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)

36 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT made in cases where no exempt income has accrued, arisen or received by the assessee during an assessment year. 3. The CBDT issued Circular No.5 of 2014, dated 11/02/2014, clarifying that rule 8D read with Section 14A of the Act provides

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)

36 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT made in cases where no exempt income has accrued, arisen or received by the assessee during an assessment year. 3. The CBDT issued Circular No.5 of 2014, dated 11/02/2014, clarifying that rule 8D read with Section 14A of the Act provides

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)

36 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT made in cases where no exempt income has accrued, arisen or received by the assessee during an assessment year. 3. The CBDT issued Circular No.5 of 2014, dated 11/02/2014, clarifying that rule 8D read with Section 14A of the Act provides

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)

36 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys. 2016-17 & 2017-18 Page No Suzlon Engergy Ltd. vs. DCIT made in cases where no exempt income has accrued, arisen or received by the assessee during an assessment year. 3. The CBDT issued Circular No.5 of 2014, dated 11/02/2014, clarifying that rule 8D read with Section 14A of the Act provides

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

36. The brief facts of the case are that search proceedings was conducted at the premises of the assessee on 21.09.2010. The assessee filed return of income in recourse to proceedings under Section 153A of the Act. 37. During the course of assessment, the Assessing Officer observed that assessee had purchased land bearing Block No.77 on 17.03.2005, situated at Bopal

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

DHARMENBHAI MAHENDRABHAI SUTARIA,HUF,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), , AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

DHARMENBHAI MAHENDRABHAI SUTARIA,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalasstt. Sr.No.

reassess the total income for the entire six years block assessment period even in case of completed/unabated assessment. As per the second proviso to Section 153A, only pending assessment/reassessment shall stand abated and the AO would assume the jurisdiction with respect to such abated assessments. It does not provide that all completed/unabated assessments shall abate. If the submission on behalf

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

36,168/- under section 270A of the Act.” In the Revenue’s Appeal: ITA No.225/Ahd/24 ITA No.1739 and 225/Ahd/2024 4 6. We have heard both the parties, and have gone through the orders of authorities below. 7. The argument of the ld.counsel for the assessee that no penalty in terms of the provisions of section 270A either on account

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

36,168/- under section 270A of the Act.” In the Revenue’s Appeal: ITA No.225/Ahd/24 ITA No.1739 and 225/Ahd/2024 4 6. We have heard both the parties, and have gone through the orders of authorities below. 7. The argument of the ld.counsel for the assessee that no penalty in terms of the provisions of section 270A either on account

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. TORRENT POWER LTD.,, AHMEDABAD

In the result, the appeal of the Revenue and the Cross-objection of the assessee, both are dismissed

Bench: Shri Sandeep Gosain & Shri Amarjit Singh

36(l)(vii), 28(ii)(c). The phrase 'wholly and exclusively for the purposes of has been used in sections 37 and 57(iii). On going through the use of the above and other similar expressions in different parts of the Act, it is clearly borne out that these have not been used interchangeably. The Legislature is fully conscious