GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

u/s. 271(l)(c) of the Act for Rs.166,50,03,312 be deleted. ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 4– 4. Without prejudice to the above, the learned CIT(A) has also erred in upholding the penalty under section 271

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

u/s 10(38)of the Act of Long Term Capital Gain from sale of equity shares deserves to be allowed and no addition is called for the estimated brokerage expenses made in the hands of the assessee(s). Thus finding of Ld. CIT(A) is set aside and the Grounds raised by the assessee(s) in ITA Nos.889/Ind/2018, 474/Ind/2019, 206/Ind/2019

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-3(3)(2), (FORMERLY ITO, WARD-3(3)(3),, AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

penalty u/s. 271(1)(c) of the Act. 8. Both the lower authorities have passed the orders without properly appreciating the facts and law on the issue. The action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed. I.T.A Nos. 85 & 87/Ahd/2024 A.Y. 2013-14 Page

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(2)(FORMERLY ITO, WARD-3(3)(3)), AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

penalty u/s. 271(1)(c) of the Act. 8. Both the lower authorities have passed the orders without properly appreciating the facts and law on the issue. The action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed. I.T.A Nos. 85 & 87/Ahd/2024 A.Y. 2013-14 Page

UPENKUMAR AMRUTJI VIHOL,VADODARA vs. THE ITO, WARD-3(1)(2)(PREVIOUSLY ITO, WARD-1, ANAND), VADODARA

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

69A of the Act. 3. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271F of the Act. 4. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271

UPENKUMAR AMRUTJI VIHOL,VADODARA vs. THE ITO, WARD-3(1)(2)(PREVIOUSLY ITO, WARD-1, ANAND), VADODARA

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

69A of the Act. 3. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271F of the Act. 4. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271

UPENKUMAR AMRUTJI VIHOL,VADODARA vs. THE ITO, WARD-3(1)(2), VADODARA

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

69A of the Act. 3. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271F of the Act. 4. The Ld. CIT(A) and the Ld. AO have erred in law and in fact in confirming the levy of penalty U/s. 271

JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

u/s 263 as well as consequential orders passed subsequent to revision proceeding are Null and VOID and deserves to be quashed and set aside. The same please be held accordingly. 5. The order passed by the learned CIT (Appeals) is bad in law and contrary to the provisions of law and facts. It is submitted that the same be held

SNEHA PAWAN AGARWAL,AHMEDABAD vs. ITO WARD 1(1)(3), AHMEDABAD

The appeals are allowed for statistical purposes

penalty proceedings\nunder sections 271(1)(b) and 271(1)(c) of the Act despite there being no\nconscious OR deliberate default by the assessee. The non-compliance was\ndue to genuine non-receipt of communications, not due to any intent to conceal\nincome OR furnish inaccurate particulars.\n5. Section 234B: The Ld. AO has erred

MAYANKKUMAR RAMESHCHANDRA BHATT,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(1), VADODARA

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2007-08 Mayankkumar Rameschandra Ito, Ward-1(2)(1) Bhatt Vs. Vadodara. B/202, Laljikrupa Society B/H. Mothers School Gotri Road, Baroda. Pan : Agypb 2066 R (Applicant) (Responent) : Shri Tushar Hemani, Sr.Advocate Assessee By Revenue By : Shri Umesh Kumar Agrawal, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29 /07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Dated 17.05.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], For The Assessment Year 2007–08, Arising Out Of The Reassessment Order Dated 27.03.2015 Passed Under Section 144 R.W.S. 147 Of The Act By The Income Tax Officer, Ward 4(2)(4), Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”].

u/s 69A. - Addition of Rs. 7,60,000/- on account of short-term capital gains from sale of shares, as the assessee did not furnish supporting documents. The AO also initiated penalty proceedings under section 271

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

69A pre supposes a credit of the aforesaid amount in the 'bank account' held for the previous year. This is the settled position of law that a statutory provision has to be strictly construed and interpreted as per its plain literal interpretation, and no word howsoever meaningful it may so appear can be allowed to be read into a statutory

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

69A pre supposes a credit of the aforesaid amount in the 'bank account' held for the previous year. This is the settled position of law that a statutory provision has to be strictly construed and interpreted as per its plain literal interpretation, and no word howsoever meaningful it may so appear can be allowed to be read into a statutory

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

69A pre supposes a credit of the aforesaid amount in the 'bank account' held for the previous year. This is the settled position of law that a statutory provision has to be strictly construed and interpreted as per its plain literal interpretation, and no word howsoever meaningful it may so appear can be allowed to be read into a statutory

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

69A pre supposes a credit of the aforesaid amount in the 'bank account' held for the previous year. This is the settled position of law that a statutory provision has to be strictly construed and interpreted as per its plain literal interpretation, and no word howsoever meaningful it may so appear can be allowed to be read into a statutory

KAUSHIK PRAVINCHANDRA GOHEL,BHAVNAGAR vs. THE ASSESSING OFFICER, WARD-1(2), BHAVNAGAR

In the result, the appeal of the assessee is allowed with respect to levy of penalty under Section 271(1)(b) of the Act for A

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

69A pre supposes a credit of the aforesaid amount in the 'bank account' held for the previous year. This is the settled position of law that a statutory provision has to be strictly construed and interpreted as per its plain literal interpretation, and no word howsoever meaningful it may so appear can be allowed to be read into a statutory