ITO, WARD-1, PALANPUR, PALANPUR vs. GELOT AGRI EXPORTS, PALANPUR

The appeal of the assessee is allowed, while that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

10. Thereafter, the ld.counsel for the assessee contended that in terms of provisions of section 270A sub-section (2) of the Act, no penalty was leviable on the addition/disallowance which were of the nature to be adjusted in the intimation made under section 143(1)(a) of the Act. He drew our attention to section 270A(1) sub-section

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

GUJARAT MEDICAL EDUCATION AND RESEARCH SOCIETY AHMEDABAD,GANDHINAGAR vs. THE DY.CIT, CIRCLE-1, EXEMP, AHMEDABAD

In the result, the appeals of the assessee for A

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

reassessment ex parte under section 147 read with sections 144 and 144B of the Act on 24.03.2023 and treated cash deposits aggregating to Rs.186,78,95,978/- as unexplained money under section 69A ITA Nos. 2612 to 2616/Ahd/2025 Gujarat Medical Education and Research Society Ahmedabad vs. DCIT Asst. Years –2015-16 & 2018-19 - 5– of the Act, time deposits

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

10. The issue for consideration before us is that whether penalty under Section 270A of the Act can be levied in the instant set of facts, when as per the assessee, she was under the genuine belief that since taxes has been deducted at source on such sale of property then there was no occasion to file return of income

MAHAVEER SINGH,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

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

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

10-02-2023 of the Act which is a clear case of under reporting of income. For ready reference Section 270A(2)(b) is reproduced as follows: “270A. (1) The Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner may, during the course of any proceedings under this Act, direct that any person who has under-reported

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

270A of the I T Act. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming the charging of interest under section 234A, 234B, 234C and 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

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

270A of the I T Act. 3.0 The learned Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming the charging of interest under section 234A, 234B, 234C and 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

URMIN PRODUCTS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(3), AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

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." 10.1 As per sub-section (2) of Section 14A of the Act, if the Assessing Officer having regard

URMIN PRODUCTS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(3), AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

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." 10.1 As per sub-section (2) of Section 14A of the Act, if the Assessing Officer having regard

NA ROTO MACHINE & MOULDS INDIA,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

270A of the Act was received and thereafter the present appeal was filed. Considering the explanation of the assessee, the delay in filing the appeal is condoned. 3. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2017-18 on 03.10.2017 declaring total income of Rs.1

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE DY.CIT, CIRCLE-1, BHAVNAGAR

The appeal of the assessee is allowed for statistical purposes

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Dy. Cit-1, Private Limited Vs. Circle-1, Ground Floor, Bhavnagar – 364 001 Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri Abhijit, Sr.Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

270A of the Act. 6. Aggrieved by the reassessment order, the assessee preferred an appeal before the Commissioner of Income-tax (Appeals). In the grounds of appeal, the assessee challenged the validity of reopening under section 147, alleging lack of jurisdiction and violation of procedure under section 144B. On merits, it was contended that the Assessing Officer erred in disallowing

ACIT, CIRCLE-1, BHAVNAGAR, BHAVNAGAR vs. LEELA GREENSHIP RECYCLING PRIVATE LIMITED, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for statistical purposes in terms of above directions

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 2111/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Leela Greenship Recycling Pvt. Ltd., The Deputy Office No.303, 3Rd Floor, बनाम/ Commissioner V/S. B Wing, Leela Efcee, Of Income Tax, Near Aksharwadi Temple, Circle-1, Waghawadi Road, Bhavnagar. Bhavnagar-364002. "थायी लेखा सं./Pan: Aagcg8956L

reassessment initiated under section 147 of the Act. After setting out the statutory framework governing reopening of assessments and analysing a series of judicial pronouncements, the learned CIT(A) recorded a categorical finding that the reopening was valid. It was held that the information received from the GST anti-evasion wing regarding the assessee’s transactions with Mahadev Trading

GANDHINAGAR DISTRICT CO.OP.MILK PRODUCERS UNION LIMITED,GANDHINAGAR vs. THE ACIT, CIRCLE GANDHINAGA, GANDHINAGAR

In the result, appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

10,62,90,443/- despite detailed specific submissions made by the appellant on such issue before Ld. CIT(A). 6. Both the lower authorities have passed the orders without properly appreciating the facts and they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before

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

270A for\nunder-reporting and misreporting of income and under section\n271AAC on the additions made under sections 68, 69, and 69A.\nInterest under sections 234A, 234B, 234C and 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

SAVLI TALUKA SECONDARY AND HIGHER SECONDARY EMPLOYEES CO OP. CREDIT SOCIETY LIMITED,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(2), VADODARA

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1772/Ahd/2024 िनधा"रण वष" /Assessment Year : 2019-20 Savli Taluka Secondary & The Income Tax Officer बनाम/ Higher Secondary Employees Ward-1(2)(2) V/S. Co-Op. Credit Society Ltd. Vadodara – 390 007 18, Rayakaka Park Savli Desar Road Vadodara – 391 770. "थायी लेखा सं./Pan: Aafas 6647 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Sanket Bakshi, Ar Revenue By : Shri Abhijit Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

10. The learned CIT(A) and the learned AO erred in fact and in law in charging interest u/s. 234B of the Act. 11. The learned CIT(A) and the learned AO erred in fact and in law in charging interest u/s. 234C of the Act. 12. The learned CIT(A) and the learned AO erred in fact

AMRUTA FABRICS PVT. LTD.,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal filed by the assessee is allowed in part

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1110, 1111 & 1112/Ahd/2024 (िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) बनाम/ Amruta Fabrics Pvt. Ltd. The Pr. Cit 199, New Cloth Market, Ahmedabad-1 Vs. Opp. Raipur Darwaja, Sarangpur, Ahmedabad, Gujarat, 380002 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaica0877A (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Ms. Astha Maniar, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhendu Das, Cit. Dr 18/09/2024 Date Of Hearing Date Of Pronouncement 21/10/2024

reassessment proceedings 3.2 The Ld. PCIT has erred in law and on facts in not appreciating that the limitation period u/s 263(2) of the Act will be calculated from the date of passing of original assessment order dated 04.11.2015 and thus, the notice issued u/s 263 of the Act dated 29.02.2024 is barred by limitation 4. The Ld. PCIT