M/S MSK PROJECTS (INDIA) LTD.,BARODA vs. THE ACIT, CIRCLE -4(1),, BARODA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 3142/Ahd/2011 िनधा"रण वष"/Asstt. Year: 2004-2005 M/S. Welspun Projects Limited, Income Tax Officer, (Formerly Known As Msk Project Vs. Ward-4(1), (India) Ltd.,) Vadodara. 707-708, Sterling Centre, R.C. Dutt Road, Vadodara.

u/s 143(3) was completed by the .learned Assistant Commissioner of Income tax after verifying all material .facts and thereafter to issue notice under section 148 is not proper because it is basically a change of opinion. As held in the case of Star India (p) Ltd. Vs. Commissioner of Central Excise

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

section 263 are applicable in this case. The ld. PCIT set aside the reassessment order passed by the AO, dated 30.03.2022 with the directions to the Assessing Officer to pass fresh order in accordance with law after duly examining the facts of the case as discussed by ld. PCIT in its I.T.A No. 590/Ahd/2024 A.Y. 2014-15 Page

SHRI DEEPAK BUDHARMAL VASWANI,,AHMEDABAD vs. DCIT, CENTRAL CIRCLE -1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. SHRI ASHOK SUNDERDAS VASWANI, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

DCIT, CENTRAL CIRCLE -1(1),, AHMEDABAD vs. SHRI DEEPAK KUMAR VASWANI,, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

SHRI RAJESH SUNDERDAS VASWANI,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. SHRI RAJESH SUNDERDAS VASWANI, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

SHRI ASHOK SUNDERDAS VASWANI,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

reassess income of such other person in accordance with the provisions of section 153A. Earlier scope of section 153C was in the cases where the documents seized belong to the assessee, but subsequently the provision of Act has been amended by adding the word 'relating to' in the section 153C. The AO in the present case has issued notice after

MR. ARPANBHAI VIRAMBHAI DESAI,GANDHINAGAR vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

In the result, all four appeals filed by the assessee are\nallowed in above terms

reassessment proceedings as per the\nsubstituted provisions of sections 147 to 151 of the IT Act as\nper the Finance Act, 2021, subject to compliance of all the\nprocedural requirements and the defences, which may be\navailable to the assessee under the substituted provisions of\nsections 147 to 151 of the IT Act and which may be available\nunder

INFINITY INTERNATIONAL,AHMEDABAD vs. NFAC, DELHI PRESENT JURIS. THE ITO, WARD-3(3)(1), AHMEDABAD

In the result, appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalinfinity International, Nfac, Delhi Vs. H-611, Titanium City Centre, Present Jurisdiction 100 Ft. Anandnagar Road, Ito, Ward 3(3)(1), Satellite, Ahmedabad-380015 Ahmedabad [Pan: Aaefi 2610 J] (Appellant) .. (Respondent) Appellant By: Shri S.N. Soparkar, Sr. Advocate & Ms. Ukti Shah, Ar Respondent By: Shri Alpesh Parmar, Cit-Dr Date Of Hearing 07.01.2026 Date Of Pronouncement 10.03.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

Section 147 of the Act when the reasons recorded demonstrate that the assessee has not fully and truly disclosed all material facts necessary for completing the assessment. The Hon’ble Jurisdictional High Court in the case of Amit Polyprints Pvt Ltd. Vs. DCIT, 94 taxmann.com 393, held that reassessment proceedings initiated on the basis of information received from Investigation Wing

M/S. NANDAN EXIM LIMITED,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1),, AHMEDABAD

In the result, assessee’s appeal is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roynandam Exim Limited, Vs. Dcit, Survey No.198, 203/2, Saijpur – Circle – 3(1)(1), Gopalpur, Pirana Road, Piplaj Ahmedabad. Ahmedabad – 382 405. [Pan No. Aaacn 5327 L] (Appellant) (Respondent) ..

reassessment proceedings deserves to be quashed. Further that, it is a settled principle of law that no action shall be taken u/s 147 of the Act after expiry of four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped assessment for such assessment year by reason of the failure on the part

ADINATH LEASING AND FINANCE P LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(1),, AHMEDABAD

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

Bench: Smt. Annapurna Gupta, Accountant Memebr & Shri Mahavir Prasad, Judicial Memebr

u/s 14A r.w.r. 8D - Rs. 1,14,869/- -------------------- Rs. 35,14,869/- ============ 4. Thereafter, assessee preferred first statutory appeal before the learned CIT(A) who confirmed the action of the learned AO on the ground that assessee has made same transaction of purchase of property situated at 7, Nalanda Society, Ahmedabad belonging to Smt. Neela R. Gandhi

INCOME-TAX OFFICER, WARD-1(3)(1), AHMEDABAD, AHMEDABAD vs. PARTHIV JAWAHARBHAI SHAH, AHMEDABAD

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

PARTHIV JAWAHARBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-1(3)(1), AHMEDABAD

The appeal of the asessee is partly allowed for statistical purposes while Revenue’s appeal is dismissed

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

reassessment or recomputation under section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

THE KALUPUR COMMERCIAL CO.-OPERATIVE BANK LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 244A(1) of the IT Act and therefore this ground of appeal is dismissed.” 6. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. Before us, the ld. counsel for the assessee submitted that the reasoning provided by the CIT(A) on page 11 of the order