SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

u/s 271(l)(c) of the Act on the additions sustained in the quantum appellate order, which is wholly unsustainable in law and on facts and as such the appellant could not be charged with any guilt of furnishing inaccurate particulars of income or concealing particulars of income within mischief of Section 271(l)(c) of the Act. The levy

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE ADIT(EXEMPTION),, AHMEDABAD

In the result, the appeal of the assessee is allowed

u/s 271(l)(c) of the Act on the additions sustained in the quantum appellate order, which is wholly unsustainable in law and on facts and as such the appellant could not be charged with any guilt of furnishing inaccurate particulars of income or concealing particulars of income within mischief of Section 271(l)(c) of the Act. The levy

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE ADIT(EXEMPTION),, AHMEDABAD

In the result, the appeal of the assessee is allowed

u/s 271(l)(c) of the Act on the additions sustained in the quantum appellate order, which is wholly unsustainable in law and on facts and as such the appellant could not be charged with any guilt of furnishing inaccurate particulars of income or concealing particulars of income within mischief of Section 271(l)(c) of the Act. The levy

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

u/s 271(l)(c) of the Act on the additions sustained in the quantum appellate order, which is wholly unsustainable in law and on facts and as such the appellant could not be charged with any guilt of furnishing inaccurate particulars of income or concealing particulars of income within mischief of Section 271(l)(c) of the Act. The levy

SHRI PAVAN M.SHARMA L/H OF LATE MAHESH L.SHARMA,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

u/s 271(l)(c) of the Act on the additions sustained in the quantum appellate order, which is wholly unsustainable in law and on facts and as such the appellant could not be charged with any guilt of furnishing inaccurate particulars of income or concealing particulars of income within mischief of Section 271(l)(c) of the Act. The levy

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

Section 271(l)(c) of the Act should be deleted in the interest of the justice. In this regard, the Appellant relies on the I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 32 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. detailed legal submissions made in para 2.5 above

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

Section 271(l)(c) of the Act should be deleted in the interest of the justice. In this regard, the Appellant relies on the I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 32 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. detailed legal submissions made in para 2.5 above

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

Section 271(l)(c) of the Act should be deleted in the interest of the justice. In this regard, the Appellant relies on the I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 32 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. detailed legal submissions made in para 2.5 above

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

Section 271(l)(c) of the Act should be deleted in the interest of the justice. In this regard, the Appellant relies on the I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 32 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. detailed legal submissions made in para 2.5 above

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.

u/s 153A of the Act as on 7th December 2016 wherein declared additional income of Rs. 25 lakhs against the cash deposited in the bank account and contributed to the partnership firm. The AO against the additional income offered initiated penalty proceedings under section 271(1)(c) of the Act. Finally, the AO levied a penalty

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.

u/s 153A of the Act as on 7th December 2016 wherein declared additional income of Rs. 25 lakhs against the cash deposited in the bank account and contributed to the partnership firm. The AO against the additional income offered initiated penalty proceedings under section 271(1)(c) of the Act. Finally, the AO levied a penalty

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.

u/s 153A of the Act as on 7th December 2016 wherein declared additional income of Rs. 25 lakhs against the cash deposited in the bank account and contributed to the partnership firm. The AO against the additional income offered initiated penalty proceedings under section 271(1)(c) of the Act. Finally, the AO levied a penalty

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view