ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

reassessment proceedings cannot be conducted on the basis of search conducted in case of third party more particularly when no details related to appellant are found therein. The ld CIT(A) ought to have treated notice u/s 148 as invalid as AO ought to have issued notice u/s 153C of the Act as proceedings have been initiated based upon documents

ARCOY INDUSTRIES (INDIA) PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, all the captioned four appeals of the assessee are hereby\nallowed

reassessment proceedings cannot be conducted on the basis of search\nconducted in case of third party more particularly when no details related to\nappellant are found therein. The ld CIT(A) ought to have treated notice u/s\n148 as invalid as AO ought to have issued notice u/s 153C of the Act as\nproceedings have been initiated based upon documents

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

reassessment order u/s. 147 r.w.s. 144B of the Act dated 30th March, 2022 , should not be revised within the provisions of section 263 of the Act. The said show cause notice is reproduced hereunder:- “M/s/Ms/Ms Subject: Notice for Hearing in respect of Revision proceedings u/s 263 of the THE INCOME TAX ACT-1961-Assessment Year 2014-15. In this regard

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEHAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page

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

search was conducted precisely for the reason that the foreign bank accounts of the assessee were not disclosed to the Department in their Income Tax returns. The information as available with the Department was confronted to the assessee in the course of statement recorded during the search. Therefore, the admission of the 51 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page