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

292/-, was added to the income of the assessee. The AO initiated penalty proceedings for under-reporting of income in consequence of misreporting ,under section 270A(1) r.w.s 270(A)(9) of the Act. 3. During penalty proceedings, the assessee remained unrepresented and the AO accordingly levied penalty for under reporting of income in consequence of misreporting at the rate

GELOT AGRI EXPORTS,DEESA vs. ITO WD 1 PALANPUR, BANASKANTHA

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

292/-, was added to the income of the assessee. The AO initiated penalty proceedings for under-reporting of income in consequence of misreporting ,under section 270A(1) r.w.s 270(A)(9) of the Act. 3. During penalty proceedings, the assessee remained unrepresented and the AO accordingly levied penalty for under reporting of income in consequence of misreporting at the rate

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

292 (Guj). He also emphasized that the AO has not made reference to any seized material for making addition in the hands of the assessee. This is not relevant assessment year where he can look into all this aspects. This is an assessment year which unabated as per the second proviso to section 153A of the Act, and therefore

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

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 : 2.1 In exercise of the powers given in S. 14A(2) C.B.D.T. has issued

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

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 : 2.1 In exercise of the powers given in S. 14A(2) C.B.D.T. has issued

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

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 : 2.1 In exercise of the powers given in S. 14A(2) C.B.D.T. has issued

RAJIV AMRITLAL PATEL,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(4), AHMEDABAD

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

reassessment order passed under section 147 of the Act relating to Asst. Year 2013-14. I.T(SS)A Nos. 32 to 37/Ahd/2023 & Ors. A.Ys. 2014-15 to 2019-20 & Ors. Page No 2 Rajiv Amritlal Patel vs. DCIT 2. The brief facts of the case is that the assessee is an individual and working as an Accountant

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

292/ to the book profits towards expenditure incurred having nexus with dividend income, which were exempt under Section 10(33). Recording the said statement, the first question is answered in favour of the appellant Revenue and against the respondent assessee.” The assessee has relied upon the judgment of ITAT special bench in the case of Vireet Investment

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

292/ to the book profits towards expenditure incurred having nexus with dividend income, which were exempt under Section 10(33). Recording the said statement, the first question is answered in favour of the appellant Revenue and against the respondent assessee.” The assessee has relied upon the judgment of ITAT special bench in the case of Vireet Investment

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

292/ to the book profits towards expenditure incurred having nexus with dividend income, which were exempt under Section 10(33). Recording the said statement, the first question is answered in favour of the appellant Revenue and against the respondent assessee.” The assessee has relied upon the judgment of ITAT special bench in the case of Vireet Investment