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

b). The Assessing Officer has made disallowance of Rs.4,22,77,759/- u/s. 14A read with Rule 8D of the income -tax Rule, 1962 and penalty proceedings u/s. 271(1)(c) had also been initiated in the assessment order. The appellant had preferred appeal against the assessment order before the CIT (A)-II, Vadodara and further the appellant

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

b). The Assessing Officer has made disallowance of Rs.4,22,77,759/- u/s. 14A read with Rule 8D of the income -tax Rule, 1962 and penalty proceedings u/s. 271(1)(c) had also been initiated in the assessment order. The appellant had preferred appeal against the assessment order before the CIT (A)-II, Vadodara and further the appellant

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s 271(1)(c) of the Income Tax Act, 1961 passed by the Assessing Officer on 30.03.2016. ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years –2005-06 to 2011-12 2. The Ld. CIT(A) has erred on facts and in law in upholding the penalty levied on additions made by the Assessing Officer

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.

B, Jadav Chambers, Nos.259- 2010-11 Ashram Road, A.C.I.T, 9-10. 260/Ahd/2022 & Ahmedabad-380009. Central Circle-(1)(2), 2011-12 Ahmedabad. PAN: ASQPS7606E (Applicant) (Respondent) Assessee by : Ms Nupur Shah, A.R Revenue by : Shri Ashok Kumar Suthar, Sr.DR सुनवाईकीतारीख/Date of Hearing : 19/01/2024 घोषणाकीतारीख/Date of Pronouncement: 10/04/2024 आदेश/O R D E R PER BENCH: The captioned appeals have

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.

B, Jadav Chambers, Nos.259- 2010-11 Ashram Road, A.C.I.T, 9-10. 260/Ahd/2022 & Ahmedabad-380009. Central Circle-(1)(2), 2011-12 Ahmedabad. PAN: ASQPS7606E (Applicant) (Respondent) Assessee by : Ms Nupur Shah, A.R Revenue by : Shri Ashok Kumar Suthar, Sr.DR सुनवाईकीतारीख/Date of Hearing : 19/01/2024 घोषणाकीतारीख/Date of Pronouncement: 10/04/2024 आदेश/O R D E R PER BENCH: The captioned appeals have

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.

B, Jadav Chambers, Nos.259- 2010-11 Ashram Road, A.C.I.T, 9-10. 260/Ahd/2022 & Ahmedabad-380009. Central Circle-(1)(2), 2011-12 Ahmedabad. PAN: ASQPS7606E (Applicant) (Respondent) Assessee by : Ms Nupur Shah, A.R Revenue by : Shri Ashok Kumar Suthar, Sr.DR सुनवाईकीतारीख/Date of Hearing : 19/01/2024 घोषणाकीतारीख/Date of Pronouncement: 10/04/2024 आदेश/O R D E R PER BENCH: The captioned appeals have

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

1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO in the notice issued under Section 274 r.w.s. 271(l)(c) did not specify under which limb

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

1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO in the notice issued under Section 274 r.w.s. 271(l)(c) did not specify under which limb

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

1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO in the notice issued under Section 274 r.w.s. 271(l)(c) did not specify under which limb

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

1. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in confirming levy of penalty under Section 271(l)(c) of the Act even in a situation wherein the learned AO in the notice issued under Section 274 r.w.s. 271(l)(c) did not specify under which limb

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

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

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

u/s. 271(1)(c) cannot be imposed. This view gets support from the ratio laid down in the case of Reliance Petroproducts Pvt. Ltd. (supra). Hence the penalty imposed by the Assessing Officer on this account is directed to be deleted and appellant succeeds in respect of Ground No.10.” 27. Being aggrieved by the order of the learned