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)

section 153B for making the order of assessment or reassessment or recomputation or fresh assessment, as the case may be, expires

SHALIGRAM INFRA PROJECTS LLP ( LTD. LIABILITY PARTNERSHIP),AHMEDABAD vs. THE JCIT (OSD), CENTRAL CIRCLE-2(2), AHMEDABAD

Appeals are partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarit(Ss)A No.167/Ahd/2021 Asstt.Year : 2017-18 & Asst.Year : 2018-19 Shaligram Infra Projects Llp Vs. The Jcit (Osd) 4Th Floor, Office No.401-402 Central Cir.2(2) B/H. Dishman House Ahmedabad. Opp: Sankalp Grace Ii, Ambli Ahmedabad. Pan: Acpfs 7047 A It(Ss)A No.194,195 & 196/Ahd/2021 Asstt.Year : 2015-16, 2016-17 & 2017-18 & Asst.Year : 2018-19 The Jcit (Osd) Vs. Shaligram Infra Projects Llp Central Cir.2(2) 4Th Floor, Office No.401-402 Ahmedabad. B/H. Dishman House Opp: Sankalp Grace Ii, Ambli Ahmedabad.

reassess the total income of six preceding assessment years, even if the earlier assessments had been completed under section 143(1) or 143(3). However, that decision was premised on the fact that incriminating material (loan documents and supporting GPAs) was actually recovered during the search of the assessee himself, which linked the assessee directly to undisclosed transactions. Likewise

THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SHALIGRAM INFRA PROJECTS LLP , AHMEDABAD

Appeals are partly allowed

reassess the total income of such years. The\nprovision is mandatory in its operation once the assessee is a searched\nperson.\n9.2 On the other hand, section 153C of the Act applies in a situation\nwhere, during the course of a search on one person, the Assessing Officer\nis satisfied that money, bullion, jewellery or documents seized actually\npertain

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment under section 147 of the Act has abated, needless to state that the scope and ambit of the assessment would include any order which the Assessing Officer could have passed under section 147 of the Act as well as under section 153A of the Act. 17. In the facts of the present case, a search came to be conducted

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

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

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

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

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

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

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

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring

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

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

153B(1)(b) 2013-14 29/11/2013 NA 143(3) 23/03/2016 17/01/2018 2014-15 29/11/2014 NA 143(3) 20/05/2016 17/01/2018 2015-16 25/11/2015 NA 143(3) 19/04/2017 29/03/2018 3.1. The assessee filed its return of income in response to Notice u/s.153A of the Act for the A.Y. 2009-10, A.Y. 2010-11 and A.Y. 2011-12 on 07-11-2012 declaring