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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

9-22 of Annexure BS-24 found during the course of search, from the premises of the assessee. While making the addition in the hands of the assessee, the Assessing Officer observed that the document relating to the above transaction was seized from the ITA No. 210/Ahd/2020 & 08 others Shri Rohitji Chanduji Thakore vs. ITO Asst. Years

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings under Section 274 r.w.s. 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” Ground number 1: taxability of HR Shall People Support as royalty: 5. During the impugned year under

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. APPLITECH SOLUTIONS LTD.,, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed)

u/s 271(1)(c) of the Act. I, therefore, levy a minimum penalty @ 100% of the amount of tax sought to be evaded on account of filing of inaccurate particulars of income, which works out of Rs. 1,94,27,849/- against the maximum penalty of Rs. 5,82,83,547/- on the assessee. Issue demand notice and Challan