CHIRAG ISHWARBHAI PATEL,AHMEDABAD vs. THE ITO, WARD-3(3)(6), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1182 & 1192/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-11 Chirag Ishwarbhai Patel, I.T.O., 49 Dharamanth Prabhu Society, Vs. Ward-3(3)(6), Near Adishawar Society, Ahmedabad. Nikol Road, Naroda, Ahmedabad.

234D of the Act s to be computed as per law and facts on the record. 4. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 3. The first issue raised by the Assessee is that the Ld. CIT-A erred in holding the assessment framed under section 143(3) read

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

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

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

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

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

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

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

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

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

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

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

In the result the appeal filed by assessee is partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

reassessment proceedings vide issuance of reopening notice dated 31 March 2018 under section 148 of the IT Act without appreciating the fact that it was issued beyond a period of four years and accordingly was time barred in terms of first proviso to section 147 of the IT Act. IRM Pvt. Ltd. vs. DCIT

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

234D of the Act as applicable after giving credit for taxes paid by the assessee. Relevant to mention that before the DPO, Panel-2, Mumbai, the assessee on 12.02.2021 by way of additional ground challenged the validity of the TPO’s order being barred by limitation. The case of the assessee before the Hon’ble DRP is this that

GUJARAT STATE ELECTRICITY CORPORATION LTD.,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

In the result, the appeal filed by the Assessee is allowed for statistical purpose

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

reassessment proceedings under section 147 of the I T Act, the claim was not considered and the depreciation claimed in the original return was only allowed. The additional ground was preferred merely because the same was left to be taken in the appeal filed against the present impugned assessment order. 2.0 The learned Commissioner of Income Tax (Appeals) erred

NASIMBANU MIRZA,AHMEDABAD vs. THE ITO, WARD-3(2)(8)- CURRENTLY THE ITO, WARD-3(2)(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 376/Ahd/2024 ("नधा"रण वष" / Assessment Year: 2011-12) बनाम/ Nasimbanu Mirza Ito B/67, Mayurpark Society, Ward-3(2)(1), Ahmedabad Vs. Opp. Bibi Talab, Vatva, Daskroi, Ahmedabad, Gujarat - 382440 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Bfkpm6262E (Appellant / Cross Objector) .. (Respondent) Assessee By : Ms. Foziya Saiyed, A.R. Shri Kavan Limbasiya, Sr. Dr Revenue By : 25/03/2025 Date Of Hearing Date Of Pronouncement 27/03/2025

234D or any other section should be deleted. 4). The appellant craves leave to add, amend, alter or delete the said ground of appeal. 4.1 The assessee has also raised an additional ground as under: 5). On the facts and in the circumstances of the case as well as in law on the subject the Learned Assessing Officer has heard

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. DCIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Bench: Us.

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.’ 2. New Rule 8D : I.T.A No. 406/Ahd/2019 A.Y. 2015-16 Page No 13 Gujrat Urja Vikas Nigam

GUJARAT URJA VIKAS NIGAM LIMITED,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

234D of the Income Tax Act, 1961. 4.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” 4. Ground No.1:- This ground relates to disallowance under Section 14A of the Act. 5. The Ld. A.O. disallowed

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

234D of the Income Tax Act, 1961. 4.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” 4. Ground No.1:- This ground relates to disallowance under Section 14A of the Act. 5. The Ld. A.O. disallowed

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

234D of the Income Tax Act, 1961. 4.0 The appellant craves leave to add to, alter, delete or modify any of the grounds of appeal either before or at the time of hearing of this appeal.” Ground No.1:- This ground relates to disallowance under Section 14A 4. of the Act. ITA Nos.318&414/Ahd/2020 Gujarat Urja Vikas Nigam Ltd. vs. ACIT/DCIT

ITO, WARD-4(2)(3), AHMEDABAD, AHMEDABAD vs. MAHESHWARI SALES CORPORATION, AHMEDABAD

In the result, the appeal filed by the Revenue stands dismissed

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

reassessment proceedings, notices under sections 143(2) and 142(1) of the Act were issued and the assessee filed various details including audited accounts, computation of income, bank statements, and ledger of Kushal Tradelink in its books. The assessee contended that no cash transaction was made with Kushal Tradelink and that all transactions represented genuine sales made in the ordinary

SHRI RUSHABHDEV SWETAMBAR MURTIPUJAK JAIN SANGH,AHMEDABAD vs. THE ITO, WARD-2 (EXEMPTION), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

reassessment Shri Rushabhdev Swetambar Murtipujak Jain Sanghvs.ITO(E) Asst.Year –2012-13 - 4– proceedings void ab initio. It was further contended that all income, expenditure, bank transactions, and TDS details of the trust were duly reflected in the audited financial statements and the return filed under the valid PAN i.e. AAATR5288B. 7. The learned CIT(A) called for a remand report

DUSHYANT SHANTILAL PATEL,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

234D was also levied.\nAccordingly, the assessed income was computed at Rs.1,31,23,819/-\nwhich was rounded off to Rs.1,31,23,820/-. The assessment was\ncompleted ex parte as the assessee failed to furnish complete details\nor comply with the notices.\n5. The assessee preferred appeal before CIT(A), who dismissed the\nappeal of the assessee ex parte