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., ,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

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.-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

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

SHRI NIRAL KRUPESH PATEL,BARODA vs. THE DY.CIT, CIRCLE-1(3), BARODA

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

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment or rectification proceedings. Now the question arises, whether the summon issued under section 131(1A) can be equated as proceeding as envisaged under section 271(1)(c)of the Act. The answer certainly stand in negative. It is because, the summon was issued under section 131(1A) of the Act by the ADIT much before the initiation

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

VARIJ BUILDERS PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER,. WARD-8(4), AHMEDABAD

In the result, assessee’s appeal is allowed; whereas the appeal of the Revenue is dismissed

Bench: Ms.Annapurna Gupta, Accountant Memeber & T.R. Senthil Kumarassessment Year : 2008-09 Varij Builders P.Ltd. Ito, Ward-8(4) 2, Sejal House Vs Ahmedabad. Nr. Maninagar Railway Station Maninagar Ahmedabad 380 008. Pan : Aaccv5656Q Assessment Year : 2008-09 Ito, Ward-8(4) Varij Builders P.Ltd. Ahmedabad. Vs 2, Sejal House Nr. Maninagar Railway Station Maninagar Ahmedabad 380 008 अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Ms.Nupur Shah, Ar & Shri Dhiren Shah, Ar Revenue By : Shri Rameshkumar L. Sadhu, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 09/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 16/02/2022 आदेश/O R D E R Per T.R. Senthil Kumar: These Are Cross Appeals One Filed By The Assessee In Ita No.1915/Ahd/2013 & Another Filed By The Revenue In Ita No.2008/Ahd/2013 Against Order Dated 9.5.2013 Passed By The Ld.Commissioner Of Income-Tax (Appeals)-Xiv, Ahmedabad [In Short Referred As “Ld.Cit(A)”] Relating To The Assessment Year 2008-09. Ita No.1915 & 2008/Ahd/2013 2 2. Original Grounds Of Appeal Raised By The Assessee Are As Follows: “1. The Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Addition Of Unexplained Cash Credit U/S.68 Of The Act Of Rs.92,00,000/- On Account Of Share Application Money Received In Cash.

Section 148 of the Act to reopen the assessment was issued on account of reduction in the investments made in mutual funds (from Rs. 2,52,00,000/-, for the year ending 31.03.2007 to Rs. 2,26,21,274/-, for the year ending 31.03.2008), which had not been shown/offered to tax in the form of gain or loss, on account

THE ITO, WARD 8(4),, AHMEDABAD vs. VARIJ BUILDERS PVT. LTD.,, AHMEDABAD

In the result, assessee’s appeal is allowed; whereas the appeal of the Revenue is dismissed

Bench: Ms.Annapurna Gupta, Accountant Memeber & T.R. Senthil Kumarassessment Year : 2008-09 Varij Builders P.Ltd. Ito, Ward-8(4) 2, Sejal House Vs Ahmedabad. Nr. Maninagar Railway Station Maninagar Ahmedabad 380 008. Pan : Aaccv5656Q Assessment Year : 2008-09 Ito, Ward-8(4) Varij Builders P.Ltd. Ahmedabad. Vs 2, Sejal House Nr. Maninagar Railway Station Maninagar Ahmedabad 380 008 अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Ms.Nupur Shah, Ar & Shri Dhiren Shah, Ar Revenue By : Shri Rameshkumar L. Sadhu, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 09/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 16/02/2022 आदेश/O R D E R Per T.R. Senthil Kumar: These Are Cross Appeals One Filed By The Assessee In Ita No.1915/Ahd/2013 & Another Filed By The Revenue In Ita No.2008/Ahd/2013 Against Order Dated 9.5.2013 Passed By The Ld.Commissioner Of Income-Tax (Appeals)-Xiv, Ahmedabad [In Short Referred As “Ld.Cit(A)”] Relating To The Assessment Year 2008-09. Ita No.1915 & 2008/Ahd/2013 2 2. Original Grounds Of Appeal Raised By The Assessee Are As Follows: “1. The Ld. Cit(A) Has Erred In Law & On Facts In Confirming The Addition Of Unexplained Cash Credit U/S.68 Of The Act Of Rs.92,00,000/- On Account Of Share Application Money Received In Cash.

Section 148 of the Act to reopen the assessment was issued on account of reduction in the investments made in mutual funds (from Rs. 2,52,00,000/-, for the year ending 31.03.2007 to Rs. 2,26,21,274/-, for the year ending 31.03.2008), which had not been shown/offered to tax in the form of gain or loss, on account

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

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 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