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

DCIT, CENTRAL CIRCLE1(2), AHMEDABAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, 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

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYAKAR BHAWAN, ASHRAM ROAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, , 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

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

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

reassessment originated from a search action under section 132, and therefore proceedings under section 147 were without jurisdiction. Reliance was placed on the coordinate bench decision in Mahesh D. Tekchandani v. ITO (ITA No. 1028/Ahd/2023, order dated 29.05.2024). 7.4 The CIT(A), while discussing the merits of best judgment assessments and the amendment introduced by the Finance Act, 2024 empowering

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

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

reassessment originated from a search action under section 132, and therefore proceedings under section 147 were without jurisdiction. Reliance was placed on the coordinate bench decision in Mahesh D. Tekchandani v. ITO (ITA No. 1028/Ahd/2023, order dated 29.05.2024). 7.4 The CIT(A), while discussing the merits of best judgment assessments and the amendment introduced by the Finance Act, 2024 empowering

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

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

reassessment originated from a search action under section 132, and therefore proceedings under section 147 were without jurisdiction. Reliance was placed on the coordinate bench decision in Mahesh D. Tekchandani v. ITO (ITA No. 1028/Ahd/2023, order dated 29.05.2024). 7.4 The CIT(A), while discussing the merits of best judgment assessments and the amendment introduced by the Finance Act, 2024 empowering

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

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

reassessment originated from a search action under section 132, and therefore proceedings under section 147 were without jurisdiction. Reliance was placed on the coordinate bench decision in Mahesh D. Tekchandani v. ITO (ITA No. 1028/Ahd/2023, order dated 29.05.2024). 7.4 The CIT(A), while discussing the merits of best judgment assessments and the amendment introduced by the Finance Act, 2024 empowering

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

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

reassessment originated from a search action under section 132, and therefore proceedings under section 147 were without jurisdiction. Reliance was placed on the coordinate bench decision in Mahesh D. Tekchandani v. ITO (ITA No. 1028/Ahd/2023, order dated 29.05.2024). 7.4 The CIT(A), while discussing the merits of best judgment assessments and the amendment introduced by the Finance Act, 2024 empowering

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

section 11(3) of the Act, unspent amount Rs.2,98,00,000/- was being deemed income for the A.Y.2008-09 and demanded tax thereon. 4. Aggrieved against the additions, the assessee filed an appeal before CIT[A] who upheld the reopening of assessment as valid in law and also confirmed the addition made by the AO by observing as follows

GMDC SCIENCE & RESEARCH CENTRE,,AHMEDABAD vs. THE INCOME TAX OFFICER (EXEMPTION),, PALANPUR

In the result, the appeal filed by the assessee is Allowed for Statistical purpose

Bench: Dr. Brr Kumar & Shri T.R. Senthil Kumar

section 11(3) of the Act, unspent amount Rs.2,98,00,000/- was being deemed income for the A.Y.2008-09 and demanded tax thereon. 4. Aggrieved against the additions, the assessee filed an appeal before CIT[A] who upheld the reopening of assessment as valid in law and also confirmed the addition made by the AO by observing as follows

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

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

4 12 248/Ahd/2016 ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India) Ltd. vs. DCIT-ACIT (By assessee and Revenue) Asst. Years : 2007-08 to 2015-16 Disallowance of 2007- ITA 3,00,000 Assessee 1 Gift/Boni/Chandla 08 2815/Ahd/2011 Expenses Addition u/s 40(a)(ia) 2010- ITA 1,26,97,906 Assessee 2.1 for Import of Materials 11 1747/Ahd/2016