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. Copy of the same was provided to the assessee vide order sheet entry dated 28/07/2016 by the A.O. The assessee firm vide letter dated 17.08.2016 submitted to the A.O. that they have no objection for the re-assessment proceedings. Subsequently, the A.O. issued notice u/s. 143(2) 142(1) requiring the assessee firm to furnish various details

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. Copy of the same was provided to the assessee vide order sheet entry dated 28/07/2016 by the A.O. The assessee firm vide letter dated 17.08.2016 submitted to the A.O. that they have no objection for the re-assessment proceedings. Subsequently, the A.O. issued notice u/s. 143(2) 142(1) requiring the assessee firm to furnish various details

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. Copy of the same was provided to the assessee vide order sheet entry dated 28/07/2016 by the A.O. The assessee firm vide letter dated 17.08.2016 submitted to the A.O. that they have no objection for the re-assessment proceedings. Subsequently, the A.O. issued notice u/s. 143(2) 142(1) requiring the assessee firm to furnish various details

SHRI SHIVAJIRAO R.CHAVAN,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-13(2),, AHMEDABAD

The appeals of the assessee are allowed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Roy

reassess the assessee u/s 147 of the Act.The relevant findings of the Hon’ble Court are reproduced hereunder: 13. The Court finds that in none of the above grounds is there any reference to any inquiry conducted by the AO or the CIT (A) on examining the above documents, which were available with the AO. The crucial element of explaining

THE ITO, WARD-13(2),, AHMEDABAD vs. SHRI SHIVAJIRAO R.CHAVAN,, AHMEDABAD

The appeals of the assessee are allowed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Roy

reassess the assessee u/s 147 of the Act.The relevant findings of the Hon’ble Court are reproduced hereunder: 13. The Court finds that in none of the above grounds is there any reference to any inquiry conducted by the AO or the CIT (A) on examining the above documents, which were available with the AO. The crucial element of explaining

VIKAS VIJAY GUPTA,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby\ndismissed

Bench: DR. BRR Kumar, Vice President\nAnd Shri T. R. Senthil Kumar, Judicial Member\nITA No. 404/Ahd/2024\nAssessment Year 2017-18\nVikas Vijay Gupta\nPrincipal Commissioner\n604 Sarap,\nof Income Tax,\nOpp. Navjivan Press Vs Ahmedabad-1,\nP.O. Navjivan,\nAhmedabad\nAhmedabad-380014,\nGujarat\n(Respondent)\nPAN: AEOPG6723L\n(Appellant)\nAssessee Represented: Shri Jaimin Shah, A.R.\nRevenue Represented: Shri R. N. Dsouza, CIT-DR\nDate of hearing : 27-02-2025\nDate of pronouncement : 27-05-2025\nआदे

penalty proceedings u/s 271AAC were initiated.\nHowever, in the concluding para of the assessment order it is incorrectly\nmentioned that \"Notice issued for 271(1)(c) of the Act.\n3. In view of the above, since in assessee's the assessment u/s 147 r.w.s.\n1448 of the Income-tax Act, 1961 (\"Act\") for AY 2017-18 had been\ncompleted

SHRI VIJAY D. PATEL,,AHMEDABAD vs. THE CIT-7,, AHMEDABAD

reassessment proceedings,u/s. 147 of the Act.The assessee had failed to file any return originally, but on initiation of re-assessment proceedings, return was filed declaring income of Rs. 33,260,50/- under the head income from other sources. The same was accepted by the AO. Subsequently on perusal of records, the ld. PCIT noted the following errors therein

ANIL EXPORTS (INDIA),AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, both the appeals are partly allowed

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

reassessment order u/s. 147 r.w.s 144B as the Assessing Officer after verifying the data has categorically mentioned that the assessee has filed the response to all the notices and furnished the details which does not find any discrepancies and therefore accepted the assessee’s return of income. Further at the time of hearing, the assessee has produced all the details

ANIL EXPORTS (INDIA),AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, both the appeals are partly allowed

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

reassessment order u/s. 147 r.w.s 144B as the Assessing Officer after verifying the data has categorically mentioned that the assessee has filed the response to all the notices and furnished the details which does not find any discrepancies and therefore accepted the assessee’s return of income. Further at the time of hearing, the assessee has produced all the details

CHANDRAKANT GORDHANBHAI PATEL HUF ,DABHOI vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-1(3), VADODARA, VADODARA

In the result, appeal of the assessee in ITA no

Bench: The Final Hearing Of This Appeal Petition…”

reassessment proceedings, but only part-reply was furnished by the assessee. The AO issued SCN invoking provisions of Section 144 with a view to proceed to frame best judgment re-assessment against the assessee.The assessee challenged reopening u/s 147 on the grounds that there is a factual error in reopening proceedings as the assessee has duly filed its return

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)

penalty U/s 271(1)(b) for non compliance of notices, u/s. 271(1)(c) for concealment of income should not be initiated and levied in your case. 4. You are therefore requested to furnish your explanation/ clarification along with the evidences in this regard as well as point wise reply of notices u/s. 142(1) on or before 13/12/2018 positively

M/S. BHAVI LEASING & FINANCE LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1),, VADODARA

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarassessment Year : 2006-07 M/S. Bhavi Leasing & Finance Ltd. Ito, Ward-1(1) 36/3, Sindhi Commercial Market Vs Baroda. Kalupur Ahmedabad 380 001. Pan : Aaacb 9407 F

reassessment done under section 147 has been challenged on various grounds. Before us, the ld.counsel for the assessee primarily challenged reopening for the following reasons: i) Reasons did not reveal any escapement of income in the case of the assessee; ITA No.994 /Ahd/2017 ii) No addition was made of the income which the AO had formed a belief of having

LALITABEN DIPAKBHAI MODH,SURAT vs. PCIT-3, AHMEDABAD, 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 of the Act. Therefore a notice u/s. 148 dated 31-03- 2021 was issued to the assessee. 3. In response, the assessee filed her Return of Income on 28-04- 2021 declaring total income of Rs.99,520/-. The Assessing Officer levied penalty u/s. 271F for not filing the return will within the time limit prescribed u/s

ABDULVAHED A. SHEIKH, LEGAL HEIROF LATE SMT. SARIFABEN BIKHUBHAI SHEK,,AHMEDABAD vs. THE ITO, WARD-7(2)(5),, AHMEDABAD

The appeal of the assessee is allowed in above terms

147) of the income of the deceased and for the purpose of levying any sum in the hands of the legal representative in accordance with the provisions of sub-section (1) any proceeding which could have been taken against the deceased if he had survived, may be taken against the legal representative. Therefore, in the light of the provisions

ALDIABLOS INFOTECH PRIVATE LIMITED,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(1), AHMEDABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 353, 354, 355, 356 & 357/Ahd/2024 िनधा"रण वष" /Assessment Years : 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18

U/s 234B of Rs.1,40,33,568/- aggregating Rs.2,49,97,293/-without appreciating the facts of the assessee. 6). on the facts the assessee no additions ought to have been made. 7). the appellant craves leave to add, to alter and/or to modify any grounds of appeal.” 6. During the course of hearing, the Ld. Authorised Representative

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

SHRI NAVINCHANDRA N. PATEL,VADODARA vs. THE ACIT, CIRCLE-1(2), VADODARA

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

penalty proceedings u/s 271(1)(c) of the Act.” Shri Navinchandra N Patel Vs. ACIT Asst. Year : 2012-13 - 3– 3. The brief facts of the case are that the assessee is an individual engaged in the business of "Trading of Land for project Development & in shares". The assessee had filed his return of income for the year under consideration

SHRI RAVINDRASINH N.GOHIL,,BHAVNAGAR vs. INCOME TAX OFFICE,WARD-1(1),, BHAVNAGAR

Appeal is allowed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

147". In other words, when no reasons are recorded for reopening the assessment prior to issuance of notice, the reassessment proceedings must fail for that reason alone. However, for the reasons we will set out now, the conclusions will be no different even if it is presumed that this communication, extracts from which are reproduced before, only conveys the reasons