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

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.-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.-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

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

234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under 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

234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

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

234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under 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

234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

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

234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

reassessment proceedings, the assessee reiterated his earlier contentions. The Assessing Officer again treated the ledger “Mukesh Ratnajyot / Mukeshbhai RJ” as pertaining to the assessee, computed the incremental negative peak for the year at ₹1,14,52,110/- and added the same under section 69C. Interest accrued as per the diary amounting to ₹12,91,279/- was added under section

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

reassessment proceedings, the assessee reiterated his earlier contentions. The Assessing Officer again treated the ledger “Mukesh Ratnajyot / Mukeshbhai RJ” as pertaining to the assessee, computed the incremental negative peak for the year at ₹1,14,52,110/- and added the same under section 69C. Interest accrued as per the diary amounting to ₹12,91,279/- was added under section

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. MUKESH MOHANLAL VAGHELA, MUMBAI

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

reassessment proceedings, the assessee reiterated his earlier contentions. The Assessing Officer again treated the ledger “Mukesh Ratnajyot / Mukeshbhai RJ” as pertaining to the assessee, computed the incremental negative peak for the year at ₹1,14,52,110/- and added the same under section 69C. Interest accrued as per the diary amounting to ₹12,91,279/- was added under section

MUKESH MOHANLAL VAGHELA,MUMBAI vs. DCIT CC 1(1) , AHMEDABAD

The appeal of the Department is allowed for assessment year 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

reassessment proceedings, the assessee reiterated his earlier contentions. The Assessing Officer again treated the ledger “Mukesh Ratnajyot / Mukeshbhai RJ” as pertaining to the assessee, computed the incremental negative peak for the year at ₹1,14,52,110/- and added the same under section 69C. Interest accrued as per the diary amounting to ₹12,91,279/- was added under section