DARED SEVA SAHKARI MANDALI LIMITED,BHAVNAGAR, GUJARAT vs. ITO, WARD-1(1), BHAVNAGAR

In the result, appeal of the assessee in ITA no

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Has Arisen From The Separate Appellate

58,357/- was raised by the AO , vide reassessment order dated 29.03.2023 passed by the AO u/s 147 read with Section 144B of the 1961 Act. 4

DCIT CENTRAL CIRCLE 1(3) ,AHMEDABAD, AAYKAR BHAVAN, ASHRAM ROAD vs. SIDDHESWARI INFRASTRUCTURE, JUDGES BUNGLOW ROAD

The appeals are dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 595 & 596/Ahd/2023 िनधा"रण वष" /Assessment Years: 2016-17 & 2017-18 Respectively The Dcit Siddheswari Infrastructure बनाम/ Circle-1(3) B-101, Shakti Enclave V/S. Ahmedabad Judges Bungalows Road Ahmedabad – 380 054 "थायी लेखा सं./Pan: Abmfs 3587 R (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : -None- Revenue By : Shri Rignesh K. Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/09/2024 घोषणा की तारीख /Date Of Pronouncement: 23/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 147 Date of Reassessment 29.09.2021 29.09.2021 Order Key Additions by AO - Rs.1,38,65,603 - Rs.2,10,62,866 (Unexplained (Unexplained transactions) transactions) ITA Nos.595 & 596/Ahd/2023 The DCIT vs. Siddheswari Infrastructure Asst. Years : 2016-17 & 2017-18 - Rs.3,85,82,434 - Rs.36,50,754 (Excess (Estimated profit @ depreciation on heavy 20% of bogus sales on machinery) Rs.23

DCIT CENTRAL CIRCLE- 1(3), AAYKAR BHAVAN vs. SIDDHESWARI INFRASTRUCTURE, JUDGES BUNGLOW ROAD

The appeals are dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 595 & 596/Ahd/2023 िनधा"रण वष" /Assessment Years: 2016-17 & 2017-18 Respectively The Dcit Siddheswari Infrastructure बनाम/ Circle-1(3) B-101, Shakti Enclave V/S. Ahmedabad Judges Bungalows Road Ahmedabad – 380 054 "थायी लेखा सं./Pan: Abmfs 3587 R (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : -None- Revenue By : Shri Rignesh K. Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/09/2024 घोषणा की तारीख /Date Of Pronouncement: 23/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 147 Date of Reassessment 29.09.2021 29.09.2021 Order Key Additions by AO - Rs.1,38,65,603 - Rs.2,10,62,866 (Unexplained (Unexplained transactions) transactions) ITA Nos.595 & 596/Ahd/2023 The DCIT vs. Siddheswari Infrastructure Asst. Years : 2016-17 & 2017-18 - Rs.3,85,82,434 - Rs.36,50,754 (Excess (Estimated profit @ depreciation on heavy 20% of bogus sales on machinery) Rs.23

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

SMT. MANJULABEN B. PATEL,BARODA vs. THE DY.CIT. CENTRAL CIRCLE-1, BARODA

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without

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

58,950.27/- (USD 89,054). 4. The ld. CIT(A) erred in law and on facts in holding that 100% of the addition is taxable on a substantive basis in the hands of the appellant as against the AO adding 50% on a substantive basis and 50% on a protective basis. This amounts to enhancement and is not permissible without