PATEL AMBALAL LAXMANDAS NI CO.,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(3), AHMEDABAD

In the result, all the appeals filed by the Assessee are hereby dismissed

133A of the Act was conducted at the business premises of the assessee firm on 02/11/2015. During the survey proceedings, several documents, note books/loose papers files/ booking receipt books etc. were found and impounded as per Annexure A-1 to A-32. In view of the survey and incriminating materials found, the case of the assessee firm were reopened u/s

OVEZ ARIFBHAI LAKHANI,BHAVNAGAR vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Income Tax Appellate Tribunal, Ahmedabad Benches, Has Arisen From The Revisionary Order Dated 12.03.2024 Passed By Ld. Principal

survey u/s 133A, and the same is placed in paper book /page nos. 28 to 42. Our attention was drawn to the page no. 27/PB where there is a report of I.T.A No. 590/Ahd/2024 A.Y. 2014-15 Page No. 9 Ovez Arifbhai Lakhani v. Pr. CIT DDIT Investigation Unit 4(3) Mumbai, wherein it is stated there was various

SUN PHARMACEUTICALS INDUSTRIES LTD.,,BARODA vs. THE ACIT, CENTRAL CIRCLE-1, BARODA

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. आयकर अपील सं./Ita No.1659/Ahd/2015 2. आयकर अपील सं./Ita No.1689/Ahd/2015 ("नधा"रण वष"/Assessment Year : 2008-09 ) बनाम/ 1. Sun Pharmaceuticals 1. The Acit Industries Ltd. Cen.Cir-1 Vs. “Sparc” Tandalja Baroda – 20 2. The Acit 2. Sun Pharmaceu- Central Circle-1 Ticals Industries Baroda Ltd. Baroda. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcs 3124K (अपीलाथ"/Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से/ Appellant By : Shri S.N. Soparkar, Ar ""यथ" क" ओर से/Respondent By: Shri R.C. Panday, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing 28/03/2019 घोषणा क" तार"ख /Date Of Pronouncement 20/06/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Cross-Appeals Have Been Filed At The Instance Of The Assessee & Revenue Against The Order Of The Commissioner Of Income Tax (Appeals)–2, Vadodara [Cit(A) In Short] Vide Appeal No.Cab/(A)- 2/387/2014-15 Dated 31/03/2015 Arising In The Assessment Order Passed Under S.143(3) R.W.S.147 Of The Income Tax Act, 1961(Hereinafter Referred To As "The Act") Dated 14/02/2014 Relevant To Assessment Year (Ay) 2008-09. Ita Nos.1659/Ahd/2015 (By Assessee) & Ita No.1689/Ahd/2015 (By Revenue) Sun Pharmaceuticals Industries Ltd. Vs. Acit Asst.Year - 2008-09 2

147. 5.2 The CIT(A) has grossly erred not adjudicating the action of the Assessing Officer has wrongly considered the date of reassessment order for computation of interest u/s. 234D instead of the date of regular assessment without appreciating that the amount of excess refund has been duly paid by the Appellant on passing of the order under regular

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)

survey u/s 133A of the Act and the assessee had disclosed Rs. 1.75 crore as undisclosed income. The same was reflected in the return of income filed by assessee. 4. It was further noticed that Assessing Officer vide letter no DCIT/Anand/ Valuation/Devraj Devp/2012-13 dated 26/02/2013 asked the District Valuation Officer, Valuation Cell, Income tax Department, Ahmedabad & Vadodara to estimate

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)

survey u/s 133A of the Act and the assessee had disclosed Rs. 1.75 crore as undisclosed income. The same was reflected in the return of income filed by assessee. 4. It was further noticed that Assessing Officer vide letter no DCIT/Anand/ Valuation/Devraj Devp/2012-13 dated 26/02/2013 asked the District Valuation Officer, Valuation Cell, Income tax Department, Ahmedabad & Vadodara to estimate

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)

survey u/s 133A of the Act and the assessee had disclosed Rs. 1.75 crore as undisclosed income. The same was reflected in the return of income filed by assessee. 4. It was further noticed that Assessing Officer vide letter no DCIT/Anand/ Valuation/Devraj Devp/2012-13 dated 26/02/2013 asked the District Valuation Officer, Valuation Cell, Income tax Department, Ahmedabad & Vadodara to estimate

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

reassessment are satisfied, is only relatable to the preceding expression in clauses (a) and (b) viz., 'escaped assessment'. The term 'escaped assessment' includes both 'non- assessment' as well as 'under assessment'. Income is said to have 'escaped assessment' within the meaning of this section when it has not been charged in the hands of an assessee in the relevant year

CRYSTAL QUINONE PVT. LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-1(1)(2), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblecrystal Quinone Pvt. Ltd., Dcit, Vs. Nr. Old Excise Chowky, Circle 1(1)(2), S.M. Road, Ambawadi, Ahmedabad Ahmedabad-380015 [Pan : Aabcc 1413 H] (Appellant) .. (Respondent) Appellant Represented By : Shri Bandish Soparkar, Ar Respondent Represented By: Shri Abhijit, Sr Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 07.04.2026

133A of the Act was earned out in the case of M/s Reynolds Petro Chems Ltd. on 16/04/2015 and statement of one of the director(s) of the M/s Reynolds Petro Chems Ltd., Shri Sanjay Parasmal Jain was recorded u/s 131 of the Act, Shri Sanjay Parasmal Jain, deposed that M/s Reynolds Petro Chems Ltd. is not genuine

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

147 r.w.s. 143(3), the assessment as well proceedings are illegal. 3. Learned CIT(A) has erred in confirming that no satisfaction was required to be recorded by A.O. of Searched Party, since the present assessment is re-open assessment. In as much as, the assessment is based on incriminating material found during Search whereby A.O. was required to record

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

147 r.w.s. 143(3), the assessment as well proceedings are illegal. 3. Learned CIT(A) has erred in confirming that no satisfaction was required to be recorded by A.O. of Searched Party, since the present assessment is re-open assessment. In as much as, the assessment is based on incriminating material found during Search whereby A.O. was required to record

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

147 r.w.s. 143(3), the assessment as well proceedings are illegal. 3. Learned CIT(A) has erred in confirming that no satisfaction was required to be recorded by A.O. of Searched Party, since the present assessment is re-open assessment. In as much as, the assessment is based on incriminating material found during Search whereby A.O. was required to record

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

147 r.w.s. 143(3), the assessment as well proceedings are illegal. 3. Learned CIT(A) has erred in confirming that no satisfaction was required to be recorded by A.O. of Searched Party, since the present assessment is re-open assessment. In as much as, the assessment is based on incriminating material found during Search whereby A.O. was required to record

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

147 r.w.s. 143(3), the assessment as well proceedings are illegal. 3. Learned CIT(A) has erred in confirming that no satisfaction was required to be recorded by A.O. of Searched Party, since the present assessment is re-open assessment. In as much as, the assessment is based on incriminating material found during Search whereby A.O. was required to record

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. APPLITECH SOLUTION LTD.,, AHMEDABAD

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

reassessment orders u/s 143(3) r.w.s 147 on 23.03.2005 and he made major disallowance on account of depreciation and interest solely relying upon the order for A. Y. 2000-01 . (4) Being aggrieved and dissatisfied, the assessee preferred appeals before CIT(A) for A.Ys 1997-98 and 1998-99 and also A.Ys

DCIT, CENTRAL CIRCLE-1, VADODARA vs. M/S. MONAREECA ENTERPRISE, VADODARA

In the result, the appeal filed by the Revenue is dismissed and consequently, the Cross Objection filed by the assessee is also dismissed

Bench: S/Shri Waseem Ahmed & T.R. Senthil Kumarwith Cross Objection No.67/Ahd/2020 Assessment Year : 2013-14 Dcit, Cent.Cir.1 M/S.Monareeca Enterprise Baroda. Vs “Monalisa Lakewood” B/H. Vibgyor School Atladra Padra Road Baroda Pan : Aatfm 2714 L अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Milin Mehta, Ar Revenue By : Shri Vijaykuamr Jaiswal, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 16/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 16/03/2022 आदेश/O R D E R

reassessment, the assessee filed an appeal before the ld.CIT(A). 4. The ld.CIT(A) after considering validity of reopening of the assessment, and additions made by the AO passed a detailed order directing the AO to delete the impugned addition made to the total income of the assessee. The operative portion of the impugned order of the ld.CIT

VERTOOL CONSULTANCY LLP,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

reassessment proceedings were triggered on the basis of material alleged to have been seized during the course of search carried out u/s. 132 in the case of Jignesh Shah and Sanjay Shah and therefore, the AO ought to have initiated the proceedings u/s. 153C of the Act. 2. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal

THE DCIT, CENTRAL CIRCLE-3,, BARODA vs. M/S. ULTRA TECH TRANSMISSION,, BARODA

In the result, appeal of the Revenue is partly allowed for assessment year 2016-17

133A of the Act was conducted on 18-6-2015, as a consequence to which it was found that the assessee firm had shown payments to various sub- contractors (" 1,86,97,354/- for assessment year 2009-10). The statement of the sub-contractors were recorded, on the basis of which the AO concluded that the sub- contractors could