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

147 as valid when 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 ITA Nos.424, 425, 426 and 427/Ahd/2024 Arcoy Industries (India

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\nallowed

147 as valid\nwhen reassessment proceedings cannot be conducted on the basis of search\nconducted in case of third party more particularly when no details related to\nappellant are found therein. The Ld CIT(A) ought to have treated notice u/s\nITA Nos.424, 425, 426 and 427/Ahd/2024\nArcoy Industries (India) P. Ltd.\nAYs

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

unexplained sources. The facts as aforestated are derived from para 2-5 of the assessment order for A.Y 1996-97which are reproduced hereunder: 7 11. Since the assessee has challenged the validity of the assessment framed u/s 147 of the Act in all the impugned years before us, pointing out insufficiency in the reasons recorded for reopening the case

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

unexplained sources. The facts as aforestated are derived from para 2-5 of the assessment order for A.Y 1996-97which are reproduced hereunder: 7 11. Since the assessee has challenged the validity of the assessment framed u/s 147 of the Act in all the impugned years before us, pointing out insufficiency in the reasons recorded for reopening the case

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.

reassess the total income of six preceding assessment years, even if the earlier assessments had been completed under section 143(1) or 143(3). However, that decision was premised on the fact that incriminating material (loan documents and supporting GPAs) was actually recovered during the search of the assessee himself, which linked the assessee directly to undisclosed transactions. Likewise

VINOD NARAYAN JOSHI,VADODARA vs. THE PR. CIT,-1, VADODARA

Bench: Shri Tr Senthil Kumar & Shri Makarand V. Mahadeokarआयकरअपीलसं./Ita No. 230 /Ahd/2021 धििाधरणवरध/Asstt. Year: 2011-2012 & आयकरअपीलसं./Ita No. 44/Ahd/2022 धििाधरणवरध/Asstt. Year: 2012-13 Vinod Narayan Joshi, The Principal Af-6, Utopian Corner, Commissioner Of बिाम Nr. Green Wood Bunglows, Income Tax, Vs. New Alkapuri, Vadodara-1, Vadodara-390021. Vadodara.

unexplained credit entries of Rs. 50,000/-, and unsecured loans claimed by the ITA No.230 /Ahd/2021 & Ninod Narayan Joshi vs. PCIT Asst. Years 2011-12 2012-13 4 assessee. Despite these discrepancies, the AO accepted the returned income without making any additions, which the PCIT considered a lapse. For A.Y. 2012-13, the PCIT set aside the reassessment order

VINOD NARAYAN JOSHI,VADODARA vs. THE PR. CIT,-1, VADODARA

Bench: Shri Tr Senthil Kumar & Shri Makarand V. Mahadeokarआयकरअपीलसं./Ita No. 230 /Ahd/2021 धििाधरणवरध/Asstt. Year: 2011-2012 & आयकरअपीलसं./Ita No. 44/Ahd/2022 धििाधरणवरध/Asstt. Year: 2012-13 Vinod Narayan Joshi, The Principal Af-6, Utopian Corner, Commissioner Of बिाम Nr. Green Wood Bunglows, Income Tax, Vs. New Alkapuri, Vadodara-1, Vadodara-390021. Vadodara.

unexplained credit entries of Rs. 50,000/-, and unsecured loans claimed by the ITA No.230 /Ahd/2021 & Ninod Narayan Joshi vs. PCIT Asst. Years 2011-12 2012-13 4 assessee. Despite these discrepancies, the AO accepted the returned income without making any additions, which the PCIT considered a lapse. For A.Y. 2012-13, the PCIT set aside the reassessment order

LALITABEN DIPAKBHAI MODH,SURAT vs. PCIT-3, AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

147 of the Act. Therefore a notice u/s. 148 dated 31-03- 2021 was issued to the assessee. 3. In response, the assessee filed her Return of Income on 28-04- 2021 declaring total income of Rs.99,520/-. The Assessing Officer levied penalty u/s. 271F for not filing the return will within the time limit prescribed u/s

M/S. HARSIDDH QUARRY WORKS,ARAVALLI vs. THE PR. CIT-1, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकरअपीलसं./Ita No.103/Ahd/2022 धििाधरणवरध/Asstt. Year: 2014-2015 M/S. Harsiddh Quarry Works, Principal Commissioner Of At Alva (Vatrak), Vs. Income Tax, Taluka Bayad, Ahmedabad. District Aravalli, Alva(Vaarak)-383325. Pan: Aaifh0303H

investment in the impugned property before the AO in the proceedings u/s 147 of the Act, therefore the Ld. PCIT cannot extend the A.Y. 2014-15 3 scope of assessment u/s 263 of the Act, by making the addition of those items which were not subject matter of re-assessment proceedings u/s 147 of the Act. 6. On the other

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara

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

Investments Ltd" through a trust, whose settler were Shri Bipinchandra Patel and Mrs. Manjula Patel and ultimate beneficiaries were his own family members. 2. In the meantime, a search u/s 132 of the I T Act was carried out at the residence of Shri Bipinchadra Patel and Mrs. Manjulaben Patel at 2, Shantivan Society, Sussen-Tarsali Road, Vadodara