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)

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

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)

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

ii) DCIT, Circle – Vaishnodevi Circle, S.G. 1(1)(1), Highway, Ahmedabad Ahmedabad. "थायी लेखा सं./जीआइआर सं./PAN/GIR No.:AAACC 6253 G (Appellant) .. (Respondent) : Shri Mukesh Patel & Shri Jigar अपीलाथ" ओर से /Appellant by Patel, A.Rs. : Ms. Saumya Pandey Jain, ""थ" की ओर से/Respondent by Sr.D.R. Date of Hearing 12/03/2024 30/05/2024 Date of Pronouncement

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

reassessment notice under Section 148 of the new regime within the time limit surviving under the Income Tax Act read with TOLA and that all notices issued beyond the surviving period were time barred and liable to be set aside. This time-line was also demonstrated in para 112 of the order with an illustration. 8.3. In the present case

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

32. In the case of Shri Girish Vitthalbhai Patel vs. ITO in ITA Nos. 798, 799, 800 & 801/Ahd/2015, the ITAT Ahmedabad made the following observations on this issue: “12. As regards ITA No.801/Ahd/2015 for Assessment Year 2011-12, penalty under Section 271(1)(c) cannot be levied in this assessment year as this is the search year in view