DARED SEVA SAHKARI MANDALI LIMITED,BHAVANAGAR 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

deduction u/s. 80P of the Act of Rs. 3,92,061/- was denied to the assessee. and notice of demand u/s 156 of Rs. 2,58,357/- was raised by the AO , vide reassessment order dated 29.03.2023 passed by the AO u/s 147

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

deduction u/s 80 IB. I.T.A No. 702 & 729/Ahd/2016 A.Y. 2011-12 Page No 30 Sun Pharmaceutical Industries Ltd. Vs. ACIT/Dy. CIT vs. Sun Pharmaceutical Industries Ltd xvi. Why, while claiming allocable office expenses the expense under the head legal, secretarial, corporate affairs etc are excluded. These are common expenses and should also be pro rata allocated to the units claiming

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

In the result, the captioned appeals are :

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

147 of the Income Tax Act, 1961 ("the Act"). Disallowance u/s. 14A: 2. The learned CIT(A) erred in fact and in law in confirming the action of AO in making disallowance by invoking the provision of section 14A of the Act and also in directing the AO to recalculate the amount of disallowance as per Rule

THE DCIT, CIRCLE-1(1),, VADODARA vs. M/S. GUJARAT INDUSTRIES POWER CO.LTD.,, VADODARA

In the result, the captioned appeals are :

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

147 of the Income Tax Act, 1961 ("the Act"). Disallowance u/s. 14A: 2. The learned CIT(A) erred in fact and in law in confirming the action of AO in making disallowance by invoking the provision of section 14A of the Act and also in directing the AO to recalculate the amount of disallowance as per Rule

THE DY. CIT., CIRCLE-1(1)(1),, VADODARA vs. M/S. GUJARAT INDUSTRIES POWER CO. LTD.,, VADODARA

In the result, the captioned appeals are :

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

147 of the Income Tax Act, 1961 ("the Act"). Disallowance u/s. 14A: 2. The learned CIT(A) erred in fact and in law in confirming the action of AO in making disallowance by invoking the provision of section 14A of the Act and also in directing the AO to recalculate the amount of disallowance as per Rule

THE KAMRAN VIKAS CO.OP. CREDIT SOCIETY LTD. ,SABARKANTHA vs. THE INCOME TAX OFFICER, WARD-1, HIMATNAGAR

In the result the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1657 To 1659/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) िनधा"रण वष"

reassessment order passed u/s 147 r.w.s 143(3) are bad in law. (2) The Learned Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in sustaining the disallowance of deduction

THE KAMRAN VIKAR CO.OP. CREDIT SOCIETY LTD.,SABARKANTHA vs. THE INCOME TAX OFFICER, WARD-1, HIMATNAGAR

In the result the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1657 To 1659/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) िनधा"रण वष"

reassessment order passed u/s 147 r.w.s 143(3) are bad in law. (2) The Learned Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in sustaining the disallowance of deduction

THE KAMRAN VIKAS CO.OP. CREDIT SOCIETY LTD.,SABARKANTHA vs. THE INCOME TAX OFFICER, WARD-1 , HIMATNAGAR

In the result the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1657 To 1659/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2013-14, 2014-15 & 2017-18) िनधा"रण वष"

reassessment order passed u/s 147 r.w.s 143(3) are bad in law. (2) The Learned Commissioner of Income Tax (Appeals) has erred in law and on facts of the case in sustaining the disallowance of deduction

THE DCIT, CIRCLE-4(1) (1),, AHMEDABAD vs. M/S. SHAH FOILS PVT. LTD.,, AHMEDABAD

Appeal is partly allowed and the Revenue’s appeal is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar1. आयकर अपील सं /Ita No.1852/Ahd/2019 2. आयकर अपील सं /Ita No.1922/Ahd/2019 िनधा"रण वष" /Assessment Year : 2011-12 1. M/S.Shah Foils Ltd. 1. The Ito, Ward-4(1)(3) बनाम/ 26, Block-B, Galaxy Ahmedabad-380 015 V/S. Signature, Science City Rd Sola, Ahmedabad-380 060 2. The Ito, 2. M/S.Shah Foils Ltd. Ward-4(1)(3) 26, Block-B, Galaxy Ahmedabad-380 015 Signature, Science City Rd Sola, Ahmedabad-380 060 "थायी लेखा सं./Pan: Aaics 0490 F (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri K.C. Thaker, Ar Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 28/01/2025 घोषणा की तारीख /Date Of Pronouncement: 31/01/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Cross-Appeals By The Assessee & The Revenue Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad [Hereinafter Referred To As “Cit(A)”], Dated 23.10.2019, Arising Out Of The Assessment Order Dated 29.12.2017 Passed Under Section 143(3) Read

reassessment proceedings under Section 147 stands dismissed. On the Grounds relating to addition of Rs.7,51,35,438/- u/s 69A of the Act: 12. Both the assessee and the revenue have contested the addition made under Section 69A. The assessee argues that the entire addition of Rs.7,51,35,438/- is unjustified, as it is based solely on third-party

PATEL AMBALAL LAXMANDAS NI CO.,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(3), AHMEDABAD

In the result, all the appeals filed by the Assessee are hereby dismissed

reassessment proceedings was to be upheld. 7.3. Further the ld. CIT(A) in his impugned order at page No. 23 held as follows: 5.1 ………. 5.2 From rom the critical perusal of the recording of the reason for initiating proceedings u/s 148 and for obtaining prior approval of the Commissioner of Income Tax as provided by the AO, I find that

PATEL AMBALAL LAXMANDAS NI CO.,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(3), AHMEDABAD

In the result, all the appeals filed by the Assessee are hereby dismissed

reassessment proceedings was to be upheld. 7.3. Further the ld. CIT(A) in his impugned order at page No. 23 held as follows: 5.1 ………. 5.2 From rom the critical perusal of the recording of the reason for initiating proceedings u/s 148 and for obtaining prior approval of the Commissioner of Income Tax as provided by the AO, I find that

PATEL AMBALAL LAXMANDAS NI CO.,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(3), AHMEDABAD

In the result, all the appeals filed by the Assessee are hereby dismissed

reassessment proceedings was to be upheld. 7.3. Further the ld. CIT(A) in his impugned order at page No. 23 held as follows: 5.1 ………. 5.2 From rom the critical perusal of the recording of the reason for initiating proceedings u/s 148 and for obtaining prior approval of the Commissioner of Income Tax as provided by the AO, I find that

SEQUEL LOGISTICS PRIVATE LIMITED,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

147 r.w.s. 144 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2017-18. I.T.A No. 1114/Ahd/2024 A.Y. 2017-18 Page No 2 Sequel Logistics Pvt. Ltd. vs. PCIT 2. Brief facts of the case is that the assessee is a Company engaged in the business of Logistic Services. For the Asst

SHIVGANGA PROPERTY HOLDERS PVT. LTD,AHMEDABAD vs. ITO, WARD-4(1)(3), 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 :

u/s. 143(3) r.w.s. 147 of the Act in pursuance thereof was not in accordance with law and consequently ought to be held as void ab-initio 2. The Ld. CIT (A) has erred in law and on facts in failing to properly appreciating the written submission of the appellant company and various judicial pronouncements relied upon by the appellant

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 :

u/s. 143(3) r.w.s. 147 of the Act in pursuance thereof was not in accordance with law and consequently ought to be held as void ab-initio 2. The Ld. CIT (A) has erred in law and on facts in failing to properly appreciating the written submission of the appellant company and various judicial pronouncements relied upon by the appellant

ITO, WARD-4(1)(3), AHMEDABAD vs. SHIVGANGA PROPERTY HOLDERS 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 :

u/s. 143(3) r.w.s. 147 of the Act in pursuance thereof was not in accordance with law and consequently ought to be held as void ab-initio 2. The Ld. CIT (A) has erred in law and on facts in failing to properly appreciating the written submission of the appellant company and various judicial pronouncements relied upon by the appellant

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

147 taxmann.com 201) (All) had taken a contrary view. After the declaration of law on the issue by the Hon’ble Apex Court, reference and reliance on various other decisions of different High Courts and Tribunals, will be otiose. The doctrine of precedence is absolute for the lower courts and therefore, we don’t find it necessary to refer

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

147 taxmann.com 201) (All) had taken a contrary view. After the declaration of law on the issue by the Hon’ble Apex Court, reference and reliance on various other decisions of different High Courts and Tribunals, will be otiose. The doctrine of precedence is absolute for the lower courts and therefore, we don’t find it necessary to refer

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

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

147 taxmann.com 201) (All) had taken a contrary view. After the declaration of law on the issue by the Hon’ble Apex Court, reference and reliance on various other decisions of different High Courts and Tribunals, will be otiose. The doctrine of precedence is absolute for the lower courts and therefore, we don’t find it necessary to refer