ABDULVAHED A. SHEIKH, LEGAL HEIROF LATE SMT. SARIFABEN BIKHUBHAI SHEK,,AHMEDABAD vs. THE ITO, WARD-7(2)(5),, AHMEDABAD

The appeal of the assessee is allowed in above terms

Section 133(6) was served to the Court Receiver and that on what date the AO has received the reply from Court Receiver is not mentioned as per Para No. 3 of the assessment order. (f). The Show Cause Notice [SCN] dated 03-10-2016 was served by the speed post to all the legal heirs [as per Para

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

reassessment proceedings with respect to ledger account seized were based on invalid order and were without jurisdiction. Reference is also drawn to the judgment/decision of Hon’ble Supreme Court in the case of ITO vs. Vikram Sujitkumar Bhatia, Civil Appeal No. 911 of 2022 (SLP) (C) No. 29096 of 2019 and oths. order dated 06.04.2023 and PCIT vs. Abhishar Buildwell

INCOME TAX WARD 4(2)(3) AHMEDABAD , AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings initiated under section 147 of the Act beyond the period of four years are not sustainable in law in the absence of any failure on the part of the assessee to fully and truly disclose material facts. 36. Accordingly, in light of our observations for assessment year 2014- 15 on identical set of facts, the reopening of assessment

INCOME TAX WARD 4(2)(3) AHMEDABAD, AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings initiated under section 147 of the Act beyond the period of four years are not sustainable in law in the absence of any failure on the part of the assessee to fully and truly disclose material facts. 36. Accordingly, in light of our observations for assessment year 2014- 15 on identical set of facts, the reopening of assessment

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings initiated under section 147 of the Act beyond the period of four years are not sustainable in law in the absence of any failure on the part of the assessee to fully and truly disclose material facts. 36. Accordingly, in light of our observations for assessment year 2014- 15 on identical set of facts, the reopening of assessment

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings initiated under section 147 of the Act beyond the period of four years are not sustainable in law in the absence of any failure on the part of the assessee to fully and truly disclose material facts. 36. Accordingly, in light of our observations for assessment year 2014- 15 on identical set of facts, the reopening of assessment

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessment proceedings initiated under section 147 of the Act beyond the period of four years are not sustainable in law in the absence of any failure on the part of the assessee to fully and truly disclose material facts. 36. Accordingly, in light of our observations for assessment year 2014- 15 on identical set of facts, the reopening of assessment

NA ROTO MACHINE & MOULDS INDIA,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

39,51,870/-. 2. The Ld. CIT(A) has erred in law and on facts by upholding the Order of the Ld. AO ignoring the fact that incriminating documents received during the course of survey operation at the premises of third party was merely a dump document and neither in the handwriting of the appellant nor have signature

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022

VANKAR DAYABHAI ,VADODARA vs. THE ITO, WARD-3(1)(4), VADODARA

Bench: Ms. Suchitra Kamble

reassessment proceedings under Section 148 of the Act has been initiated by the JAO vide notice dtd. 13-03-2023 after introduction of e- Assessment/Faceless Income Escaping Assessment Scheme, 2022 under Section 151A of the Act and hence, the notice issued by the JAO is without jurisdiction and illegal and also in violation of Notification No: 18/2022