JIGNASA ATULKUMAR SHAH,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Transfer Pricing Officer, as the case may be] had been the subject matter of any appeal filed on or before or after the 1st day of June 1988 the powers of the Principal Commissioner or Commissioner under this sub-section shall extend and shall be deemed always to have extended to such matters as hail not been considered and decided

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

reassessed has the effect of reducing the loss or converting such loss into income. (6) The under-reported income, for the purposes of this section, shall not include the following, namely:— (a) the amount of income in respect of which the assessee offers an explanation and the Assessing Officer or29-30[the Joint Commissioner (Appeals) or] the Commissioner (Appeals

DILIPKUMAR BABABHAI ZAVERI,PATAN, GUJARAT vs. PCIT, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Transfer Pricing Officer,\nas the case may be,] is erroneous in so far as it is prejudicial to the interests\nof the revenue, he may, after giving the assessee an opportunity of being\nheard and after making or causing to be made such inquiry as he deems\nnecessary, pass such order thereon as the circumstances of the case\njustify

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

THE ACIT, CIRCLE-5,, AHMEDABAD vs. M/S. JUBILEE TRADELINK PVT. LTD., AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Mrs. Annapurna Gupta & Shri Siddhartha Nautiyalिनधा"रणवष"/Assessment Year: 2008-09 Vs. M/S. Jubilee Tradelink Pvt. Ltd., The Acit, 9B, Bansidhar Apartments, Circle-5, Gyanganga Classes, Ahmedabad Jawaharnagar, Vasna, Ahmedabad Pan : Aabcj 0614 P अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Revenue By : Shri Ravindra, Sr Dr तारीख/Date Of Hearing : 08.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 29.05.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश Per Siddhartha Nautiyal: This Appeal Has Been Filed By The Department Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-9, Ahmedabad [Hereinafter Referred To As "Cit(A)" For Short] Dated 05.01.2016, Passed Under Section 250(6) Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2008-09. 2. The Department Has Taken The Following Grounds Of Appeal:- “1. The Ld. Cit(A) Has Erred In Law & On Facts In Holding The Reassessment Proceedings As Void. 2. The Ld. Cit(A) Has Erred In Law & On Facts By Not Appreciating That The Assessment Was Reopened Within Four Years From The Relevant Assessment Year & The Issue Decided In Reassessment Proceedings Was Not Dealt With During Original Assessment Proceedings..

price at which the appellant has sold these shares. The appellant has submitted during the reassessment proceedings that these shares have been transferred

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

transfer entries in Bank Account [Protective Addition] 3 Disallowance of business expense claimed in P & L A/c.: Kasar(Discount) @ 50% 1,17,622 5,10,530 Salary @ 10% 31,768 2,02,518 Transport comm. @ 20% 19,114 78,922 11,934 Vapsi Exp.(Khedut exp) -- 3,77,600 Municipal

INCOME TAX OFFICER, WARD - 3(3)(5), AHMEDABAD, PANJARAPOLE, AHMEDABAD vs. VIKASH MORE, BODAKDEV, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

reassessment proceedings. The Assessment Order was passed under Section 147 read with Section 144B of the Act dated 30.03.2022 thereby making addition of Rs.1,47,12,954/- as unexplained money under Section 69A of the Act which was claimed by the assessee on sale of shares of M/s. Kushal Tradelink Pvt. Ltd. The Assessing Officer also made addition of Rs.1

VEENITA ENTERPRISE PVT. LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1),, AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

reassessment proceedings in respect of three assessment years i.e. A.Y. 2007-08, A.Y. 2008-09 and A.Y. 2009-10 in which, the entire modus operandi and the scheme of affairs was elaborated and additions were made in the hands of the assessee on the ground that the assessee through the issuance of shares at a high premium to I.T.A

BHAVNA SHETALKUMAR PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee stands allowed

transfer. In these circumstances, the plea raised in the additional\nground is contrary to the record, devoid of merit, and does not give rise\nto any triable issue. The additional ground is accordingly not admitted.\n13.\nThe AR assailed the validity of the reassessment proceedings\ninitiated for the Assessment Year 2016-17 on several grounds. It was\nsubmitted that

OVEZ ARIFBHAI LAKHANI,BHAVNAGAR vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Income Tax Appellate Tribunal, Ahmedabad Benches, Has Arisen From The Revisionary Order Dated 12.03.2024 Passed By Ld. Principal

transferred 1000 shares in financial year 2011-12 itself, and the remaining shares were held in demat account . The remaining 18400 shares of KDJHRL were sold in the financial year 2013-14 i.e. impugned assessment year The assessee submitted before the AO during reassessment proceedings bank statements, cross ledger of M/s Prabhudas Liladhar Private Limited and ledger accounts

GUJARAT INDUSTRIES POWER CO.LTD.,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

In the result, the appeal filed by the assessee is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 3049 & 3050/Ahd/2010 धििाधरणवरध/Asstt. Years: (1998-1999 & 1999 & 2000) Gujarat Industries Power Company The Asst. Commissioner Of Ltd., Vs. Income Tax, P.O Petrochemicals, Circle-1(1), Baroda-391346. Baroda.

reassessment there is not a whisper about re-computation of books profit by the AO. In fact there is no discussion about it in the assessment order and certainly there no formation of opinion on the said issue. In the case of Praful Chunilal Patel vs. M.J.Makwana, ITA nos.3049 & 3050/Rjt/2010 A.Y.s 1998-99 & 1999 & 2000 3 Assistant Commissioner of Income

THE ACIT, CIRCLE-1, BHAVNAGAR vs. SHRI VALLABHBHAI DHANJIBHAI PATEL, BHAVNAGAR

In the result the appeal filed by the Revenue is hereby dismissed

Bench: The Tribunal On

price of sale deed executed in 2006 and such amount is paid by original owners. These facts clearly prove that Title of the land was not clear which is accepted by original owners of the land. On perusal of 7/12 and 8 extracts as submitted before AO and appellate proceedings, that land was never transferred in the name of appellant

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

price as mentioned in the seized documents. Accordingly, the Assessing Officer made addition of Rs. 24,04,282/- in the hands of the assessee for the impugned year under consideration. 4. In appeal, the Ld. CIT(A) dismissed the appeal of the assessee with the following observations: “5.3 Further, with regard to appellant's claim regarding correct jurisdiction