PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

section 12AA of the Act and also has got approval u/s 10(23C(vi) of the Act effective from A.Y.2015-16. It is also approved u/s 80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

section 12AA of the Act and also has got approval u/s 10(23C(vi) of the Act effective from A.Y.2015-16. It is also approved u/s 80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

section 12AA of the Act and also has got approval u/s 10(23C(vi) of the Act effective from A.Y.2015-16. It is also approved u/s 80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case

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

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

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

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

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

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

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

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

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

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY,,AHMEDABAD vs. THE COMMISSIONER OF INCOME TAX(EXEMPTION), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

12, Gandhinagar, Gujarat, 382016 [PAN No.AVXPK7106R] (Appellant) .. (Respondent) Appellant by : Shri Sanjay R Shah, AR Respondent by: Shri Prathvi Raj Meena, CIT. D.R. 20.11.2024 Date of Hearing Date of Pronouncement 04.12.2024 O R D E R PER SIDDHARTHA NAUTIYAL, JM: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Exemption

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

reassessment proceedings disclosed the following: (i) That Green Channel Travel Services Ltd. had received fees of Rs. 5,29,440/- under section 194J and commission/brokerage of Rs. 45,17,539/- under section 194H during the financial year 2010–11 relevant to A.Y. 2011– 12, aggregating to Rs. 50,46,979/-. IRM Pvt. Ltd. vs. DCIT

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

12 Vaswani who are promoters/ directors of various concern of assessee group. Accordingly, assessments under section 143(3) r.w.s. 147 of the Act were completed in the case of abovementioned individuals after making various addition to the total income including addition under section 69C of the Act representing unaccounted expenses for “Vejalpur-503 site expenses” and “Golden Park Society & Golden

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

12 Vaswani who are promoters/ directors of various concern of assessee group. Accordingly, assessments under section 143(3) r.w.s. 147 of the Act were completed in the case of abovementioned individuals after making various addition to the total income including addition under section 69C of the Act representing unaccounted expenses for “Vejalpur-503 site expenses” and “Golden Park Society & Golden

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

10 7.2 Before the learned CIT(A), the assessee raised the following effective ground: “That the proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act and subsequent proceedings are without jurisdiction and bad in law and against the facts of the case, and therefore the order passed by the learned AO is required to be quashed

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

10 7.2 Before the learned CIT(A), the assessee raised the following effective ground: “That the proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act and subsequent proceedings are without jurisdiction and bad in law and against the facts of the case, and therefore the order passed by the learned AO is required to be quashed

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

10 7.2 Before the learned CIT(A), the assessee raised the following effective ground: “That the proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act and subsequent proceedings are without jurisdiction and bad in law and against the facts of the case, and therefore the order passed by the learned AO is required to be quashed

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

10 7.2 Before the learned CIT(A), the assessee raised the following effective ground: “That the proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act and subsequent proceedings are without jurisdiction and bad in law and against the facts of the case, and therefore the order passed by the learned AO is required to be quashed

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

10 7.2 Before the learned CIT(A), the assessee raised the following effective ground: “That the proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act and subsequent proceedings are without jurisdiction and bad in law and against the facts of the case, and therefore the order passed by the learned AO is required to be quashed

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets