-3(3), AHMEDABAD vs. SHRI CHANDRAKANT G PATEL, AHMEDABAD

Appeal of the Revenue is dismissed

e letter dated 27/06/2016 is general details and in such letter, AO has not pointed out that appellant has claimed false claim u/s 2(14) and offered taxable income as exempt income which means that it cannot be said that disclosure made by appellant is only account of detection by AO. It is true that assessment proceedings have already started