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

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

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

reassess the income of the other person in accordance with the provisions of section 153A, if, that Assessing Officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person for six assessment years immediately preceding the assessment year relevant to the previous

PARTH DINESH PATEL,MEHSANA vs. THE INCOME TAX OFFICER, WARD-1,, PATAN

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.137/Ahd/2024 & 138/Ahd/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 Parth Dinesh Patel The Income Tax Officer बनाम/ 18/19, Utkarsh Society Ward-1, V/S. Opp. Market Yard Patan – 384 265 Tal. Visnagar, Mehsana Gujarat – 384 315 "थायी लेखा सं./Pan: Bwrpp 7811 A (अपीलाथ&/ Appellant) ('( यथ&/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 23/04/2025 घोषणा की तारीख /Date Of Pronouncement: 25/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Two Appeals Are Filed By The Assessee Against The Separate Orders Dated 01.12.2023 Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], Arising Out Of Reassessment Orders Framed Under Section 147 R.W.S. 144B Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], By The National Faceless Assessment Centre (Nfac), Delhi [Hereinafter Referred To As “Assessing Officer /Ao”] For The Assessment Years (Ays) 2015–16 & 2016–17, Respectively. As The Issues Involved In Both The Appeals Are Common

reassessment proceedings for A.Y. 2015–16, the Assessing Officer (AO) made additions under section 68 of the Act aggregating to Rs.86,62,160

PARTH DINESH PATEL,MEHSANA vs. THE INCOME TAX OFFICER, WARD-1,, PATAN

In the result, both the appeals of the assessee are allowed for statistical\npurposes

reassessment proceedings for A.Y. 2015–16, the\nAssessing Officer (AO) made additions under section 68 of the Act\naggregating to Rs.86,62,160

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

section 148 is a fatal flaw that renders the reassessment proceedings invalid. 8. The DR stated that the assessee was given a period of 30 days to file the return of income in response to notice u/s 148 dated 31-3-2021 in which it was mentioned that the same issued after obtaining the necessary satisfaction of the range head

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

section 148 is a fatal flaw that renders the reassessment proceedings invalid. 8. The DR stated that the assessee was given a period of 30 days to file the return of income in response to notice u/s 148 dated 31-3-2021 in which it was mentioned that the same issued after obtaining the necessary satisfaction of the range head

DILIPKUMAR VITTHALDAS DESAI,VADODARA vs. THE INCOME TAX OFFICER,WARD-3(1)(1), VADODARA

Bench: The Tribunal Has Caused The Delay Of 87 Days In Filing The Appeal. The Assessee Enclosed The United States Passport Copy Of His Brother, Who Visited India In December 2023. We Are Satisfied With The Reasons Stated In The Notarized Affidavit Thereby We Hereby Condone The Delay Of 87 Days In Filing The Above Appeals & Adjudicate The Cases On Merits.

reassessment order, the assessee filed an appeal before Ld. CIT(A) with a delay. The delay was condoned by the Ld. CIT(A) and after considering reply filed by the assessee and the Affidavit by Shri Mahesh Vitthaldas Desai and Smt. Smita Mahesh Desai dismissed the appeal filed by the assessee by observing as follows: “5.4 Nowhere in the affidavit

DILIPKUMAR VITTHALDAS DESAI,VADODARA vs. THE INCOME TAX OFFICER, WARD-3(1)(1), VADODARA

Bench: The Tribunal Has Caused The Delay Of 87 Days In Filing The Appeal. The Assessee Enclosed The United States Passport Copy Of His Brother, Who Visited India In December 2023. We Are Satisfied With The Reasons Stated In The Notarized Affidavit Thereby We Hereby Condone The Delay Of 87 Days In Filing The Above Appeals & Adjudicate The Cases On Merits.

reassessment order, the assessee filed an appeal before Ld. CIT(A) with a delay. The delay was condoned by the Ld. CIT(A) and after considering reply filed by the assessee and the Affidavit by Shri Mahesh Vitthaldas Desai and Smt. Smita Mahesh Desai dismissed the appeal filed by the assessee by observing as follows: “5.4 Nowhere in the affidavit

SARFARAZKHAN SARVARKHAN PATHAN,AHMEDABAD vs. ITO, WARD3(3)(5), AHMEDABAD, AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

reassessment under section 143(3) read with section 147 of the Act on 17.12.2019 and assessed the total income at Rs.2,24,27,908/-. In doing so, the Assessing Officer made additions of Rs.47,48,500/- as unexplained cash deposits under section 69A of the Act, Rs.6,00,000/- as unexplained cash credit under section 68 of the Act, Rs.1

LATE SHRI RANJITSINH BHAWANSINH VAGHELA THRU L/H BHARATSINH R. VAGHELA,GANDHINAGAR vs. THE INCOME TAX OFFICER, WARD-3,, GANDHINAGAR

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

160/- and recomputing the deduction allowable under section 54F at Rs.29,00,637/-. The CIT(Appeals) accordingly partly allowed the appeal of the assessee. Late Shri Ranjitsinh Bhawansih Vaghela (L/h. Through Bharatsinh R. Vaghela) vs. ITO Asst.Year –2012-13 - 3– 5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal

THE INCOME TAX OFFICER,WARD-3, GANDHINAGAR vs. SHRI RAMESH GOBARJI THAKOR, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2010-11 Income-Tax Officer Vs. Shri Ramesh Gobarji Thakor Ward-3 Sector 11 Gandhinagar. Gandhinagar. Pan : Aespt 3446 H (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ars. Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 16/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/07/2024 आदेश आदेश/O R D E R आदेश आदेश

reassessment proceedings under section 147 of the Act were initiated on the assessee. 5. The assessment order reveals that several notices were issued to the assessee by the AO during the proceedings, but the assessee did not respond to the same. The AO accordingly made inquiries and collected information from the bank of the assessee where the amounts were found

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

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

160 taxmann.com 676. 9. The Departmental Representative (DR), on the other hand, stated that the vendors who are not verifiable itself is incriminating material. These vendors have not responded to the notices of AO issued u/s 133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth

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

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

160 taxmann.com 676. 9. The Departmental Representative (DR), on the other hand, stated that the vendors who are not verifiable itself is incriminating material. These vendors have not responded to the notices of AO issued u/s 133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth

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

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

160 taxmann.com 676. 9. The Departmental Representative (DR), on the other hand, stated that the vendors who are not verifiable itself is incriminating material. These vendors have not responded to the notices of AO issued u/s 133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth

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

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

160 taxmann.com 676. 9. The Departmental Representative (DR), on the other hand, stated that the vendors who are not verifiable itself is incriminating material. These vendors have not responded to the notices of AO issued u/s 133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth

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

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

160 taxmann.com 676. 9. The Departmental Representative (DR), on the other hand, stated that the vendors who are not verifiable itself is incriminating material. These vendors have not responded to the notices of AO issued u/s 133 of the Act. The DR further stated that such denials suggest consciousness of guilt or an attempt to obscure the truth