THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section 36(1)(iii) 7 Disallowance of Sales Promotion / Business 23,05,47,312 Promotion Expenses under Section 37 8 Disallowance of Commission Paid to Non- 23,71,88,037 Residents 3. Aggrieved by the assessment order, the assessee filed

SANJAY JAYANTILAL SHAH,AHMEDABAD vs. THE ITO, WARD-2(1)(1), AHMEDABAD

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

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2014-2015 Sanjay Jayantilal Shah Ito, Ward-2(1)(1) 202/A, Shivalik 10 Vs. Vejalpur Opp: Sbi Zonal Office Ahmedabad. Ambawadi, Ahmedabad 380 015 Pan : Aktps 8891 A (Applicant) (Responent) : Assessee By Shri S.N. Divatia & Shri Samir Vora, Ars. : Shri Kalpesh Rupavatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश/O R D E R आदेश आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 29.11.2024 Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As "Cit(A)"], For The Assessment Year 2014–15, Arising Out Of The Assessment Order Dated 31.03.2022 Passed U/S 147 Read With Section 144B Of The Income-Tax Act, 1961 (Hereinafter Referred To As "The Act") By The National Faceless Assessment Centre, Delhi [Hereinafter Referred To As "Assessing Officer Or Ao"].

penalty proceedings u/s 271(1)(c) for furnishing inaccurate particulars of income and directed charging of interest u/s 234A, 234B and 234C of the Act. 2.6 Aggrieved by the aforesaid assessment, the assessee carried the matter in appeal before the ld. CIT(A)/NFAC. In the appellate proceedings, the assessee submitted, inter alia, bank statements, contract notes, share sale bills

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-3(3)(2), (FORMERLY ITO, WARD-3(3)(3),, AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

penalty u/s. 271(1)(c) of the Act. 8. Both the lower authorities have passed the orders without properly appreciating the facts and law on the issue. The action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed. I.T.A Nos. 85 & 87/Ahd/2024 A.Y. 2013-14 Page

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(2)(FORMERLY ITO, WARD-3(3)(3)), AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

penalty u/s. 271(1)(c) of the Act. 8. Both the lower authorities have passed the orders without properly appreciating the facts and law on the issue. The action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed. I.T.A Nos. 85 & 87/Ahd/2024 A.Y. 2013-14 Page

NALINI VIJAY SHAH,SATELLITE vs. WARD 3(1)(2) AHMEDABAD, AHMEDABAD

In the result, all appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

251(1)(a) as the assessment was concluded ex parte under section 144. 4.2 That in the law and/ or on facts, the Ld. CIT(A) ought to have set a side the assessment as per Section 25 1(1) (a) as the assessment was concluded ex parte under section 144. 5.1 The Ld. CIT(A) has grievously erred

NALINI VIJAY SHAH,AHMEDABAD vs. ITO WARD 3(1)(2), AHMEDABAD

In the result, all appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

251(1)(a) as the assessment was concluded ex parte under section 144. 4.2 That in the law and/ or on facts, the Ld. CIT(A) ought to have set a side the assessment as per Section 25 1(1) (a) as the assessment was concluded ex parte under section 144. 5.1 The Ld. CIT(A) has grievously erred

NALINI VIJAY SHAH,AHMEDABAD vs. ITO WARD 3(1)(2), AHMEDABAD

In the result, all appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

251(1)(a) as the assessment was concluded ex parte under section 144. 4.2 That in the law and/ or on facts, the Ld. CIT(A) ought to have set a side the assessment as per Section 25 1(1) (a) as the assessment was concluded ex parte under section 144. 5.1 The Ld. CIT(A) has grievously erred

NALINI VIJAY SHAH,AHMEDABAD vs. ITO WARD 3(1)(2), AHMEDABAD

In the result, all appeals filed by the assessee are allowed for\nstatistical purposes

251(1)(a) as the assessment was concluded ex parte\nunder section 144.\n5.1 The Ld. CIT(A) has grievously erred in law and / or on facts in upholding\nthe invocation of the provisions of Section 115BBE\n5.2 That in the law and/or on facts, the Ld. CIT(A) ought not to have upheld\nthe invocation of the provisions

TEJAS GHANSHYAMBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

271(1) (c) of the Act. 3. The appellant craves liberty to add, alter, amend any ground of appeal. 5. Ld. Counsel for the assessee submitted that belated Return of Income cannot deny deduction u/s. 54F of the Act as held by the I.T.A No. 628/Ahd/2025 A.Y. 2016-17 Page No 3 Tejas Ghanshyanbhai Patel vs. ITO Co-ordinate Bench

GOVINDBHAI BHAVANDAS PATEL,AHMEDABAD vs. ITO WARD 4(2)(2), AHMEDABAD (EXISTING ITO WARD 4(2)(1), AHMEDABAD), AHMEDABAD

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: Ld. Cit(A) Who Has Set Aside The Exparte Assessment Order Invoking Section 251(1)(A) Of The Act By Observing As Follows:

penalty proceedings u/s. 271(1)(c) of the Act. 7. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 5. None appeared on behalf of the assessee. RPAD notice sent to the assessee was returned with postal remark, the assessee “Left” from the above address. Further no details or documents filed

SHRI RUSHABHDEV SWETAMBAR MURTIPUJAK JAIN SANGH,AHMEDABAD vs. THE ITO, WARD-2 (EXEMPTION), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

penalty proceedings under section 271(1)(c) for concealment of income and directed the charging of interest under sections 234A, 234B, 234C of the Act. 5. Aggrieved by the assessment order passed under section 144 read with section 147, the assessee preferred an appeal before the learned CIT(A). The assessee raised multiple legal and factual grounds, contending that

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

271(1)(c) of the I.T. Act for furnishing inaccurate particulars of income. (Addition of Rs. 1,80,69,095/-)” AYs:2014-15 & 2015-16 Sh. Sanjay Kishanlal Bishnoi 4.4 The AO on examination of the details, material, SCN , concluded that the assessee was involved in the undervaluation of imports. The assessee was having understanding with the supplier wherein

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

271(1)(c) of the I.T. Act for furnishing inaccurate particulars of income. (Addition of Rs. 1,80,69,095/-)” AYs:2014-15 & 2015-16 Sh. Sanjay Kishanlal Bishnoi 4.4 The AO on examination of the details, material, SCN , concluded that the assessee was involved in the undervaluation of imports. The assessee was having understanding with the supplier wherein

THE ITO, WARD-1(2)(4), AHMEDABAD vs. SHRI. SURESHCHANDRA SHANTILAL BRAHMBHATT, AHMEDABAD

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

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2016-17 Income Tax Officer, Shri. Sureshchandra Shantilal Ward-1(2)(4), Ahmedabad, Brahmbhatt, Room No. 220, V. 4 Shreenath Bangalow Part-2 2Nd Floor, Aayakar Bhawan, Opp. Matrushree Party Plot, Near Sachin Tower, Vejalpur, Chandkheda, Ahmedabad-380005 Ahmedabad-380051, Gujarat Gujarat Pan:Actpb8904H (Appellant) (Respondent) Assessee By: Sh. Tushar Hemani, Sr. Ar & Sh. Parimalsinh Parmar, Ar Revenue By: Sh. Prasad Rao Waghe Annasaheb, Sr. Dr Date Of Hearing: 25.01.2024 Date Of Pronouncement: 03.04.2024

u/s 68 w.r.t. advances granted as well unsecured loans raised in the preceding years, have not stood the verification by the AO. Rule 46A is not merely an empty formality. 14 AY:2016-17 Sh. Sureshchandra Shantilal Bramhbhatt Rule 46A of the 1962 is reproduced hereunder and sub-rule 3 of Rule 46A is relevant: “Production of additional evidence before

JADE GRANITES INDUSTRIES,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(1),, AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: The Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Which Has Arisen From The Appellate Order Dated 23-11-2023 In Din & Order No. Itba/Nfac/S/250/2023-24/1058173176(1)

Penalty proceedings u/s. 271(1)(c) of the Act are also initiated separately. [Addition Rs.30,00,000] In support of above discussion relied on following judicial decision: In Tolaram Daga v. CIT (1966) 59 ITR 632 (Gau.) the High Court held that requiring the firm or the individual partner to go further and adduce proof of the sources from which

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under section 271(1)(c) of the Act were initiated for concealment of income and furnishing inaccurate particulars. 5. In appeal, CIT(Appeals) noted that the Assessing Officer had added the entire amount under Section 68 of the Act without verifying whether all eight bank accounts actually belonged to the HUF and treated the entire amount as unexplained

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under section 271(1)(c) of the Act were initiated for concealment of income and furnishing inaccurate particulars. 5. In appeal, CIT(Appeals) noted that the Assessing Officer had added the entire amount under Section 68 of the Act without verifying whether all eight bank accounts actually belonged to the HUF and treated the entire amount as unexplained

INCOME TAX WARD 4(2)(3) AHMEDABAD , AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under section 271(1)(c) of the Act were initiated for concealment of income and furnishing inaccurate particulars. 5. In appeal, CIT(Appeals) noted that the Assessing Officer had added the entire amount under Section 68 of the Act without verifying whether all eight bank accounts actually belonged to the HUF and treated the entire amount as unexplained