DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. DHARMENBHAI MAHENDRABHAI SUTARIA -HUF, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 795/Ahd/2019 With C.O.No.169/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Dharmenbhai M. Sutaria, Huf Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aafhd1653K

cash deposit of Rs.1,53,25,000/- in the City Union Bank (Account No.463205, Navrangpura Branch) and Rs.20,00,000/- in the HDFC Bank Account. Accordingly, the case was reopened and the proceedings for re-assessment were commenced. The reasons for reopening u/s. 148 were duly provided to the assessee, opportunity under natural justice was given

THE DCIT, CENTRAL CIIRCLE-1(2), AHMEDABAD vs. SHRENA S SUTARIA, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 796/Ahd/2019 With C.O.No.172/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Shrena S. Sutaria, Central Circle-1(2), Vs. 8, Amrashagun Bunglows, Ahmedabad. Nr. Hathisingh Park, Satellite, Ahmedabad-380015. Pan: Asqps7606E

cash deposit of ₹ 1,66,00,000/- has escaped assessment in respect of which the assessee failed to disclose fully and truly all material facts necessary for the assessment. Therefore, the AO initiated the proceedings under section 147 of the Act by issuing a notice under section 148 of the Act. 3.4 However, the assessee before the AO has challenged

THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. STHAPATYA SHILP CONSTRUCTION, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 907/Ahd/2019 With C.O.No.170/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sthapatya Shilp Construction, Central Circle-1(2), Vs. 2, Abhiraj Complex, Ahmedabad. 68-B, Swastic Society, Ahmedabad. Pan: Abffs2922P

cash deposit of ₹ 1,14,60,000/- has escaped assessment in respect of which the assessee failed to disclose fully and truly all material facts necessary for the assessment. Thus, the AO initiated the proceedings under section 147 of the Act by issuing a notice under section 148 of the Act. 4.3 However, the assessee before the AO has challenged

GHANSHYAMBHAI AMBALAL PATEL,KHEDA vs. THE PCIT-1, AHMEDABAD

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

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

cash deposit is "ESCAPED INCOME" However, as per settled position of law emerging from various decided cases of ITAT Delhi, Ahmedabad, Amritsar and other courts, this cannot be valid REASON TO BELIEVE REASSESSMENT PROCEEDINGS ARE HELD TO BE BAD IN LAW AND QUASHED. When the so called Order u/s 147

PARESHKUMAR PUNAMCHAND SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-2(2)(4), AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Ramit Kochar (Accountant Member)

cash deposit in the bank account. The assessee also did not filed return of income in pursuance to notice u/s 148.The assessee never asked for reasons recorded by the AO u/s 147 for reopening of the assessment. The assessee did not participated in reassessment

ANISH RAJNIKANT SHAH,AHMEDABAD, GUJARAT vs. INCOME TAX OFFICER, AHMEDABAD, GUJARAT

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

Bench: Shri Ramit Kochar (Accountant Member)

cash deposit of Rs. 21,51,200/- , this case requires to be reopened u/s 147 of the Act.” 4. Further, the statutory notice(s) u/s.142(1) of the Act were also issued by the AO to assessee , from time to time, I.T.A No. 200/Ahd/2024 A.Y. 2011-12 Page No. 4 Anish Rajnikant Shah v. ITO during the course of reassessment

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

147 of the Act. The CIT(A) accordingly dismissed the assessee’s appeal challenging the validity of the reassessment proceedings. 10. Before CIT(A), on merits, the assessee contended that all the deposits made in its bank account with the Society were duly recorded in its regular books of accounts and were explainable with reference to business receipts, loans

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

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

147 of the Act. The CIT(A) accordingly dismissed the assessee’s appeal challenging the validity of the reassessment proceedings. 10. Before CIT(A), on merits, the assessee contended that all the deposits made in its bank account with the Society were duly recorded in its regular books of accounts and were explainable with reference to business receipts, loans

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

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

147 of the Act. The CIT(A) accordingly dismissed the assessee’s appeal challenging the validity of the reassessment proceedings. 10. Before CIT(A), on merits, the assessee contended that all the deposits made in its bank account with the Society were duly recorded in its regular books of accounts and were explainable with reference to business receipts, loans

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

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

147 of the Act. The CIT(A) accordingly dismissed the assessee’s appeal challenging the validity of the reassessment proceedings. 10. Before CIT(A), on merits, the assessee contended that all the deposits made in its bank account with the Society were duly recorded in its regular books of accounts and were explainable with reference to business receipts, loans

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

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)

147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments and additions

SHRI MOHIT PRAFULBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

147 of the IT Act for A.Y. 2010-11 by an amount of more than Rs. 1 lakh as the assessee has failed to disclose fully and truly all material facts necessary for his escapement. Therefore, this is a fit case for issue of Notice u/s. 148 of the IT Act for A.Y. 2010-11. 5. Referring to the same

PINKESHMUMAR MELAPCHAND SHAH,AHMEDABAD vs. THE ITO, WARD-2(2)(4), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2012-13 Pinkeshkumar Melapchand Shah The Ito, Ward-2(2)(4) B-1, 1St Floor, Abhinandan Flat Vs. Ahmedabad. Opp: Kothari Tower Ramnagar, Sabarmati, Ahmedabad 380005.Gujarat. Pan : Aeaps 0609 D. (Applicant) (Responent) : Shri Sunil Maloo, Ca Assessee By Revenue By : Shri Amit Pratap Singh, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 31/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025

147 was furnished. 2. The Ld. CIT(A) grossly erred in law and facts in upholding the addition of Rs.16,69,608/- u/s 69A being cash deposited in ICICI Bank Account generated out of duly accounted business sales by ignoring the debit / withdrawal side of same bank account. 3. The Ld. CIT(A) grossly erred in law and facts