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

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

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

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

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

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

THE INCOME TAX OFFICER,WARD-3, GANDHINAGAR vs. SHRI RAMESH GOBARJI THAKOR, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2010-11 Income-Tax Officer Vs. Shri Ramesh Gobarji Thakor Ward-3 Sector 11 Gandhinagar. Gandhinagar. Pan : Aespt 3446 H (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ars. Revenue By : Shri Kamlesh Makwana, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 16/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/07/2024 आदेश आदेश/O R D E R आदेश आदेश

u/s 144 of the Act and aggregated credit entries of Rs.6,80,50,635/- made in the said bank account were treated as unexplained and addition of Rs.6,80,50,635/- was made by the I.T.O: Ward- 5(3)(4), Ahmedabad. The appellant has filed the copies of four sale deeds of the lands sold by Shri Mukesh J. Shah

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

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. APPLITECH SOLUTION LTD.,, AHMEDABAD

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

reassessment orders u/s 143(3) r.w.s 147 on 23.03.2005 and he made major disallowance on account of depreciation and interest solely relying upon the order for A. Y. 2000-01 . (4) Being aggrieved and dissatisfied, the assessee preferred appeals before CIT(A) for A.Ys 1997-98 and 1998-99 and also A.Ys.1999-2000,2001-02 and 2002-03 which

SATYA SANKALP VILLA (ELLISBRIDGE) PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-8(1),, AHMEDABAD

In the result, appeal preferred by the assessee is dismissed

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1132/Ahd/2014 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2004-05) िनधा"रण वष" Satya Sankalp Villa The Income Tax Officer बनाम बनाम/ बनाम बनाम Ward – 8(1), Ahmedabad (Ellisbridge) P. Ltd. Vs. Dharmadev House, Shyamal Cross Road, Satellite, Ahmedabad, Gujarat 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaics2707B (Appellant) .. (Respondent) Shri Mahesh Chhajed, A.R. अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 05/06/2024 24/06/2024 Date Of Pronouncement O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of Commissioner Of Income Tax (Appeals)-Xiv, Ahmedabad (In Short ‘The Cit(A)’), Dated 16.01.2014 For A.Y. 2004-05. 2. This Is Second Round Of Appeal Before This Tribunal. Before We Adjudicate The Grounds Taken By The Assessee In This Appeal, It Will Be Relevant To Recapitulate The Facts Of The Case.

115 taxmann.com 105 (SC) for his contention that it was mandatory for the AO of the assessee to record his satisfaction before initiating proceeding under Section 153C of the Act. The Ld. AR also contended that order passed by the AO was bad and illegal as the addition was made without any incriminating material. According

M/S GREENWELL ORCHARDS,AHMEDABAD vs. THE PR.CIT-3 , AHMEDABAD

In the result, appeal filed by the Assessee is allowed

section 263 (1)(b) of the Act namely the A.O. has not conducted proper enquiry while passing the reassessment order. It is seen from the record, more particularly Paper Book at pages 115 to 178 in reply to the show cause notice issued u/s.142[1] dated 09.08.2017, the assessee produced before the Assessing Officer copy of the sale register, sales

SHRI BHUMIKA STRIPS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee in ITA No

115 BBE of the Act. 3. Aggrieved against the reassessment order, the Assessee filed an appeal before the CIT(A), who has confirmed the additions made by the Assessing Officer, thereby dismissing the appeal filed by the Assessee. 4. Aggrieved against the same, the Assessee is in appeal before us raising the following Grounds of Appeal

SHRI BHUMIKA STRIPS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee in ITA No

115 BBE of the Act. 3. Aggrieved against the reassessment order, the Assessee filed an appeal before the CIT(A), who has confirmed the additions made by the Assessing Officer, thereby dismissing the appeal filed by the Assessee. 4. Aggrieved against the same, the Assessee is in appeal before us raising the following Grounds of Appeal

SHRI BHUMIKA STRIPS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee in ITA No

115 BBE of the Act. 3. Aggrieved against the reassessment order, the Assessee filed an appeal before the CIT(A), who has confirmed the additions made by the Assessing Officer, thereby dismissing the appeal filed by the Assessee. 4. Aggrieved against the same, the Assessee is in appeal before us raising the following Grounds of Appeal

CORRTECH ENERGY LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD

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

Bench: Shri P.M. Jagtap, Vice- & Ms. Madhumita Royassessment Year : 2013-14 Corrtech Energy Ltd., Dy. Commissioner Of 22, Dhara Centre, Near Vijay Cross Vs Income-Tax, Roads, Navrangpura, Circle 1(1)(2), Ahmedabad-380009 Ahmedabad Pan : Aaaci 8838 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Tushar Hemani, Sr Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Shri Mukesh Thakwani, Sr. Dr

reassessment u/s. 143(3) r.w.s. 147 of the Act as valid and justified without appreciating the fact that the same was bad in law and invalid in as much as the same being based on invalid notice issued u/s. 148 of the Act on mere change of opinion. 2. The Ld. CIT(A) has erred in law and on facts

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

115 ITR 519 (SC) explained that deduction is allowable even where income was not actually earned in the AY in question. This aspect of the matter was dealt with by this Court in M/s Cheminvest Ltd. (supra) where it reversed the decision of the Special Bench of the ITAT by observing as under: 33 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

115 ITR 519 (SC) explained that deduction is allowable even where income was not actually earned in the AY in question. This aspect of the matter was dealt with by this Court in M/s Cheminvest Ltd. (supra) where it reversed the decision of the Special Bench of the ITAT by observing as under: 33 I.T.A No. 198 & 199/Ahd/2023 & Ors. A.Ys