SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

6. Ground No.2, the appellant has challenged imposition of penalty on the ground that Assessing Officer had not recorded proper and specific satisfaction for initiating the penalty proceedings in the assessment proceedings which is necessary even after insertion of section 271(1B). The contentions of the Ld. Authorized Representatives that the Assessing Officer has not recorded proper and specific satisfaction

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD, VADODARA

In the result, the appeal filed by the Assessee in ITA No

6. Ground No.2, the appellant has challenged imposition of penalty on the ground that Assessing Officer had not recorded proper and specific satisfaction for initiating the penalty proceedings in the assessment proceedings which is necessary even after insertion of section 271(1B). The contentions of the Ld. Authorized Representatives that the Assessing Officer has not recorded proper and specific satisfaction

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

6. The issue involves levy of penalty under Section 271AAA on two additions made while framing assessment, consequent to search carried out on 21.09.2010: Amt. (Rs.) Particulars Rs.1,89,43,840/- Undisclosed consideration on sale of land Rs.1,48,00,000/- Protective addition w.r.t. undisclosed capital gain Penalty on addition of Rs. 1,89,43,840/- 7. The brief facts

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.

c) of the Act or under explanation 5A to section to section 271(1) of the Act in the given fact and circumstances. It is important to note that the assessee belongs to a group known as barter/entry provider group which was subject to search under the provisions of section 132 of the Act dated 4 December 2014. In consequence

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.

c) of the Act or under explanation 5A to section to section 271(1) of the Act in the given fact and circumstances. It is important to note that the assessee belongs to a group known as barter/entry provider group which was subject to search under the provisions of section 132 of the Act dated 4 December 2014. In consequence

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.

c) of the Act or under explanation 5A to section to section 271(1) of the Act in the given fact and circumstances. It is important to note that the assessee belongs to a group known as barter/entry provider group which was subject to search under the provisions of section 132 of the Act dated 4 December 2014. In consequence

SHRI NIRAL KRUPESH PATEL,BARODA vs. THE DY.CIT, CIRCLE-1(3), BARODA

In the result the appeal filed by the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment or rectification proceedings. Now the question arises, whether the summon issued under section 131(1A) can be equated as proceeding as envisaged under section 271(1)(c)of the Act. The answer certainly stand in negative. It is because, the summon was issued under section 131(1A) of the Act by the ADIT much before the initiation

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYAKAR BHAWAN, ASHRAM ROAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, , AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

DCIT, CENTRAL CIRCLE1(2), AHMEDABAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes