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

ii) Raj Kumar Chawla v.lTO [2005] 94 ITD 1 (DELHI)(SB) iii) ITO v. Smt. Sukhini P. Modi [2008] 112 1TD1 (AHD.) iv) Alpine Electronics Asia Pvt. Ltd. Vs. DGIT and Others[2012] 341ITR 247 (Delhi) v) DIT Vs. V.R. Educational Trust - ITA No.510/2011 dated 10.02.2012. vi) Shri Mohinder Kumar Chhabra vs ITO, ITA No. 3523/Del/2013 (ITAT Delhi) vii) Pr.CIT

ASHVIN PARSOTTAMBHAI SARDHARA,AHMEDABAD vs. THE ACIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Dr. Brr Kumar & Ms Suchitra Kamblei.Ta. No.68/Ahd/2025 (Assessment Year: 2013-14) Ashvin Parsottambhai Vs. The Assistant Sardhara, Commissioner Of B-27, Sudarshan Tower, Income Tax, Opp. Sun-N-Step Club, Circle-4(1)(1), Sal Hospital Road, Ahmedabad. Thaltej, Ahmedabad-380054. [Pan No.Bdjps2083Q] (Appellant) .. (Respondent) Appellant By : Shri D K Parikh, Ar Respondent By: Adjournment Application Filed Date Of Hearing 11.03.2025 Date Of Pronouncement 18.03.2025 O R D E R

reassessment order. On the facts and in view of the submissions made, the order passed being untenable in law ought to be quashed. It be quashed now. 2. Without prejudice to the above ground, the Id CIT (Appeals)/NFAC further erred in law and on facts in not properly considering the grounds No: 3 to 8 and elaborate submissions thereon

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available

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

ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available