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

NILESH JAYANTILAL SHAH,AHMEDABAD vs. NFAC, DELHI, JURIDIS. AO- THE ITO, WARD-2(1)(2), AHMEDABAD

The appeals of the assessee are allowed for\nstatistical purposes

u/s 271B are wrongly initiated on facts of the\ncase. It be so held now.\n9. The assessee craves leave to add, amend, alter, delete, change or\nmodify any or all grounds of appeal before or at the time of the hearing.\"\n6. Shri S.N. Divatia, Ld. AR of the assessee, explained that the\nassessee is a trader

SNEHA PAWAN AGARWAL,AHMEDABAD vs. ITO WARD 1(1)(3), AHMEDABAD

The appeals are allowed for statistical purposes

penalty proceedings\nunder sections 271(1)(b) and 271(1)(c) of the Act despite there being no\nconscious OR deliberate default by the assessee. The non-compliance was\ndue to genuine non-receipt of communications, not due to any intent to conceal\nincome OR furnish inaccurate particulars.\n5. Section 234A, 234B, 234C: The Ld. AO has erred

SNEHA PAWAN AGARWAL,AHMEDABAD vs. ITO WARD 1(1)(3), AHMEDABAD

The appeals are allowed for statistical purposes

penalty proceedings\nunder sections 271(1)(b) and 271(1)(c) of the Act despite there being no\nconscious OR deliberate default by the assessee. The non-compliance was\ndue to genuine non-receipt of communications, not due to any intent to conceal\nincome OR furnish inaccurate particulars.\n5. Section 234A, 234B, 234C: The Ld. AO has erred

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

section 271(1)(c) and as such the penalty and interest u/s 234A, 234B and 234C may please be deleted

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

section 271(1)(c) and as such the penalty and interest u/s 234A, 234B and 234C may please be deleted

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

section 271(1)(c) and as such the penalty and interest u/s 234A, 234B and 234C may please be deleted

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MAHARASHTRA vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,AHMEDABAD vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. MUKESH MOHANLAL VAGHELA, MUMBAI

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) , AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

u/s. 69Con account of Unexplained expenditure based on entries in the ledger "Mukeshbhai Ratanjyot" in the diaries seized from the premises of Shri Prakash Sanghvi. The learned CIT (A) has erred in confirming the action of the AO in invoking s. 115BBE in respect of the said addition. 5. The learned CIT(A) has erred in not holding that

RAJENDRA GADHIA,GANDHINAGAR vs. INCOME TAX OFFICER, INCOME TAX OFFICER, WARD , INT.TAX, AHMNAVJEEVAN TRUST BUILDING

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.31/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Rajendra Gadhia The Income Tax Officer बनाम/ Plot No.672 Ward-1, Int.Tax. V/S. Pachasheel Park Ahmedabad Sector No.21 Gandhinagar – 382 021 "थायी लेखा सं./Pan: Bcppg 3929 Q अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Parimalsingh B. Parmar, Ar Revenue By : Shri Surendra Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 03/10/2024 घोषणा की तारीख /Date Of Pronouncement: 10/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

penalty u/s 271 AAC (1) of the I. T. Act, 1961. 5) The learned CIT (A) has erred in law and on facts of the case in confirming action of the Id. AO in charging interest u/s. 234A, 234B, 234C of the Act. The appellant craves leave to add, amend, alter, edit, delete, modify or change

BHAGVANJIBHAI SOMABHAI PATEL,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(3)(1), VADODARA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 147 r.w.s. 144B of the Income Tax Act, 1961 [herein after referred as the Act] relating to the assessment year 2013–14. 2. The brief facts of the case is that the assessee is an individual and engaged in the agricultural activities and deriving agricultural I.T.A No. 746/Ahd/2023 A.Y. 2013-14 Page No 2 Bhagvanjibhai Somabhai Patel