M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings is bad in law, void ab initio and liable to be quashed. 2. The learned AO based on the directions of the DRP has erred on the facts and in law in treating the aggregate cost recovery of Rs. 7,15,01,526 received from Hazira LNG Private Limited (‘HLPL’), Hazira Port Private Limited (‘HPPL’), Shell India Markets

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. N K PROTEINS PVT. LIMITED, AHMEDABAD

In the result the appeal filed by the Revenue is hereby dismissed

Bench: Shri T R Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 14A does not survive. • Considering these facts Assessee claimed that once addition made by the AO is deleted by the Hon'ble ITAT, disallowance u/s.14A would not survive and AO has already not made other additions based upon reasons recorded. Hence reassessment order passed by AO deserves to be annulled as no effective addition(s) is/are made or survive

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.

195/ Ahd/2021 relating to the Asst. years 2015-16 and 2016-17 filed by the Revenue. 3. The brief facts of the case are that there was Search and Survey action under sections 132/133A were conducted on 06/03/2018 and on subsequent dates in the cases of “SSS Group”. SSS stands for three separate but internally connected groups viz Sangani Group

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

Appeals are partly allowed

195/ Ahd/2021 relating to the\nAsst. years 2015-16 and 2016-17 filed by the Revenue.\n3. The brief facts of the case are that there was Search and Survey action\nunder sections 132/133A were conducted on 06/03/2018 and on\nsubsequent dates in the cases of “SSS Group”. SSS stands for three\nseparate but internally connected groups viz Sangani Group

BIPINBHAI KANTILAL VAKTA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(2)(1),, AHMEDABAD

In the result, both the appeals filed by the respective assessees are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

195, Doshivadani Pole, Ward – 1(2)(1), Nr. Gosaiji Haveli, Ahmedabad. Vs. Kalupur, Ahmedabad – 380 001. [PAN – AAGPV 4044 F] Assessment Year: 2012-13 Dhananjaya Tradelink Pvt. Ltd., The Income Tax Officer, 505, Padshahni Pole, Ward – 1(1)(4), Kalupur, Ahmedabad. Vs. Ahmedabad – 380 001. [PAN – AADCD 8007 A] (Appellants) (Respondents) Assessee by Shri S.N. Divetia, & Shri Samir Vora

DHANANJAYA TRADELINK PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-1(1)(4), AHMEDABAD

In the result, both the appeals filed by the respective assessees are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

195, Doshivadani Pole, Ward – 1(2)(1), Nr. Gosaiji Haveli, Ahmedabad. Vs. Kalupur, Ahmedabad – 380 001. [PAN – AAGPV 4044 F] Assessment Year: 2012-13 Dhananjaya Tradelink Pvt. Ltd., The Income Tax Officer, 505, Padshahni Pole, Ward – 1(1)(4), Kalupur, Ahmedabad. Vs. Ahmedabad – 380 001. [PAN – AADCD 8007 A] (Appellants) (Respondents) Assessee by Shri S.N. Divetia, & Shri Samir Vora

GAUTAMBHAI NANSINH CHAUHAN,ANAND vs. THE ITO, WARD-1(3)(1), PETLAD

In the result, the appeal of the assessee is allowed

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

reassessment proceedings, notices under section 142(1) were issued on various dates calling for explanation regarding the source and nature of the high-value cash withdrawals. The assessee responded on 08.09.2023, submitting that he was appointed as an authorised agent of SBI’s Customer Service Centre (Grahak Seva Kendra) through its technology partner NICT Technologies Pvt. Ltd., and was providing

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

195 head-note (v) are worth to be reproduced hereafter:- ITA Nos.1867/Ahd/2019 & 54/Ahd/2020 Assessment Years: 2011-12 Page 6 of 8 “That though the writ of prohibition or certiorari would not issue against an executive authority, the High Courts had power to issue in a fit case an order prohibiting an executive authority from acting without jurisdiction. Where such action

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

195 head-note (v) are worth to be reproduced hereafter:- ITA Nos.1867/Ahd/2019 & 54/Ahd/2020 Assessment Years: 2011-12 Page 6 of 8 “That though the writ of prohibition or certiorari would not issue against an executive authority, the High Courts had power to issue in a fit case an order prohibiting an executive authority from acting without jurisdiction. Where such action

MUHAMMED ARIF SHAIKH,VEJALPUR vs. ASST. UNIT. INCOME TAX DEPT. (PRESENT JURI. - ITO, WARD 3(3)(2) AHMEDABAD), VEJALPUR

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

reassessment order passed under section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2018-19. 2. Brief facts of the case that the assessee is an individual and Partner in a firm deriving income from business, remuneration, I.T.A No. 1806/Ahd/2025 A.Y. 2018-19 Page No 2 Muhammed Arif