DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

reassessment proceedings were initiated under section 147 of the Act, on the basis of documents impounded during a survey in the case of M/s. Krishna Developers. The Assessing Officer made additions under section 69A of the Act treating the amounts reflected in the impounded “Red Diary” and “Register” as unexplained cash received by the assessee outside its books of account

DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

reassessment proceedings were initiated under section 147 of the Act, on the basis of documents impounded during a survey in the case of M/s. Krishna Developers. The Assessing Officer made additions under section 69A of the Act treating the amounts reflected in the impounded “Red Diary” and “Register” as unexplained cash received by the assessee outside its books of account

DEWARKADHISH DEVELOPERS,BHARUCH vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all three appeals are dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 635 To 637/Ahd/2025 िनधा"रण वष" /Assessment Years : (2015-16 To 2017-18) Dwarkadhish Developers, The Deputy Commissioner Plot No. H-3066/4, बनाम/ Of Income Tax, V/S. Dwarkadhish Residency, Central Circle-2, Esic Hospital Road, Vadodara. Gidc Ankleshwar, Bharuch-393002. (Gujarat) "थायी लेखा सं./Pan: Aakfd8537F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Adjournment Application Filed Revenue By : Shri Abhijit, Sr-Dr

reassessment proceedings were initiated under section 147 of the Act, on the basis of documents impounded during a survey in the case of M/s. Krishna Developers. The Assessing Officer made additions under section 69A of the Act treating the amounts reflected in the impounded “Red Diary” and “Register” as unexplained cash received by the assessee outside its books of account

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, both appeals of the assessee are allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ It(Ss)A No. 45 & Ita No.204/Ahd/2020 "नधा"रण वष"/Assessment Year: 2005-06 Rohitji Chanduji Thakore Dcit, Cent.Cir.2(1) Chandanami Nivas Vs Ahmedabad. Thakor Vas, Ambali Gam Ahmedabad. Pan : Adtpt 4435 C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr.Adv Parimal Singh B. Parmar, Ar Shri Vijay Govani, Ar Revenue By : Shri Virendra Ojha, Cit-Dr

253 contemplates that the IT(SS)A.No.45/Ahd/2020 and ITA No.1188 /Ahd/2019 Tribunal may admit an appeal or permit filing of memorandum of cross- objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. Similarly, it has been used in section 5 of Indian Limitation

SACHINKUMAR PREMANANDBHAI PATEL,ANAND vs. THE ITO, WARD-1, ANAND

In the result, the appeal of the assessee is allowed

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2013-14 Sachinkumar Premanandbhai Patel Ito, Ward-1 Nr.Old Post Office Vs. Anand. Bhalej Anand Umreth, Gujarat Pan : Auhpp 8057 H (Applicant) (Responent) : Shri B.T. Thakkar, Ar Assessee By : Shri Amit Pratap Sigh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025

reassessment proceedings initiated under section 147 r.w.s. 144 of the Income-tax Act, 1961. 2. Condonation of Delay 2.1 At the outset, it is noted that there is a delay of 233 days in filing the present appeal. The assessee filed an application for condonation of delay supported by a duly sworn affidavit dated 20.03.2025, explaining that the 2 delay

THE DY. CIT (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. GANDHINAGAR URBAN DEVELOPMENT AUHORITY (GUDA),, GANDHINAGAR,

In the result, appeals of the Revenue are dismissed, and Cross

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 1560 & 1561/Ahd/2017 With Cross Objection No.05 & 06/Ahd/2019 "नधा"रण वष"/Assessment Year: 2009-10 & 2010-11 Dy.Cit (Exemptions) Gandhinagar Urban Development Cir.1 Vs Authority, 4Th Floor, Udyog Bhavan Ahmedabad. Sector 11, Gandhinagar 382 011. Pan : Aaalg 0922 K

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross-objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression “sufficient cause” employed in the section has also been used identically in sub-section 3 of section

THE DY. CIT (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. GANDHINAGAR URBAN DEVELOPMENT AUHORITY (GUDA),, GANDHINAGAR,

In the result, appeals of the Revenue are dismissed, and Cross

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 1560 & 1561/Ahd/2017 With Cross Objection No.05 & 06/Ahd/2019 "नधा"रण वष"/Assessment Year: 2009-10 & 2010-11 Dy.Cit (Exemptions) Gandhinagar Urban Development Cir.1 Vs Authority, 4Th Floor, Udyog Bhavan Ahmedabad. Sector 11, Gandhinagar 382 011. Pan : Aaalg 0922 K

253 contemplates that the Tribunal may admit an appeal or permit filing of memorandum of cross-objections after expiry of relevant period, if it is satisfied that there was a sufficient cause for not presenting it within that period. This expression “sufficient cause” employed in the section has also been used identically in sub-section 3 of section

GANESH HOUSING CORPORATION LTD.,,AHMEDABAD vs. THE DY.CIT., CIRCLE-4, NOW, CIRCLE-2(1)(1),, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh"नधा"रण वष"/ Asstt. Year: 2009-2010 Ganesh Housing Corporation Ltd. Dcit, Cir.2(1)(1) “Ganesh Corporate House” Navjivan Trust Bldg. Vs. Ahmedabad. 100 Ft. Hebatpur-Thaltej Road Nr. Sola Bridge Off. S.G. Highway Ahmedabad 380 015. Pan : Aaacg 5590 Q With Co No.216/Ahd/2015 "नधा"रण वष"/ Asstt. Year: 2009-2010 Dcit, Cir.2(1)(1) Ganesh Housing Corporation Ltd. Navjivan Trust Bldg. “Ganesh Corporate House” Vs. Ahmedabad. 100 Ft. Hebatpur-Thaltej Road Nr. Sola Bridge Off. S.G. Highway Ahmedabad 380 015. (Applicant) (Responent) : Shri Dhiren Shah, Ar Assessee By Revenue By : Shri C. Danday, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 19/09/2018 घोषणा क" तार"ख /Date Of Pronouncement: 23/10/2018 आदेश/O R D E R

reassessment proceedings before the A.O as well as in «w appellate proceedings before the Ld. CIT(A). The appellant reserves its right to add, amend, alter or modify any of the grounds stated hereinabove either before or at the time of hearing.” ITA No.3083/Ahd/2015 with CO And ITA No.3034/Ahd/2015 3 3. As far as CO filed by the assessee

THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD vs. GANESH HOUSING CORPORATION LIMITED,, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh"नधा"रण वष"/ Asstt. Year: 2009-2010 Ganesh Housing Corporation Ltd. Dcit, Cir.2(1)(1) “Ganesh Corporate House” Navjivan Trust Bldg. Vs. Ahmedabad. 100 Ft. Hebatpur-Thaltej Road Nr. Sola Bridge Off. S.G. Highway Ahmedabad 380 015. Pan : Aaacg 5590 Q With Co No.216/Ahd/2015 "नधा"रण वष"/ Asstt. Year: 2009-2010 Dcit, Cir.2(1)(1) Ganesh Housing Corporation Ltd. Navjivan Trust Bldg. “Ganesh Corporate House” Vs. Ahmedabad. 100 Ft. Hebatpur-Thaltej Road Nr. Sola Bridge Off. S.G. Highway Ahmedabad 380 015. (Applicant) (Responent) : Shri Dhiren Shah, Ar Assessee By Revenue By : Shri C. Danday, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 19/09/2018 घोषणा क" तार"ख /Date Of Pronouncement: 23/10/2018 आदेश/O R D E R

reassessment proceedings before the A.O as well as in «w appellate proceedings before the Ld. CIT(A). The appellant reserves its right to add, amend, alter or modify any of the grounds stated hereinabove either before or at the time of hearing.” ITA No.3083/Ahd/2015 with CO And ITA No.3034/Ahd/2015 3 3. As far as CO filed by the assessee

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial