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

u/s. 271(1)(c), such an order of assessment or reassessment shall be deemed to constitute satisfaction of Assessing Officer for initiation of penalty proceedings in term of section 271(1B). Therefore, in view of the above factual and legal position, I hold that Assessing Officer had recorded his satisfaction as mandated by the law and hence arguments

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

282 days (in ITA Nos. 210/Ahd/2020, 211/Ahd/2020 & 214/Ahd/2020) and 332 days (in ITA Nos. 212/Ahd/2020, 213/Ahd/2020, 215/Ahd/2020, 216/Ahd/2020, 217/Ahd/2020 & 218/Ahd/2020). The assessee has submitted similar Affidavits for the impugned years under consideration in which it has been submitted that the order passed Ld. CIT(A) was to be handed over by the assessee to the concerned Tax Practitioner for filing

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

In the result, the appeal filed by the Assessee in ITA No

u/s 14A?\n\n2 The learned CIT(Appeals)) has erred in law and on facts in deleting the penalty of Rs.8,64,686/- on account of repairing expenses.\n\n3. The learned CIT(Appeals)) has erred in law and on facts in deleting the penalty on the issue of addition of Rs.94,71,966/- in total income as per provisions

INDIAN CHRONICLE LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-4(3),, AHMEDABAD

In the result, the appeal ofthe assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1275/Ahd/2012 ("नधा"रण वष" / Assessment Year : 2007-08) Indian Chronicle Ltd. बनाम/ Ito Gujarat Samacharbhavan, Ward4(3), Ahmedabad Vs. Khanpur,Ahmedabad - 380001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaaci0793H (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & अपीलाथ" ओर से/Appellant By : Shri Parimalsinh B. Parmar, A.R. Shri Rignesh Das, Sr. Dr ""यथ" क" ओर से/Respondentby: Date Of Hearing 28/11/2024 Date Of Pronouncement 18/12/2024

271(1)(c) on the ground that the appellant was guilty of concealment of income inasmuch as it had failed to show in its return the total income pursuance to Section 115JB and instead, merely returned total income as per the normal provisions of the Income-tax Act, 1961. The same may be deleted for the reasons stated

YOGESH JASHUBHAI PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(4) NOW WARD- 1(2)(1), AHMEDABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.158/Ahd/2023, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.159/Ahd/2023, Asst.Year 2011-12 Yogesh Jashubhai Patel, The Income Tax Officer Harivallabh Society बनाम/ Ward-3(4) V/S. Naroda Now Ward-1(2)(1) Opp. Devi Cinema Ahmedabad – 380 051 Ahmedabad – 382 345 "थायी लेखा सं./Pan: Audpp 9058 L (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/01/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.158/Ahd/2023:

u/s 271(1)(c) of the Act. 7. Before us, the Counsel for the assessee submitted that the learned CIT(A), NFAC, erred in law and on facts in refusing to condone the delay in filing the appeal and thereby dismissing it in limine without considering the ITA Nos.158 & 159/Ahd/2023 Yogesh Jashubhai Patel vs. ITO Asst. Year

YOGESH JASHUBHAI PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(4) NOW WARD- 1(2)(1), AHMEDABAD

In the result, both the appeals filed by the assessee are allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal1. आयकर अपील सं /Ita No.158/Ahd/2023, Asst.Year 2011-12 2. आयकर अपील सं /Ita No.159/Ahd/2023, Asst.Year 2011-12 Yogesh Jashubhai Patel, The Income Tax Officer Harivallabh Society बनाम/ Ward-3(4) V/S. Naroda Now Ward-1(2)(1) Opp. Devi Cinema Ahmedabad – 380 051 Ahmedabad – 382 345 "थायी लेखा सं./Pan: Audpp 9058 L (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri C. Dharani Nath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 16/09/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeals Have Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/01/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2011-2012. 2. The Assessee Has Raised The Following Grounds Of Appeal In Ita No.158/Ahd/2023:

u/s 271(1)(c) of the Act. 7. Before us, the Counsel for the assessee submitted that the learned CIT(A), NFAC, erred in law and on facts in refusing to condone the delay in filing the appeal and thereby dismissing it in limine without considering the ITA Nos.158 & 159/Ahd/2023 Yogesh Jashubhai Patel vs. ITO Asst. Year

SUJAN INFRASTRUCTURE PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result, the appeal of the assessee is allowed

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

Section 271(1)(c) of the Income-tax Act, 1961’. On this issue, we straight away find that the Assessing Officer vide penalty order dated 20.07.2021 u/s 271(1)(c) of the Act imposed penalty on additions made alleging ‘furnishing of inaccurate particulars of income’. Apparently, the basis and foundation for imposition of penalty has been altered by the Assessing

FALGUNI S. MEHTA,AHMEDABAD vs. THE ITO, WARD-1(2)(1), VADODARA

In the result, the appeal of the assessee is allowed

u/s 271(1)(c)\nis as under\"\n12.\nTherefore, from the contents of the notice initiating penalty\nproceedings as well as order levying penalty u/s.271(1)(c) of the Act\non assessee, we observe that the AO has not given clear cut\nclassification as to whether the penalty has been levied for\n\"concealment of income” or “furnishing inaccurate particulars

BABUBHAI PUNMAJI GEHLOT,AHMEDABAD vs. THE ITO, WARD-5(3)(3), AHMEDABAD

The appeals of the assessee are allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The said assessment order was passed on 31.12.2009. 5. The assessee filed appeal against aforesaid assessment order of Ld. Assessing Officer on 05.01.2017, after gap of over seven years. The Ld. CIT(A), in order to verify the correct date of service of order (passed under

BABUBHAI PUNMAJI GEHLOT,AHMEDABAD vs. THE ITO, WARD-5(3)(3), AHMEDABAD

The appeals of the assessee are allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The said assessment order was passed on 31.12.2009. 5. The assessee filed appeal against aforesaid assessment order of Ld. Assessing Officer on 05.01.2017, after gap of over seven years. The Ld. CIT(A), in order to verify the correct date of service of order (passed under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed