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

40. Ground Nos 3 and 5 of the assessee’s appeal are general in nature and do not require any specific adjudication. 41. In the result Ground No. 3 and 5 of the assessee’s appeal is dismissed. 42. Ground No. 4 of the assessee’s appeal that Ld. AO did not record mandatory satisfaction for initiating penalty proceedings u/s

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

40. Ground Nos 3 and 5 of the assessee’s appeal are general in nature and do not require any specific adjudication. 41. In the result Ground No. 3 and 5 of the assessee’s appeal is dismissed. 42. Ground No. 4 of the assessee’s appeal that Ld. AO did not record mandatory satisfaction for initiating penalty proceedings u/s

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

40. Ground Nos 3 and 5 of the assessee’s appeal are general in nature and do not require any specific adjudication. 41. In the result Ground No. 3 and 5 of the assessee’s appeal is dismissed. 42. Ground No. 4 of the assessee’s appeal that Ld. AO did not record mandatory satisfaction for initiating penalty proceedings u/s

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

40. Ground Nos 3 and 5 of the assessee’s appeal are general in nature and do not require any specific adjudication. 41. In the result Ground No. 3 and 5 of the assessee’s appeal is dismissed. 42. Ground No. 4 of the assessee’s appeal that Ld. AO did not record mandatory satisfaction for initiating penalty proceedings u/s

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

40. Ground Nos 3 and 5 of the assessee’s appeal are general in nature and do not require any specific adjudication. 41. In the result Ground No. 3 and 5 of the assessee’s appeal is dismissed. 42. Ground No. 4 of the assessee’s appeal that Ld. AO did not record mandatory satisfaction for initiating penalty proceedings u/s

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

u/s. 271(1)(c), vide order dated 25/07/2019. 34. The assessee has taken the following grounds of appeal: “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated 25 July 2019 passed by the Commissioner of Income-tax (Appeals)-13, Ahmedabad ['the learned I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 37 Shell

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

u/s. 271(1)(c), vide order dated 25/07/2019. 34. The assessee has taken the following grounds of appeal: “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated 25 July 2019 passed by the Commissioner of Income-tax (Appeals)-13, Ahmedabad ['the learned I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 37 Shell

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

u/s. 271(1)(c), vide order dated 25/07/2019. 34. The assessee has taken the following grounds of appeal: “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated 25 July 2019 passed by the Commissioner of Income-tax (Appeals)-13, Ahmedabad ['the learned I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 37 Shell

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

u/s. 271(1)(c), vide order dated 25/07/2019. 34. The assessee has taken the following grounds of appeal: “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated 25 July 2019 passed by the Commissioner of Income-tax (Appeals)-13, Ahmedabad ['the learned I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 37 Shell

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.

271(1)(c) of the Act was levied on the income offered by revised return after the same was accepted by the assessee in the survey proceedings. 4.1 Accordingly, the AO held that the assessee has concealed the particular of additional income of Rs. 65 lacs offered during the proceedings under section 153A of the Act and levied the 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.

271(1)(c) of the Act was levied on the income offered by revised return after the same was accepted by the assessee in the survey proceedings. 4.1 Accordingly, the AO held that the assessee has concealed the particular of additional income of Rs. 65 lacs offered during the proceedings under section 153A of the Act and levied the 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.

271(1)(c) of the Act was levied on the income offered by revised return after the same was accepted by the assessee in the survey proceedings. 4.1 Accordingly, the AO held that the assessee has concealed the particular of additional income of Rs. 65 lacs offered during the proceedings under section 153A of the Act and levied the penalty

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

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 of Ld. Authorized Representative on this account are rejected. 6.2. The appellant has also submitted that while initiating the penalty proceedings, the Assessing Officer has not specified as to whether

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

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 of Ld. Authorized Representative on this account are rejected. 6.2. The appellant has also submitted that while initiating the penalty proceedings, the Assessing Officer has not specified as to whether

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

40. It would useful to reproduce the relevant extracts of the ITAT ruling in case of two co-owner of the said property i.e. Rohit G. Thakor, in which similar additions and penalty under Section 271(1)(c) of the Act was deleted by the Hon’ble ITAT, Ahmedabad in IT(SS)A No. 45/Ahd/2020 and ITA No. 204/Ahd/2020