GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal as time-barred without appreciating that the delay was due to bona fide belief of exemption under section 10(23C)(iiiab)/(iiiac) of the Act and absence of tax consultant, constituting

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal as time-barred without appreciating that the delay was due to bona fide belief of exemption under section 10(23C)(iiiab)/(iiiac) of the Act and absence of tax consultant, constituting

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal as time-barred without appreciating that the delay was due to bona fide belief of exemption under section 10(23C)(iiiab)/(iiiac) of the Act and absence of tax consultant, constituting

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal as time-barred without appreciating that the delay was due to bona fide belief of exemption under section 10(23C)(iiiab)/(iiiac) of the Act and absence of tax consultant, constituting

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

penalty under Section 271(1)(c) of the Act) 2. The assessee has taken the following grounds of appeal: “1. The learned CIT(A) erred in dismissing the appeal as time-barred without appreciating that the delay was due to bona fide belief of exemption under section 10(23C)(iiiab)/(iiiac) of the Act and absence of tax consultant, constituting

CREELOTEX ENGINEERS PVT. LTD.,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-2(4),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

234B and 234C of the I T Act, if any. Give credit for prepaid taxes after due verification. Demand notice and challan issued accordingly. Issue notice u/s. 271(1)(c)of the IT Act.” 11. We have perused the penalty order also. There are only three paragraphs i.e. para-4, 6 and 7, where the AO has made some observation

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

234B and 234C of the Income Tax Act. Penalty Proceeding U/s 271(l)(b): 18) Notice u/s 142(1) requires clarification of the source of the depositing amount in the bank account of Rs.3613600/-. for the same which is shown in the return of income filed in response to notice u/s 148 of Income

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

234B and 234C of the Income Tax Act. Penalty Proceeding U/s 271(l)(b): 18) Notice u/s 142(1) requires clarification of the source of the depositing amount in the bank account of Rs.3613600/-. for the same which is shown in the return of income filed in response to notice u/s 148 of Income

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

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

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

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

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., ,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

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

sections 234B and 234C. 5.5.2 In AY 2012-13, the DB held that the levy of interest is consequential in nature and does not call for separate adjudication once the substantive additions are sustained. The same reasoning applies mutatis mutandis to the present year. 11 Accordingly, Ground 7 is dismissed as consequential. 5.6 Grounds 8 & 9: Penalty Proceedings (u/s 271