SHRI MAHESH P. GANDHI,AHMEDABAD vs. THE ACIT., CIRCLE-10,, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita Nos.1022 To 1025/Ahd/2018 िनधा"रण वष"/Asstt. Year: (1992-1993 To 1995-1996) Shri Mahesh P. Gandhi, A.C.I.T., D-404, 5Th Floor, Vs. Circle-10, Dharnidhar Tower, Ahmedabad. Paldi, Ahmedabad.

153 ITR 596 wherein it was held as under : “Since in this case the assessee had been prosecuting other remedies, the time taken by those proceedings should naturally be taken while determining the question whether the assessee had sufficient cause for not presenting the appeal in time. Therefore, the revenue was not right in submitting that the appeal filed under

SHRI ANILBHAI HIRALAL SHAH,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

153 and if Assessing Officer is said to be justified in proceeding with section 147 to reopen the assessment, then there would be no relevance to section 153A, which was inserted in the Act to deal exclusively with search cases. (b) The AO erred to notice that the legislators in their wisdom clearly spelt out the provisions of law applicable

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

reassessments and the additions before the learned Commissioner of Income-tax (Appeals)-12, Ahmedabad. In the appellate proceedings, the CIT(A) passed separate orders for each ITA Nos.635 to 637/Ahd/2025. Dwarkadhish Developers vs.D CIT A.Ys 2015-16 to 2017-18) 3 year, exercising powers under the amended provisions of section 153(3) and the newly inserted proviso to section

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

reassessments and the additions before the learned Commissioner of Income-tax (Appeals)-12, Ahmedabad. In the appellate proceedings, the CIT(A) passed separate orders for each ITA Nos.635 to 637/Ahd/2025. Dwarkadhish Developers vs.D CIT A.Ys 2015-16 to 2017-18) 3 year, exercising powers under the amended provisions of section 153(3) and the newly inserted proviso to section

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

reassessments and the additions before the learned Commissioner of Income-tax (Appeals)-12, Ahmedabad. In the appellate proceedings, the CIT(A) passed separate orders for each ITA Nos.635 to 637/Ahd/2025. Dwarkadhish Developers vs.D CIT A.Ys 2015-16 to 2017-18) 3 year, exercising powers under the amended provisions of section 153(3) and the newly inserted proviso to section

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

reassessment proceedings, which clearly suggest that the appellant had participated in assessment proceedings. Considering such fact, plea taken by the appellant cannot be accepted. 5.4 It is further observed that for the administrative purpose, jurisdiction of all the cases of the Sankalp Group and its related case like the assessee firm M/s. Sai Krupa Developers (Shri Robin Goenka

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

reassessment proceedings, which clearly suggest that the appellant had participated in assessment proceedings. Considering such fact, plea taken by the appellant cannot be accepted. 5.4 It is further observed that for the administrative purpose, jurisdiction of all the cases of the Sankalp Group and its related case like the assessee firm M/s. Sai Krupa Developers (Shri Robin Goenka

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

reassessment proceedings, which clearly suggest that the appellant had participated in assessment proceedings. Considering such fact, plea taken by the appellant cannot be accepted. 5.4 It is further observed that for the administrative purpose, jurisdiction of all the cases of the Sankalp Group and its related case like the assessee firm M/s. Sai Krupa Developers (Shri Robin Goenka

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

reassessment proceedings, which clearly suggest that the appellant had participated in assessment proceedings. Considering such fact, plea taken by the appellant cannot be accepted. 5.4 It is further observed that for the administrative purpose, jurisdiction of all the cases of the Sankalp Group and its related case like the assessee firm M/s. Sai Krupa Developers (Shri Robin Goenka

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

reassessment proceedings, which clearly suggest that the appellant had participated in assessment proceedings. Considering such fact, plea taken by the appellant cannot be accepted. 5.4 It is further observed that for the administrative purpose, jurisdiction of all the cases of the Sankalp Group and its related case like the assessee firm M/s. Sai Krupa Developers (Shri Robin Goenka

SHRI HIRALAL D. THAKKAR,AHMEDABAD vs. THE PR. CIT (CENTRAL), , AHMEDABAD

Bench: S/Shri Pramod M. Jagtap & T.R. Senthil Kumar

ii) Pr.CIT Vs. Anil Bholabhai Patel (Guj) dated 30.8.2017; iii) Pr.CIT Vs. Sanghvi Fincap Ltd., (Guj) dated 20.2.2018; iv) Sunrise FinleaseP.Ltd., 89 taxmann.com 1 (Guj); v) Desai construction, 81 taxmann.com 271 (Guj); 5.7 It is an undisputed fact that on the date of initiation of the search no assessment proceedings were pending in this assessment year. Therefore, the proceedings were

SHRI HIRALAL D. THAKKAR,AHMEDABAD vs. THE PR. CIT (CENTRAL), , AHMEDABAD

Bench: S/Shri Pramod M. Jagtap & T.R. Senthil Kumar

ii) Pr.CIT Vs. Anil Bholabhai Patel (Guj) dated 30.8.2017; iii) Pr.CIT Vs. Sanghvi Fincap Ltd., (Guj) dated 20.2.2018; iv) Sunrise FinleaseP.Ltd., 89 taxmann.com 1 (Guj); v) Desai construction, 81 taxmann.com 271 (Guj); 5.7 It is an undisputed fact that on the date of initiation of the search no assessment proceedings were pending in this assessment year. Therefore, the proceedings were

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

ii. Assessments and reassessments pending on the date of the search shall abate. The total income for such AYs will have to be computed by the AOs as a fresh exercise. iii. The AO will exercise normal assessment powers in respect of the six years previous to the relevant AY in which the search takes place