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 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

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

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

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

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

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

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, 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

SHRI AJAY MAYOR,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

vii) of the Act as income from other sources since it was received without consideration. The CIT(Appeals) also referred to the decision of the Hon’ble Supreme Court in Mak Data Pvt. Ltd. vs. CIT (2013) 38 taxmann.com 448 (SC) and K.P. Madhusudhanan vs. CIT (2001) 251 ITR 99 (SC) to hold that voluntary disclosure or explanation offered