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

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

reassessment proceedings. 4.3 In the absence of any explanation or documentary evidence, the AO proceeded to complete the assessments ex parte under section 147 r.w.s. 144 read with section 144B of the Act, treating the cash deposits appearing in the information report as unexplained money under section 69A. The entire deposits were added to the total income, without allowing

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

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

reassessment proceedings. 4.3 In the absence of any explanation or documentary evidence, the AO proceeded to complete the assessments ex parte under section 147 r.w.s. 144 read with section 144B of the Act, treating the cash deposits appearing in the information report as unexplained money under section 69A. The entire deposits were added to the total income, without allowing

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

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

reassessment proceedings. 4.3 In the absence of any explanation or documentary evidence, the AO proceeded to complete the assessments ex parte under section 147 r.w.s. 144 read with section 144B of the Act, treating the cash deposits appearing in the information report as unexplained money under section 69A. The entire deposits were added to the total income, without allowing

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

AMBE TRADECORP PVT. LTD.,AHMEDABAD vs. THE PR. CIT (CENTRAL), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.53/Ahd/2021 िनधा"रण वष"/Asstt. Year: 2010-2011 Ambe Tradecorp Private Limited, The P.C.I.T.(Central) Iscon House, Vs. Ahmedabad. B/H. Rembrandt Building, C.G. Road, Ahmedabad.

reassessment proceedings were framed under section 143(3) read with section 147 of the Act vide order dated 13th December 2017 after making any addition of Rs. 39,05,50,000/- to the total income of the assessee. It is necessary to clarify at this juncture that there was a mismatch in the amount recorded in the reasons for reopening

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result, appeal of the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad)

40,98,79,270/- under normal provisions and book profit u/s. 115JB of Rs. 83,47,52,785/-. 3. Subsequently, notice u/s. 148 was issued after recording reasons on 30.03.2012. The notice was served on the same date. The reasons recorded were also communicated to the assessee. After receipt of reasons, the assessee filed an objection vide letter dated

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

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability

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

40 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. 43. In the case of Varkey Jacoob (supra) when the amendment came with effect from 1-4-1989, the time for assessment or reassessment, as provided under section 147 read with section 149, was over and the liability