SHRI SHIVAJIRAO R.CHAVAN,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-13(2),, AHMEDABAD

The appeals of the assessee are allowed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Roy

section 147/148. From the so-called reasons, it was not at all discernible as to whether the Assessing Officer had applied his mind to the information and independently arrived at a belief that, on the basis of the material which he had before him, income had escaped assessment. Therefore, the reassessment was not valid. Principal Commissioner of Income

THE ITO, WARD-13(2),, AHMEDABAD vs. SHRI SHIVAJIRAO R.CHAVAN,, AHMEDABAD

The appeals of the assessee are allowed

Bench: Smt.Annapurna Gupta & Smt. Madhumita Roy

section 147/148. From the so-called reasons, it was not at all discernible as to whether the Assessing Officer had applied his mind to the information and independently arrived at a belief that, on the basis of the material which he had before him, income had escaped assessment. Therefore, the reassessment was not valid. Principal Commissioner of Income

THE ITO, WARD-1,, ANAND vs. M/S. DEVRAJ DEVELOPERS,, ANAND

In the result, appeal of the revenue in ITA No

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. Nos. 1524 To 1526/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2009-10 To 2011-12)

u/s 147 was justified and in accordance with law, considering the reasons recorded and the facts of the case. 1.6 That in the facts and circumstances of the case, and in law, the Ld. CIT(Appeals) has erred in observing that the investment as per the books of account exceeded the investment determined by the DVO towards cost of construction

THE ITO, WARD-1,, ANAND vs. M/S. DEVRAJ DEVELOPERS,, ANAND

In the result, appeal of the revenue in ITA No

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. Nos. 1524 To 1526/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2009-10 To 2011-12)

u/s 147 was justified and in accordance with law, considering the reasons recorded and the facts of the case. 1.6 That in the facts and circumstances of the case, and in law, the Ld. CIT(Appeals) has erred in observing that the investment as per the books of account exceeded the investment determined by the DVO towards cost of construction

THE ITO, WARD-1,, ANAND vs. M/S. DEVRAJ DEVELOPERS,, ANAND

In the result, appeal of the revenue in ITA No

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. Nos. 1524 To 1526/Ahd/2018 ("नधा"रण वष" / Assessment Years : 2009-10 To 2011-12)

u/s 147 was justified and in accordance with law, considering the reasons recorded and the facts of the case. 1.6 That in the facts and circumstances of the case, and in law, the Ld. CIT(Appeals) has erred in observing that the investment as per the books of account exceeded the investment determined by the DVO towards cost of construction

THE DCIT-CIRCLE-4(1)(1), AHMEDABAD vs. SHREE SIDDHI INFRABUILD PVT. LTD, AHMEDABAD

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

u/s 69A of the Act 5 Assessed 11,16,69,870/- 10,32,34,740/- 8,37,42,940/- Income in Rs. 4. The assessee carried the matter in appeals before the CIT(A), challenging both the validity of the reopening of assessments under section 147 and the additions made under sections 68 and 69A on facts

THE DCIT-CIRCLE-4(1)(1), AHMEDABAD vs. SHREE SIDDHI INFRABUILD PVT. LTD, AHMEDABAD

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

u/s 69A of the Act 5 Assessed 11,16,69,870/- 10,32,34,740/- 8,37,42,940/- Income in Rs. 4. The assessee carried the matter in appeals before the CIT(A), challenging both the validity of the reopening of assessments under section 147 and the additions made under sections 68 and 69A on facts

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

In the result, appeal filed by the Assessee is allowed

147 of the Act. It is not the case of the assessee that the A.O. has not conducted necessary inquiry, verification before passing the reassessment order. The same cannot be construed either as ‘Lack of enquiry’ or as ‘Inadequate enquiry’. Thus the ld. PCIT cannot revise the reassessment order merely because he held a different opinion than that is verified

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

SHAMA AJAY PATEL,AHMEDABAD vs. THE CIT(IT & TP), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2017-18 Shama Ajay Patel, Vs. 2, Chandroday Society, The Cit(It & Tp), Opp. Golden Triangle, Sp Ahmedabad Stadium Road, Navjivan Post, Ahmedabad-380014 Pan : Alxpp 5273 E अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Sunil Talati, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 26.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (It & Tp), Ahmedabad [Hereinafter Referred To As Ld. "Cit(It & Tp)" For Short] Dated 08.02.2023, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Challenging The Impugned Order Of The Ld. Cit (It & Tp) Reads As Under:- “1. The Ld. Cit Has Erred In Passing Order U/S 263 Without Jurisdiction & Appropriate Powers Available Under The Act. It Is Submitted That The Order Passed U/S. 263 Is Bad In Law As A.O. Has Neither Committed Any Error Nor It Is Prejudicial To The Interest Of Revenue. It Be Held Now.

Section 263 of the Act as found by the ld. CIT (IT & TP). 10. Undoubtedly, the assessment order sought to be revised was passed u/s 147 of the Act on reopening the case of the assessee for the specific reason that the Assessing Officer had information regarding the dubious dealing in shares of M/s. Kushal Limited. Clearly, the scope

THE DCIT-CIRCLE-4(1)(1), AHMEDABAD vs. SHREE SIDDHI INFRABUILD PVT. LTD, AHMEDABAD

Accordingly kept open.\n10. All Revenue appeals fail on merits and are dismissed

u/s 69A of the Act\n2,00,00,000/-\nAssessed Income in Rs.\n11,16,69,870/-\n10,32,34,740/-\n8,37,42,940/-\n4. The assessee carried the matter in appeals before the CIT(A), challenging\nboth the validity of the reopening of assessments under section 147 and the\nadditions made under sections 68 and 69A on facts

THE HARSIDDHI CO.OP. CREDIT SOCIETY LTD.,MAHISAGAR vs. THE ITO,, LUNAWAD

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 1862/Ahd/2017 "नधा"रण वष"/Assessment Year: 2009-10 The Harsiddhi Co-Op. Credit Ito, Lunawada. Society Ltd., Tower Road Vs At & O : Santrampur 389 260 Dist: Mahisagar, Gujarat Pan : Aabat 3395 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sakar Sharma, Ar Revenue By : Shri T.C.Meena, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 25/03/2019 घोषणा क" तार"ख /Date Of Pronouncement : 26/03/2019

U/s 148 of the Act, in your case-Reg. Sir/Madam, In this connection it is submitted that as per details available with this office, Cash of Rs.99,08,676/- has been deposited in the Bank account of The Harisiddhi Co op Credit Society, during the F.Y. 2008-09. From verification of the record, it is found that

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

reassess under section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under section 154, for any assessment year beginning on or before the 1st day of April, 2001.’ 2. New Rule 8D : 2.1 In exercise of the powers given in S. 14A(2) C.B.D.T. has issued

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

260,000 Total 21,223,718 16,086,323 ITA Nos.1362, 1363 & 1364/Ahd/2025 3 Asst Years: 2014-15 to 2016-17 Shri Bhumika Strips Private Limited Vs. ITO 2.1 The Assessing Officer found that the above parties had shown meagre income and have had only salary income and no business income by M/s. Kabra and Company, as well

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

260,000 Total 21,223,718 16,086,323 ITA Nos.1362, 1363 & 1364/Ahd/2025 3 Asst Years: 2014-15 to 2016-17 Shri Bhumika Strips Private Limited Vs. ITO 2.1 The Assessing Officer found that the above parties had shown meagre income and have had only salary income and no business income by M/s. Kabra and Company, as well

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

260,000 Total 21,223,718 16,086,323 ITA Nos.1362, 1363 & 1364/Ahd/2025 3 Asst Years: 2014-15 to 2016-17 Shri Bhumika Strips Private Limited Vs. ITO 2.1 The Assessing Officer found that the above parties had shown meagre income and have had only salary income and no business income by M/s. Kabra and Company, as well

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.

260 sq yard, Plot No 27= 228 sq mtr= 273 sq yard]. In the page no 58, total area of land and bungalows sold by Shri Ashwin B Dudhat and his brothers and the on-money component of sale consideration has been shown 893 sq yards and Rs.66,521/-per sq yard. 3.4 After analysing seized materials, Revenue appointed Special

THE ITO, WARD-2(2)(1), AHMEDABAD vs. DUSHYANT U PATEL, AHMEDABAD

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

260 Bhagwanbhai R. Prajapati 144150 554574 ITA No. 1197/Ahd/2019 a/w. CO No. 212/Ahd/2019 [Dushyant U Patel] A.Y. 2011-12 - 4 - Kantibhai R. Prajapati 144150 554574 432450 1663722 Total 1663722 B.NO. 261 Motibhai R. Prajapaii 113850 438004 Bhagwanbhai R, Prajapati 113850 438004 Kantibhai R. Prajapati 113850 438004 Total 341550 1314012 1314012 B.NO. Motibhai R. Prajapati 37950 146001 265 Bhagwanbhai R. Prajapati