YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

u/s. 69A of the Income Tax Act. 3. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 5. During the course of hearing, the learned Authorised Representative (AR) reiterated the facts and submitted that the notice issued under section 148 of the Act and the consequential reassessment order passed under section

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

u/s. 69A of the Income Tax Act. 3. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 5. During the course of hearing, the learned Authorised Representative (AR) reiterated the facts and submitted that the notice issued under section 148 of the Act and the consequential reassessment order passed under section

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

u/s. 69A of the Income Tax Act. 3. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 5. During the course of hearing, the learned Authorised Representative (AR) reiterated the facts and submitted that the notice issued under section 148 of the Act and the consequential reassessment order passed under section

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

u/s. 69A of the Income Tax Act. 3. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing. 5. During the course of hearing, the learned Authorised Representative (AR) reiterated the facts and submitted that the notice issued under section 148 of the Act and the consequential reassessment order passed under section

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 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 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

ITO, WARD-2(2)(2), AHMEDABAD vs. JASMIN JAYENDRABHAI THAKKAR, AHMEDABAD

In the result, we answer the question in the affirmative i

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment proceedings initiated under Section 147/148 of the Income-tax Act. 4. The brief facts of the case are that the learned Assessing Officer has issued a notice under Section 148 of the Income-tax Act on 08.01.2016 after recording the reasons. The learned Counsel for the assessee, while impugning the reopening of the assessment, contended that the assessment

ITO, WARD-2(2)(2), AHMEDABAD vs. JASMIN JAYENDRABHAI THAKKAR, AHMEDABAD

In the result, we answer the question in the affirmative i

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment proceedings initiated under Section 147/148 of the Income-tax Act. 4. The brief facts of the case are that the learned Assessing Officer has issued a notice under Section 148 of the Income-tax Act on 08.01.2016 after recording the reasons. The learned Counsel for the assessee, while impugning the reopening of the assessment, contended that the assessment

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

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period

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

reassessment notices issued on or after 1-4-2021 under the erstwhile sections 148 to 151 by relying on Explanations in the Notification No. 20/2021, dated 31-3-2021 and Notification No. 38/2021, dated 27-4-2021 which extended applicability of aforesaid provision as they stood on 31-3- 2021, before commencement of Finance Act, 2021, beyond period