THE ITO, WARD-4(1)(3), AHMEDABAD vs. SHRI VIGHNAHARTA REALITY PVT. LTD., AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

reassessment. ITA Nos.2370, 2112, 2205 and 2206/Ahd/2018 & CO Nos.108 & 137/Ahd/2019 Shri Vighnaharta Reality Pvt.Ltd. & Shivganga Property Holders P.Ltd. vs. ITO Asst. Year : 2012-13 8.4. Accordingly, we uphold the order of CIT(A) and dismiss the legal grounds raised by the assessee. The AO had sufficient grounds to reopen the assessment, and the CIT(A) correctly sustained the jurisdiction assumed

SHRI VIGHNAHARTA REALTY PVT. LTD,AHMEDABAD vs. THE ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

reassessment.\n\nITA Nos.2370, 2112, 2205 and 2206/Ahd/2018 &\nCO Nos.108 & 137/Ahd/2019\nShri Vighnaharta Reality Pvt.Ltd. & Shivganga Property Holders P.Ltd. vs. ITO\nAsst. Year: 2012-13\n14\n8.4.\nAccordingly, we uphold the order of CIT(A) and dismiss the legal\ngrounds raised by the assessee. The AO had sufficient grounds to reopen the\nassessment, and the CIT(A) correctly sustained

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

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकरअपीलसं./Ita No. 200/Ahd/2021 धििाधरणवरध/Asstt. Year: 2012-2013 Atul Hiralal Shah, D.C.I.T, 8, Amrashirish Bungalows, Vs. Central Circle-1(2), Near Prahladnagar Garden, Ahmedabad. Prahladnagar, Ahmedabad-380015. Pan: Aljps4966M

90 or section 90A and ending with the date on which the information requested is last received by the Commissioner or a period of one year, whichever is less, shall be excluded in computing the period of limitation for the purposes of section 153. Similar amendments are also proposed in the Explanation to section 153B of the Income

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

reassessment 90,37,67,440/ under due to failure - under Section of the section 68 as 147 read assessee to unexplained

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

reassessment 90,37,67,440/ under due to failure - under Section of the section 68 as 147 read assessee to unexplained

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

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

LEELA GREENSHIP RECYCLING PVT. LTD.,BHAVNAGAR vs. THE DY. CIT, CIRCLE-1, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for\nstatistical purposes in terms of above directions

section 147 r.w.s.144B. n the course of reassessment,\nthe assessee produced purchase register entries, ledger and confirmation\nfrom M/s. Mahadev Trading Co., invoices and transport documents, RTGS\nevidence of payments, matching entries in GSTR-2A; and handwritten\nweighment slips. The AO rejected the explanation, observing that the\ninvoices mentioned the buyer as \"Ganpatrai Jaigopal Shipbreakers Pvt.\nLtd.\", not \"Leela Greenship

ACIT, CIRCLE-1, BHAVNAGAR, BHAVNAGAR vs. LEELA GREENSHIP RECYCLING PRIVATE LIMITED, BHAVNAGAR

In the result, both the appeals are treated as partly allowed for statistical purposes in terms of above directions

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 2111/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Leela Greenship Recycling Pvt. Ltd., The Deputy Office No.303, 3Rd Floor, बनाम/ Commissioner V/S. B Wing, Leela Efcee, Of Income Tax, Near Aksharwadi Temple, Circle-1, Waghawadi Road, Bhavnagar. Bhavnagar-364002. "थायी लेखा सं./Pan: Aagcg8956L

90,420/-, and penalty proceedings under section 271AAC were initiated separately. 3. In appeal before the CIT(A), the assessee challenged the reopening itself as without jurisdiction and also contested the addition on merits. The learned CIT(A) carefully examined the entire assessment record, written ITA Nos.2111 & 2135/Ahd/2024 Leela Greenship Recycling Pvt. Ltd. vs. DCIT A.Y 2018-19 4 submissions

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

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

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

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial

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

Section 132(4) of the Act that he was settlor of the trust and that the beneficiaries of the trust were all his family members constituted incriminating material. The Ld. CIT.DR submitted that in spite of being confronted with all the documentary evidences which clearly established that the foreign bank accounts belonged to the assessee, the assessee was in denial