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

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

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

32. Both the learned DR and the AR before us vehemently supported the order of the authorities below as favourable to them. 33. We have heard the rival contentions of both the parties and perused the materials available on record. The first controversy arises whether the assessment framed under section 147 read with section

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

32. Both the learned DR and the AR before us vehemently supported the order of the authorities below as favourable to them. 33. We have heard the rival contentions of both the parties and perused the materials available on record. The first controversy arises whether the assessment framed under section 147 read with section

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

u/s 147 of the Act. (KAVITA P. KAUSHIK) Dy. Commissioner of Income-tax Central Circle-1(3), Ahmedabad.” 17. A perusal of the above reasons would indicate that the Assessing Officer has reopened the assessment on the ground that the assessee had made deposits in cash aggregating to Rs.1.63 crores. This cash deposit, in the opinion of the Assessing Officer

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

u/s 147 of the Act. (KAVITA P. KAUSHIK) Dy. Commissioner of Income-tax Central Circle-1(3), Ahmedabad.” 17. A perusal of the above reasons would indicate that the Assessing Officer has reopened the assessment on the ground that the assessee had made deposits in cash aggregating to Rs.1.63 crores. This cash deposit, in the opinion of the Assessing Officer

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

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147

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

32 I.T.A No. 1894/Ahd/2019 A.Y. 2000-01 Page No Manjulaben Bipinbhai Patel Legal Heir of Late Bipinbhai P. Patel & 81 ors. respective income tax returns. Further, this decision was in the context of reopening beyond 4 years and in consideration of Proviso to section 147 of the Act. In fact, the Proviso to section 147