ITO, WARD-2(2)(2), AHMEDABAD vs. JASMIN JAYENDRABHAI THAKKAR, AHMEDABAD

In the result, we answer the question in the affirmative i

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

184 & 185 Ahd 2019 Assessee - Jasmin Jayendrabhai Thakkar AYs :2010-11 & 2011-12 14 section 139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment, for that assessment year: Provided further that the Assessing Officer may assess or reassess

GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

reassessment. It is also established principle of law that if a particular authority has been designated to record his/her satisfaction on any particular issue, then it is that authority alone who should apply his/her independent mind to record his/her satisfaction and further mandatory condition is that the satisfaction recorded should be ‘independent’ and not ‘borrowed’ or ‘dictated’ satisfaction

GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

reassessment. It is also established principle of law that if a particular authority has been designated to record his/her satisfaction on any particular issue, then it is that authority alone who should apply his/her independent mind to record his/her satisfaction and further mandatory condition is that the satisfaction recorded should be ‘independent’ and not ‘borrowed’ or ‘dictated’ satisfaction

LEELA GREENSHIP RECYCLING PVT. LTD.,BHAVNAGAR vs. THE DY. CIT, CIRCLE-1, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for\nstatistical purposes in terms of above directions

reassessment initiated under section 147 of the\nAct. After setting out the statutory framework governing reopening of\nassessments and analysing a series of judicial pronouncements, the learned\nCIT(A) recorded a categorical finding that the reopening was valid. It was\nheld that the information received from the GST anti-evasion wing\nregarding the assessee's transactions with Mahadev Trading

ACIT, CIRCLE-1, BHAVNAGAR, BHAVNAGAR vs. LEELA GREENSHIP RECYCLING PRIVATE LIMITED, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for statistical purposes in terms of above directions

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 2111/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Leela Greenship Recycling Pvt. Ltd., The Deputy Office No.303, 3Rd Floor, बनाम/ Commissioner V/S. B Wing, Leela Efcee, Of Income Tax, Near Aksharwadi Temple, Circle-1, Waghawadi Road, Bhavnagar. Bhavnagar-364002. "थायी लेखा सं./Pan: Aagcg8956L

reassessment initiated under section 147 of the Act. After setting out the statutory framework governing reopening of assessments and analysing a series of judicial pronouncements, the learned CIT(A) recorded a categorical finding that the reopening was valid. It was held that the information received from the GST anti-evasion wing regarding the assessee’s transactions with Mahadev Trading

THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. STHAPATYA SHILP CONSTRUCTION, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 907/Ahd/2019 With C.O.No.170/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sthapatya Shilp Construction, Central Circle-1(2), Vs. 2, Abhiraj Complex, Ahmedabad. 68-B, Swastic Society, Ahmedabad. Pan: Abffs2922P

reassessment proceedings and grants primacy to section 153C. As noted earlier, exercise of power under section 153C is governed without any stringent fetters of holding 'reason to believe' contemplated under section 147. Therefore, while exercise of overriding power under section 153C will render section 147 otiose, the converse case of clipping the powers available under section 147 in search cases

D. J. STOCK BROKING PRIVATE LIMITED,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(4),, AHMEDABAD

In the result, ground number 1 of the assessee’s appeal is allowed

reassessment proceeding and the order passed and therefore the ld.AO should be directed to accept returned Income. 2 That the learned CIT(A) has erred in Rs. 52,99,188/- law and facts by confirming the addition of Rs.1,59,53,000/- of Share Capital Money under section 68 of the Act and therefore the ld.AO should be directed

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. 12. A perusal of this section would indicate that sub-section-1 contemplates that deduction of expenditure incurred

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001. 12. A perusal of this section would indicate that sub-section-1 contemplates that deduction of expenditure incurred

HITESHKUMAR ISHWARBHAI PATEL,VADODARA vs. THE ITO, WARD-3(1)(2), VADODARA

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

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.986/Ahd/2024 िनधा"रण वष" /Assessment Year : 2014-15 Hiteshkumar Ishwarbhai Patel The Income Tax Officer बनाम/ C-70, Shripad Nagar Society Ward-3(1)(2) V/S. Vip Road Ahmedabad Karelibaug Vadodara – 390 022 (Gujarat) "थायी लेखा सं./Pan: Aekpp 5163 R अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Mehul Thakkar, Ar Revenue By : Shri Prateek Sharma, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 08/10/2024 घोषणा की तारीख /Date Of Pronouncement: 15/10/2024

reassessment proceedings under Section 147 of the Act, 1961, by issuing a notice under Section 148 of the Act on 27.03.2019. The reasons for reopening the assessment were based on information that the assessee had purchased immovable property worth Rs.1,99,73,500/-, and the source of funds for the purchase was unexplained. After reopening the assessment, the AO completed

THE ACIT,(OSD)RANGE-1,, AHMEDABAD vs. M/S. DISHMAN PHARMACEUTICALS & CHEMICALS LTD.,, AHMEDABAD

In the result, we allow appeal of the assessee and delete penalty confirmed by the ld

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

reassessment order. Dissatisfied with the addition, the assessee carried the matter in appeal before the ld.CIT(A). 19. It contended that similar issue was taken in the hands of SDBPL. Dispute travelled upto the ITAT, and it was held that assessee and SDBPL were maintaining current accounts. These were not in the nature of loans which could be treated

DISHMAN PHARMACEUTICALS & CHEMICALS LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)RANGE-1,, AHMEDABAD

In the result, we allow appeal of the assessee and delete penalty confirmed by the ld

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

reassessment order. Dissatisfied with the addition, the assessee carried the matter in appeal before the ld.CIT(A). 19. It contended that similar issue was taken in the hands of SDBPL. Dispute travelled upto the ITAT, and it was held that assessee and SDBPL were maintaining current accounts. These were not in the nature of loans which could be treated

THE DCIT(OSD)RANGE-1,, AHMEDABAD vs. DISHMAN PHARMACEUTICALS & CHEMICALS LTD.,, AHMEDABAD

In the result, we allow appeal of the assessee and delete penalty confirmed by the ld

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

reassessment order. Dissatisfied with the addition, the assessee carried the matter in appeal before the ld.CIT(A). 19. It contended that similar issue was taken in the hands of SDBPL. Dispute travelled upto the ITAT, and it was held that assessee and SDBPL were maintaining current accounts. These were not in the nature of loans which could be treated

THE DCIT(OSD)RANGE-1,, AHMEDABAD vs. DISHMAN PHARMACEUTICALS & CHEMICALS LTD.,, AHMEDABAD

In the result, we allow appeal of the assessee and delete penalty confirmed by the ld

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

reassessment order. Dissatisfied with the addition, the assessee carried the matter in appeal before the ld.CIT(A). 19. It contended that similar issue was taken in the hands of SDBPL. Dispute travelled upto the ITAT, and it was held that assessee and SDBPL were maintaining current accounts. These were not in the nature of loans which could be treated

DISHMAN PHARMACEUTICALS & CHEMICALS LIMITED,,AHMEDABAD vs. THE ACIT, (OSD),RANGE-1,, AHMEDABAD

In the result, we allow appeal of the assessee and delete penalty confirmed by the ld

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

reassessment order. Dissatisfied with the addition, the assessee carried the matter in appeal before the ld.CIT(A). 19. It contended that similar issue was taken in the hands of SDBPL. Dispute travelled upto the ITAT, and it was held that assessee and SDBPL were maintaining current accounts. These were not in the nature of loans which could be treated

RAMJIBHAI MAJETHIA,AHMEDABAD vs. THE ITO, WARD-3(2)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2016-17 Ramjibhai Majethia Vs. Ito, Ward-3(2)(1) 184, Hanuman Was Ahmedabad. Vilage Hirapur, Sanand Ahmedabad 382 2110 India. Pan : Bxopm 9746 D (Applicant) (Responent) : None Assessee By Revenue By : Shri Yogeesh Mishra, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 15/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 17/09/2025 आदेश आदेश/O R D E R आदेश आदेश

184, Hanuman Was Ahmedabad. Vilage Hirapur, Sanand Ahmedabad 382 2110 India. PAN : BXOPM 9746 D (Applicant) (Responent) : None Assessee by Revenue by : Shri Yogeesh Mishra, Sr.DR सुनवाई क" तारीख/Date of Hearing : 15/09/2025 घोषणा क" तारीख /Date of Pronouncement: 17/09/2025 आदेश आदेश/O R D E R आदेश आदेश PER MAKARAND V.MAHADEOKAR, AM: This appeal by the assessee is directed

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

184. The Ld. AR further submitted that on the face of the reasons recorded, the Assessing Officer states that for both issues, they are framed on perusal of the case records itself. Thus, there is no case of any failure full and true disclosure on part of the assessee. The Ld. AR submits that Proviso to Section 147 applied

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

184. The Ld. AR further submitted that on the face of the reasons recorded, the Assessing Officer states that for both issues, they are framed on perusal of the case records itself. Thus, there is no case of any failure full and true disclosure on part of the assessee. The Ld. AR submits that Proviso to Section 147 applied