JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

reassessment and directed the Assessing Officer to pass a fresh order after considering the entire bank credits of Rs.123.12 crores. Pursuant to this direction, the case was again taken up in faceless proceedings and several notices under section 142(1) of the Act were issued by the Assessing Officer. Since the assessee again confined himself only to raising objections

SHRI MAHESH P. GANDHI,AHMEDABAD vs. THE ACIT., CIRCLE-10,, AHMEDABAD

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita Nos.1022 To 1025/Ahd/2018 िनधा"रण वष"/Asstt. Year: (1992-1993 To 1995-1996) Shri Mahesh P. Gandhi, A.C.I.T., D-404, 5Th Floor, Vs. Circle-10, Dharnidhar Tower, Ahmedabad. Paldi, Ahmedabad.

234B of the Act, on the last assessed income. 5. That the appellant craves liberty to add, amend, alter and delete any grounds of appeal before the final hearing. 3. The assessee in ground No. 1 and 2 has challenged the validity of the assessment framed under section 147 read with section 143(3)/254

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

MUKESH MOHANLAL VAGHELA,MAHARASHTRA 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

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,AHMEDABAD 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

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

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

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

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, 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., ,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