SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

133A was carried ITA Nos.248 to 250/Ahd/2023 & 325&326/Ahd/2023 Sai Krupa Developers vs. ACIT & ACIT vs. Sai Krupa Developers Asst. Years –2014-15, 2016-17 & 2019-20 - 3– out on 30.10.2018 at the business premises of the assessee at 418, Gala Empire, Ahmedabad in connection with the development of industrial plots done by the assessee for Sankalp Group. Further

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

133A was carried ITA Nos.248 to 250/Ahd/2023 & 325&326/Ahd/2023 Sai Krupa Developers vs. ACIT & ACIT vs. Sai Krupa Developers Asst. Years –2014-15, 2016-17 & 2019-20 - 3– out on 30.10.2018 at the business premises of the assessee at 418, Gala Empire, Ahmedabad in connection with the development of industrial plots done by the assessee for Sankalp Group. Further

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

133A was carried ITA Nos.248 to 250/Ahd/2023 & 325&326/Ahd/2023 Sai Krupa Developers vs. ACIT & ACIT vs. Sai Krupa Developers Asst. Years –2014-15, 2016-17 & 2019-20 - 3– out on 30.10.2018 at the business premises of the assessee at 418, Gala Empire, Ahmedabad in connection with the development of industrial plots done by the assessee for Sankalp Group. Further

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

133A was carried ITA Nos.248 to 250/Ahd/2023 & 325&326/Ahd/2023 Sai Krupa Developers vs. ACIT & ACIT vs. Sai Krupa Developers Asst. Years –2014-15, 2016-17 & 2019-20 - 3– out on 30.10.2018 at the business premises of the assessee at 418, Gala Empire, Ahmedabad in connection with the development of industrial plots done by the assessee for Sankalp Group. Further

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

133A was carried ITA Nos.248 to 250/Ahd/2023 & 325&326/Ahd/2023 Sai Krupa Developers vs. ACIT & ACIT vs. Sai Krupa Developers Asst. Years –2014-15, 2016-17 & 2019-20 - 3– out on 30.10.2018 at the business premises of the assessee at 418, Gala Empire, Ahmedabad in connection with the development of industrial plots done by the assessee for Sankalp Group. Further

DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

133A conducted on 23.02.2018 in the case of M/s. Krishna Developers, a third-party real estate concern. During the course of the said survey, certain loose documents were found and impounded, including a handwritten “Red Diary” and a bound “Register,” which allegedly recorded details of unaccounted cash transactions involving various parties. Consequently, notices under section 148 were issued, and reassessment

DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

133A conducted on 23.02.2018 in the case of M/s. Krishna Developers, a third-party real estate concern. During the course of the said survey, certain loose documents were found and impounded, including a handwritten “Red Diary” and a bound “Register,” which allegedly recorded details of unaccounted cash transactions involving various parties. Consequently, notices under section 148 were issued, and reassessment

DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

133A conducted on 23.02.2018 in the case of M/s. Krishna Developers, a third-party real estate concern. During the course of the said survey, certain loose documents were found and impounded, including a handwritten “Red Diary” and a bound “Register,” which allegedly recorded details of unaccounted cash transactions involving various parties. Consequently, notices under section 148 were issued, and reassessment

SHRI NIRAL KRUPESH PATEL,BARODA vs. THE DY.CIT, CIRCLE-1(3), BARODA

In the result the appeal filed by the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

133A of the Act, the assessee would not have offered the undisclosed investment in the insurance policies as income. Accordingly, the AO proposed to levy the penalty by issuing notice under section 274/271(1)(c) of the Act upon the assessee on account of concealment of income for the investment in the insurance policies. 5.3 The assessee in response

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. APPLITECH SOLUTION LTD.,, AHMEDABAD

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

133A of the Act was carried out at the premises of the assessee on 07.03.2003. The findings of the said survey as mentioned in the assessment order for AY 2000-01 were as under:-- “1. No insurance cover was taken for the computers 2. No adequate evidences relating to the real purchase of computer hardware were produced. 3. The main

NA ROTO MACHINE & MOULDS INDIA,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

133A of the Act carried out on 24.10.2018 in the case of one Pinaxis Polyplast LLP, certain documents were impounded as per which the assessee had received cash of Rs.6,00,000/- for sale of certain machinery to M/s. Pinaxis Polyplast LLP, M/s. Pacific Polymers & M/s. Pacific Polyplast. On the basis of this information, the case of the assessee

SAURABHBHAI ROHITBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file a return in response to the notice under section 148 of the Act, a notice under section 142(1) read with section 148 of the Act dated 21.06.2016 was issued. In response

ROHITKUMAR CHINUBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment proceedings by issuing notice under section 148 on 23.03.2016 after recording reasons and obtaining approval as required under the Act. Since the assessee did not file a return in response to the notice under section 148 of the Act, a notice under section 142(1) read with section 148 of the Act dated 21.06.2016 was issued. In response

SHRI RAJESHHBHAI JIVRAJ DESAI,,MEHSANA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1),, AHMEDABAD

In the result, the appeal of the assessee is allowed in part

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 2291/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2013-2014 Shri Rajeshbhai Jivraj Desai, D.C.I.T., Prop. M/S.Rajiv Enterprise, Vs. Central Circle-2(1), 5 Ashoknagar Society, Ahmedabad. Radhanpur Road, Mehsana.

reassess the total income of six assessment years immediately preceding the assessment year relevant to the previous year in which such search is conducted or requisition is made and for the relevant assessment year or years : 3.3 As per the above clause the period of 6 years will be counted from immediately preceding the assessment year relevant to the previous

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

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

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