SHRIRAM TUBES PVT. LTD.,,AHMEDABAD vs. THE DCIT.,CIRCLE-4(1)(1), AHMEDABAD

In the result, subject to payment of Rs

Bench: Shri Rajpal Yadav & Shri Pradipkumar Kediaआयकर अपील सं./ Ita No.27 & 28/Ahd/2019 [Asstt.Year: 2007-08]

section 271(1)(c) of the Act was initiated against the assessee, and in an ex parte order penalty of Rs.8,09,40,722/- was imposed vide order dated 28.9.2015. Appeal against this order was presented after expiry of limitation by 27 months. In order to explain the delay, the ITA No.27 and 28/Ahd/2019 4 assessee has filed explanation which

BHADRESH KANCHANLAL JARIWALA,VADODARA vs. THE ITO, WARD-4(1)(4), VADODARA

3 Bhadresh Kanchanlal Jariwala vs. ITO Notice under Date of notice Served on Date of Remarks section appointment 148 23/03/2015 31/03/2015 You have to deliver the return of your income within 30 days from the service of notice u/s 148. No return is filed till date. 142(1) 03/08/2015 Un-served 24/08/2015 Un-served with the remarks "left" by postal

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

THE DCIT, CIRCLE-1(1), NOW CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

THE DCIT, CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

THE ACIT, CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1)(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

penalty proceedings under section 271(1)(c) of the Income Tax Act, 1961 for the alleged concealment and/or furnishing of inaccurate particulars of income. 7.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” ITA No.2858/Ahd/2015 & 05 others Dakshin Gujarat

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under