RASHMIN KANTILAL VAKTA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

reassessment proceedings. However, it is an admitted position that the AO did not carry out any independent verification of these materials—no enquiries were made under section 133(6), nor were the creditors summoned under section 131 to verify their creditworthiness or the genuineness of the transactions. 41. The learned CIT(A) accepted the explanation of the assessee and held

RASHMIN KANTILAL VAKTA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

reassessment proceedings. However, it is an admitted position that the AO did not carry out any independent verification of these materials—no enquiries were made under section 133(6), nor were the creditors summoned under section 131 to verify their creditworthiness or the genuineness of the transactions. 41. The learned CIT(A) accepted the explanation of the assessee and held

MANISH RANJAN, DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. RASHMIN KANTILAL VAKTA, AHMEDABAD

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

reassessment proceedings. However, it is an admitted position that the AO did not carry out any independent verification of these materials—no enquiries were made under section 133(6), nor were the creditors summoned under section 131 to verify their creditworthiness or the genuineness of the transactions. 41. The learned CIT(A) accepted the explanation of the assessee and held

MANISH RANJAN, DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYKAR BHAWAN ASHRAM ROAD, AHMEDABAD vs. RASHMIN KANTILAL VAKTA, ELLISBRIDGE AHMEDABAD GUJARAT

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokar

reassessment proceedings. However, it is an admitted position that the AO did not carry out any independent verification of these materials—no enquiries were made under section 133(6), nor were the creditors summoned under section 131 to verify their creditworthiness or the genuineness of the transactions. 41. The learned CIT(A) accepted the explanation of the assessee and held

SHRI ANILBHAI HIRALAL SHAH,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

reassessment proceedings. 7 Ld. CIT (A) erred in law and on facts confirming addition made by AO of unaccounted income earned from various scripts u/s 69A of the Act though assessee is not found to be owner of any money, bullion or jewellery. 8 Ld. CIT (A) erred in law and on facts confirming addition

DEEP SUDHIRBHAI SHETH (LEGAL HEIR OF SUDHIR HIMMATLAL SHETH),AHMEDABAD vs. ITO, WARD 3(2)(1), AHMEDABAD, AHMEDABAD

In the result the appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Makarand V. Mahadeokarasstt. Year: 2016-17 Deep Sudhirbhai Sheth (Legal Heirs Ito, Ward-3(2)(1) Of Sudhir Himmatlal Sheth) Vs. Ahmedabad. Prop. Subhlaxmi Jewellers 3, Khodiyar Shopping Centre Nr.Ishanpur Bus Stand Ishanpur, Ahmedabad. Pan : Ainps 3786 Q (Applicant) (Respondent) Assessee By : Shri Chetan Agarwal, Ar Revenue By : Shri Nitin Vishnu Kulkarnai, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 10/11/2025 घोषणा की तारीख /Date Of Pronouncement: 28/11/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

reassessment proceedings, a notice under section 148 was issued on 18.03.2023. Thereafter, notice under section 143(2) and several notices under section 142(1) along with questionnaires were issued on different dates. The Assessing Officer has tabulated the chronology of notices, including show cause notices under section 144 and centralised reminder communication, and has recorded that no compliance was made

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

44,950/-. Subsequently, during\nthe course of processing disclosures made under the Income Declaration\nScheme (IDS), 2016, it came to the notice of the Department that the\nassessee had disclosed investment of Rs.92,62,433/- in immovable\nproperty for the relevant previous year 2012–13. As per the Department's\nrecords, the total tax liability under IDS was computed

ROHITKUMAR CHINUBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

section 147 was completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment

SAURABHBHAI ROHITBHAI MODI,AHMEDABAD vs. THE ACIT, CIR. 5(2) NOW DCIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is hereby dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

section 147 was completed on 17.12.2014 determining the total income at Rs.45,44,450/-Once again, the Assessing Officer initiated reassessment

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)

reassessment, as the case maybe, under the said sub-sections (1), (2) and (3) shall be extended by twelve months. Section 153 of the Act does not permit passing any order after the expiry of 33 months from the end of the assessment year i.e. AY 2016-17 in the present case. Therefore, the time limit for completing assessment

SHRI MUKESH R.SHAH,AHMEDABAD vs. THE ACIT.,CIRCLE-6,, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Smt. Suchitra Kambleasstt Year - 2001-02

reassessment under section 147 is clearly invalid. Re-assessment framed, therefore, under section 147 of the Act is set aside. The appeal of the assessee is allowed on this count. Assessee’s appeal in ITA No.3331/Ahd/2010 (Asst.Year 2001-02) 28. This appeal arises from the rectification proceedings conducted on the re-assessment order passed under section

SHRI MUKESH RASIKLAL SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, CENT.WARD-1(1),, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Smt. Suchitra Kambleasstt Year - 2001-02

reassessment under section 147 is clearly invalid. Re-assessment framed, therefore, under section 147 of the Act is set aside. The appeal of the assessee is allowed on this count. Assessee’s appeal in ITA No.3331/Ahd/2010 (Asst.Year 2001-02) 28. This appeal arises from the rectification proceedings conducted on the re-assessment order passed under section

SHRI MUKESH R.SHAH,AHMEDABAD vs. THE ACIT.,CIRCLE-6,, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Smt. Suchitra Kambleasstt Year - 2001-02

reassessment under section 147 is clearly invalid. Re-assessment framed, therefore, under section 147 of the Act is set aside. The appeal of the assessee is allowed on this count. Assessee’s appeal in ITA No.3331/Ahd/2010 (Asst.Year 2001-02) 28. This appeal arises from the rectification proceedings conducted on the re-assessment order passed under section

SHRI MUKESH R.SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, CENT.WARD-1(1),, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Smt. Suchitra Kambleasstt Year - 2001-02

reassessment under section 147 is clearly invalid. Re-assessment framed, therefore, under section 147 of the Act is set aside. The appeal of the assessee is allowed on this count. Assessee’s appeal in ITA No.3331/Ahd/2010 (Asst.Year 2001-02) 28. This appeal arises from the rectification proceedings conducted on the re-assessment order passed under section

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

reassessment, as provided under section 147 read with section 149, was over and the liability for assessment was completely extinguished. Thus, at the time of issuance of the notices for reopening and at the time of amendment, the right to initiate proceedings under section 147 was extinguished for certain assessment years as per the old provisions. The Hon’ble Kerala

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEHAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

reassessment, as provided under section 147 read with section 149, was over and the liability for assessment was completely extinguished. Thus, at the time of issuance of the notices for reopening and at the time of amendment, the right to initiate proceedings under section 147 was extinguished for certain assessment years as per the old provisions. The Hon’ble Kerala

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

reassessment, as provided under section 147 read with section 149, was over and the liability for assessment was completely extinguished. Thus, at the time of issuance of the notices for reopening and at the time of amendment, the right to initiate proceedings under section 147 was extinguished for certain assessment years as per the old provisions. The Hon’ble Kerala

MANJULABEN BIPINBHAI PATEL LEGAL HEIR OF LATE BIPINBHAI P.PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

reassessment, as provided under section 147 read with section 149, was over and the liability for assessment was completely extinguished. Thus, at the time of issuance of the notices for reopening and at the time of amendment, the right to initiate proceedings under section 147 was extinguished for certain assessment years as per the old provisions. The Hon’ble Kerala