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., ,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

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

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

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

RAMESHKUMAR G. PATEL,VADODARA vs. THE ITO, WARD-3(1)(5) PRESENT JURISDICTION ITO, WARD-3(1)(2), VADODARA

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

section 142(1) on 04.09.2019,\n26.09.2019, and 12.10.2019, seeking explanation on the source of\ninvestment and requiring details of income and expenses claimed in the\nreturn. The assessee either did not respond or sought adjournments. In the\ncourse of the reassessment proceedings, the AO also issued a notice under\nsection 133(6) of the Act to the Sub-Registrar, Vadodara

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed by the assessee

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed by the assessee

NIRANJANBHAI D. PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(1)(1), AHMEDABAD

In the result, all four appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

reassessment, the AO observed that the assessee, along with co-owners, had sold lands during the year for a total consideration of Rs. 2,74,59,970/-. After reducing the cost of acquisition of Rs. ITA No.449,450, 470 and 471/Ahd/2024 4 70,35,635/-, the net surplus of Rs. 2,04,24,335/- was claimed by the assessee

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

section 148 and framed the ITA No.254 to 256 and 274 to 276 /Ahd/2024 3 reassessment under section 143(3) r.w.s

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

274 read with section 271(1)(c) or any other section and interest under section 234A,234B, 234C, 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

VIKAS VIJAY GUPTA,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby\ndismissed

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No. 404/Ahd/2024\nAssessment Year 2017-18\nVikas Vijay Gupta\nPrincipal Commissioner\n604 Sarap,\nof Income Tax,\nOpp. Navjivan Press Vs Ahmedabad-1,\nP.O. Navjivan,\nAhmedabad\nAhmedabad-380014,\nGujarat\n(Respondent)\nPAN: AEOPG6723L\n(Appellant)\nAssessee Represented: Shri Jaimin Shah, A.R.\nRevenue Represented: Shri R. N. Dsouza, CIT-DR\nDate of hearing : 27-02-2025\nDate of pronouncement : 27-05-2025\nआदे

reassessment order\nconcluded the unexplained amount of Rs.66,63,250/= is required\nto be taxed u/s.69A in line with section 115BBE of the Act and also\ninitiated penalty proceeding u/s.271AAC[1] of the Act but\nerroneously issued penalty notice u/s.271[1][c] of the Act, which is\nerroneous and prejudicial to the interest of the Revenue and\nthereby setaside

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

reassessment shall be deemed to constitute satisfaction of Assessing Officer for initiation of penalty proceedings in term of section 271(1B). Therefore, in view of the above factual and legal position, I hold that Assessing Officer had recorded his satisfaction as mandated by the law and hence arguments of Ld. Authorized Representative on this account are rejected. 6.2. The appellant