SEJALBEN PATEL,VADODARA vs. THE PR.CIT, VADODARA-1, VADODARA

The appeal of the assessee is allowed

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Sejalben Patel The Pr.Cit-1 1049, Kantvalue Faliyu Vs. Vadodara. At & Po-Karkhadi Tal. Padra, Dist. Vadodara. Pan : Drhpp 9550 D Asstt.Year : 2018-19 Binitaben Sandipkumar Patel The Pr.Cit-1 Javla, Chotra Pase Vs. Vadodara. Savli, Dist. Vadodara. Pan : Cwopp 4609 Q (Applicant) (Responent)

reassessment (u/s 147 r.w.s. 144B) 7 Assessed Income Rs.90,350/- (same Rs.1,10,350/- as returned) (same as returned) ITA No.701 & 702/Ahd/2025 4 8 TDS credit claimed Rs.2,400/- under Rs.2,400/- under section 194

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

U/s. 234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

U/s. 234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

U/s. 234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

U/s. 234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

U/s. 234B whereas he has allowed Grounds of Appeal and in respect of that this Ground of Appeal is required to be adjudicated.” 3. The assessee is engaged in the business of development of industrial plots i.e. purchase of land, development of such land, industrial plotting followed by sale of such land. The assessee filed return of income under Section

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

147 are applicable to facts of this case\nand the assessment year under consideration is deemed to be a\ncase where income chargeable to tax has escaped assessment. In\nthis case more than four years have lapsed from the end of\n assessment year under consideration. Hence necessary sanction to\nissue notice u/s 148 is to be obtain separately from

WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

147 of the Act dated 30.05.2023, on the foundation of invalid\nnotice, cannot be survive. Accordingly, the assessment order passed u/s\n147 read with Section 144B of the Act dated 30.05.2023 is quashed. The\nground taken by the assessee is allowed.\n\n12. Since the appeal of the assessee is allowed on the ground of\njurisdiction, the other grounds

WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

147 read with Section 144B of the Act dated 30.05.2023 is quashed. The ground taken by the assessee is allowed. ITA Nos.1228, 1229 & 1230/Ahd/2025 (Assessment Years: 2015-16, 2016-17 & 2017-18) Waves Tradeline Private Limited vs. ITO Page 7 of 18 12. Since the appeal of the assessee is allowed on the ground of jurisdiction, the other grounds

WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

147 read with Section 144B of the Act dated 30.05.2023 is quashed. The ground taken by the assessee is allowed. ITA Nos.1228, 1229 & 1230/Ahd/2025 (Assessment Years: 2015-16, 2016-17 & 2017-18) Waves Tradeline Private Limited vs. ITO Page 7 of 18 12. Since the appeal of the assessee is allowed on the ground of jurisdiction, the other grounds

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

147 of the Act, the assessee would not have reported the escaped amount and then, the said amount would have escaped assessment. The Assessing Officer, therefore, initiated penalty proceedings under Section 270A Parulben Vijakumar Patel vs. ITO Asst.Year –2017-18 - 3– of the Act for misreporting of income and levied penalty @ 200% of the tax payable on such under reported

NA ROTO MACHINE & MOULDS INDIA,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

147 r.w.s.144B of the Act on 15.05.2023 at total income of Rs.1,39,51,870/-. Na Roto Machine & Moulds India vs. ACIT Page 3 of 15 4. Aggrieved with the order of the Assessing Officer, the assessee had filed an appeal before the First Appellate Authority which was adjudicated vide the impugned order and the appeal of the assessee

PROLIFE INDUSTRIES LTD.,ANKLESHWAR vs. THE ITO, WARD-3(1)(1), AHMEDABAD

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

147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2016-17 and 2018-19. Since common issues of unsecured loan, payment of interest and repayment of loans are I.T.A Nos. 2224 & 2225/Ahd/2025 A.Ys. 2016-17 & 2018-19 2 Prolife Industries Ltd. Vs. ITO involved in both the appeals

PROLIFE INDUSTRIES LTD.,ANKLESHWAR vs. THE ITO, WARD-3(1)(1), AHMEDABAD

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

147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2016-17 and 2018-19. Since common issues of unsecured loan, payment of interest and repayment of loans are I.T.A Nos. 2224 & 2225/Ahd/2025 A.Ys. 2016-17 & 2018-19 2 Prolife Industries Ltd. Vs. ITO involved in both the appeals

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

194/- in terms of provisions of section 92CA(1) of the Act on account of determination of arm's length price of international transaction entered into by the assessee. 19. On appeal, the learned CIT(A) upheld the findings of the AO while relying upon his own decision for the AY 2003-04. 20. The assessee is now in appeal

MILAN NARESHKUMAR VARMA,AHMEDABAD vs. THE ITO, WARD-3(2)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed for statistical purpose

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2019-20. I.T.A No. 2050/Ahd/2024 A.Y. 2019-20 Page No 2 Milan Nareshkumar Varma Vs. ITO 2. Brief facts of the case is that the assessee is an individual and doctor by profession. For the Asst. Year 2019-20, the assessee filed

SHALIGRAM INFRA PROJECTS LLP ( LTD. LIABILITY PARTNERSHIP),AHMEDABAD vs. THE JCIT (OSD), CENTRAL CIRCLE-2(2), AHMEDABAD

Appeals are partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarit(Ss)A No.167/Ahd/2021 Asstt.Year : 2017-18 & Asst.Year : 2018-19 Shaligram Infra Projects Llp Vs. The Jcit (Osd) 4Th Floor, Office No.401-402 Central Cir.2(2) B/H. Dishman House Ahmedabad. Opp: Sankalp Grace Ii, Ambli Ahmedabad. Pan: Acpfs 7047 A It(Ss)A No.194,195 & 196/Ahd/2021 Asstt.Year : 2015-16, 2016-17 & 2017-18 & Asst.Year : 2018-19 The Jcit (Osd) Vs. Shaligram Infra Projects Llp Central Cir.2(2) 4Th Floor, Office No.401-402 Ahmedabad. B/H. Dishman House Opp: Sankalp Grace Ii, Ambli Ahmedabad.

reassess the total income of six preceding assessment years, even if the earlier assessments had been completed under section 143(1) or 143(3). However, that decision was premised on the fact that incriminating material (loan documents and supporting GPAs) was actually recovered during the search of the assessee himself, which linked the assessee directly to undisclosed transactions. Likewise

GAUTAMBHAI NANSINH CHAUHAN,ANAND vs. THE ITO, WARD-1(3)(1), PETLAD

In the result, the appeal of the assessee is allowed

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

147 read with section 144B of the Act. 2. Facts of the Case 2.1 The assessee is an individual and a resident of village Khododhi, Khambhat Taluka, District Anand, Gujarat. For the relevant assessment 2 year 2019–20, the assessee did not file return of income under section 139(1). Based on information received through the Insight Portal indicating substantial

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

reassessment. (c) The contents of the declaration shall not be admissible in evidence against the declarant for the purpose of any proceeding under any Act other than the Acts referred in Para- 8 above. 2.9. However, AO did not accept the submission of the assessee due to following reasons: 1. Total of amount worked out as per extrapolation exercise comes