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

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

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

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

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

Appeals are allowed

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

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

1) is made on or after the 1st day of June, 2007, an order under sub-section (3) may be made at any time before sixty days prior to the date on which the period of limitation referred to in section 153, or as the case may be, in section 153B for making the order of assessment or reassessment

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

DHARMENBHAI MAHENDRABHAI SUTARIA,HUF,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), , AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

GELOT AGRI EXPORTS,DEESA vs. ITO WD 1 PALANPUR, BANASKANTHA

The appeal of the assessee is allowed, while that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

reassessment; 11. Referring to the same, he pointed out that as per the provision of sub-section (2) underreporting income is only that income assessed, which is greater than the income determined in the return processed under clause (a)of sub-section (i) of section 143. He also drew our attention to sub-section (3) of section 270A

ITO, WARD-1, PALANPUR, PALANPUR vs. GELOT AGRI EXPORTS, PALANPUR

The appeal of the assessee is allowed, while that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

reassessment; 11. Referring to the same, he pointed out that as per the provision of sub-section (2) underreporting income is only that income assessed, which is greater than the income determined in the return processed under clause (a)of sub-section (i) of section 143. He also drew our attention to sub-section (3) of section 270A