DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation to the transactions. Further Ld TPO observed that the assessee had filed requisite details (in Para

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation to the transactions. Further Ld TPO observed that the assessee had filed requisite details (in Para

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation to the transactions. Further Ld TPO observed that the assessee had filed requisite details (in Para

SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

u/s 271(l)(c) of Rs. 2,76,33,870.\n9. The learned CIT(A) erred in fact and in law in confirming the action of the\nlearned AO in levying penalty despite the fact that the Appellant has not furnished\ninaccurate particulars of income either in return of income or during the course of\nassessment proceedings.\n10. The learned

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

61,022/=\n[e] Suppression of sale - Gas turbine Rs.3,41,34,100/=\n\n2. 3. Ld TPO, while passing the order u/s 92CA(3) has accepted\nthe underlying transactions to be at Arms Length Pricing [ALP] and\ntherefore not made any adjustment in relation to the transactions.\nFurther Ld TPO observed that the assessee had filed requisite\ndetails

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

61,022/=\n[e] Suppression of sale - Gas turbine Rs.3,41,34,100/=\n2. 3. Ld TPO, while passing the order u/s 92CA(3) has accepted\nthe underlying transactions to be at Arms Length Pricing [ALP] and\ntherefore not made any adjustment in relation to the transactions.\nFurther Ld TPO observed that the assessee had filed requisite\ndetails (in Para

RAMCHAND BHULCHAND RAJAI,BHAVNAGAR vs. THE DY.CIT.,CIRCLE-1, , BHAVNAGAR

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 167/Ahd/2024 िनधा"रण वष"/Assessment Year : 2009-10 बनाम बनाम बनाम बनाम Ramchand Bhulchand Rajai, The Deputy Commissioner C/O. Jayesh Tyres, Vs. Of Income-Tax, Opp. Railway Station, Circle-1, Bhavnagar Bhavnagar-364001 Pan : Abmpr 4841 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) िनधा"रती की ओर से / Assessee By : Shri B.R. Popat, Ar ""थ" की ओर से / Revenue By: Shri Prateek Sharma, Sr Dr सुनवाई की तारीख /Date Of Hearing : 22/04/2024 घोषणा की तारीख /Date Of Pronouncement: 15/07/2024 आदेश/O R D E R Per Annapurna Gupta

u/s 40A(3) of the Act is not sustainable and we direct deletion of the same. Ramchand Bhulchand Rajai Vs. DCIT AY : 2009-10 12 17. We regard to the addition made by disallowing loading and unloading expenses, the contention made by the assessee before the ld. CIT(A) is as under:- “2.2.1 In so far as the penalty levied

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. SANJAY PRATAPRAI MEHTA, BHAVNAGAR

In the result, appeal of the Department is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

271(1)(c) of the Act. The Revenue has taken the following grounds of appeal:- 2. “1. In the facts and on the circumstances of the case, Ld. CIT(A) erred in directing to delete the penalty levied u/s.271(1)(c) holding that the issue has been decided in favour of appellant by the Hon’ble ITAT, consequential penalty u/s.271

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

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

271(l)(c) by stating that the assessee has concealed ITA Nos. 1277&1278/Ahd/2024 Manas Kumar Das vs. ITO Asst. Year –2011-12 - 5– the particulars of income which is not valid notice as the assessee has shown the same in his return filed under section 148 of the Act. Penalty Proceeding U/s 271F: 20) AO has initiated the penalty

MANAS KUMAR DAS,AHMEDABAD vs. THE ITO, WARD-5(1)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

271(l)(c) by stating that the assessee has concealed ITA Nos. 1277&1278/Ahd/2024 Manas Kumar Das vs. ITO Asst. Year –2011-12 - 5– the particulars of income which is not valid notice as the assessee has shown the same in his return filed under section 148 of the Act. Penalty Proceeding U/s 271F: 20) AO has initiated the penalty

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. UNIMED TECHNOLOGIES LIMITED, PANCHMAHAL

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

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

u/s. 271[1][c] of Rs.1,61,42,867/- vide order dated 29.03.20 for furnishing inaccurate particulars of income. 4. Aggrieved against the Penalty order, assessee company filed appeal before Ld CIT[A] who deleted the penalty by observing as follows: “… 5.3. In the quantum appeal, the Commissioner of Income Tax (Appeals), NFAC, vide order No.ITBA/NFAC/S/250/2023- 24/1060679970(1) dated

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

M/S. DRAIPL-MSKEL(JV),,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-9(2),, AHMEDABAD

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

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2007-08 Draipl-Kskel (Jv) Ito, Ward-9(2) 2Nd Floor, “Msk” Vs. Ahmedabad. Passport Office To Panjarapole Rd. Ambawadi Ahmedabad 380 015. Pan : Aaaad 3825 B (Applicant) (Responent)

section 80IA(4) of the Act. The assessment was completed u/s 143(3) on 24.12.2009 determining total income at Rs.2,61,21,380/- after making the following additions: Disallowance of deduction u/s 80IA(4): Rs.2,42,98,174/- i. Disallowance u/s 40(a)(ia): Rs.18,23,203/- ii. 3. Penalty proceedings were initiated u/s 271

SOMA TEXTILES & INDUSTRIES LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2008-09

penalty u/s. 271(1)(c) of the Act.” 3. Return of income for the relevant Assessment Year was filed on 27.09.2008 declaring total loss of Rs.9,67,82,080/-. Assessment under Section 143(3) of the Income Tax Act, 1961 was completed on 25.01.2012 thereby assessing loss of Rs.4,88,61

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, 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

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, 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

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, 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