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\nallowed

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\n148 as invalid as AO ought to have issued notice u/s 153C of the Act as\nproceedings have been initiated based upon documents

GHANSHYAMBHAI AMBALAL PATEL,KHEDA vs. THE PCIT-1, AHMEDABAD

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

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

unexplained money u/s. 69A in the hands of the assessee and under the head income from sources and charged the same at a special rate u/s. 115BBE of the Act. After giving final notice u/s. 142(1) dated 12-03-2022, the Assessing Officer has accepted the return of income filed by the assessee. The Pr. CIT observed that

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

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

THE ITO, WARD-4(1)(3), AHMEDABAD vs. SHRI VIGHNAHARTA REALITY PVT. LTD., AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

147 of the Act by issuing notices under section 148 of the Act, alleging that the assessees had received unaccounted cash through accommodation entries. In response to the reassessment notices, the assessees reiterated their originally declared income and denied any involvement in unaccounted cash transactions. The AO, relying on the seized material, made additions under section

SHIVGANGA PROPERTY HOLDERS PVT. LTD,AHMEDABAD vs. ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

147 of the Act by issuing notices under section 148 of the Act, alleging that the assessees had received unaccounted cash through accommodation entries. In response to the reassessment notices, the assessees reiterated their originally declared income and denied any involvement in unaccounted cash transactions. The AO, relying on the seized material, made additions under section

ITO, WARD-4(1)(3), AHMEDABAD vs. SHIVGANGA PROPERTY HOLDERS PVT. LTD, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

147 of the Act by issuing notices under section 148 of the Act, alleging that the assessees had received unaccounted cash through accommodation entries. In response to the reassessment notices, the assessees reiterated their originally declared income and denied any involvement in unaccounted cash transactions. The AO, relying on the seized material, made additions under section

RAMANBHAI JETHABHAI JADAV,AHMEDABAD vs. THE PR. CIT-3, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2016-17

unexplained money. Notice u/s. 263 was issued on 07-03-2025 which was replied by the assessee on 15-03-2024. After taking cognizance of the assessee’s submissions, the Pr. CIT directed the Assessing Officer to pass a fresh assessment order and also directed to apply correct provisions of Act i.e. section 69A and taxed to be chargeable

NIRMAN,AHMEDABAD vs. DCIT, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalnirman, Vs. 35, Vasantkunj Society, New Dcit, Sharda Mandir Road, Paldi, Circle-2(1)(1), Ahmedabad-380007 Ahmedabad [Pan :Aabfn 7155 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Parin Shah, Ar Respondent Represented By: Shri C. Dharani Nath, Sr Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 13.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

reassessment proceedings, the Assessing Officer treated the alleged accommodation entry of Rs. 1,00,00,000/- as unexplained money u/s 69A of the Act and added the same to the income of the assessee. 4. For the sake of ready reference, the reasons recorded for reopening the case are reproduced here asunder:- “BASIS OF FORMING REASON TO BELIEVE AND DETAILS

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

ALDIABLOS INFOTECH PRIVATE LIMITED,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(1), AHMEDABAD

In the result, all the appeals of the assessee are allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 353, 354, 355, 356 & 357/Ahd/2024 िनधा"रण वष" /Assessment Years : 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18

money U/s 69A of I.T. Act, 1961. 2). He has previously erred in law and facts in upholding the ex-party order U/s 144 r.w.s. 147 without considering and appreciating the erroneous contention of the A.O who has alternatively treated the credits in the bank accounts of Rs.5,67,70,140/- as unexplained cash credit U/s

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

money from Africa to London. In view of these facts, these bank accounts with Merrill Lynch Bank and Trust Company (Cayman) Ltd are undisclosed and the deposits made in these Foreign Bank Accounts are unexplained. .' 29 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. 4. Details of deposits

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

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

money from Africa to London. In view of these facts, these bank accounts with Merrill Lynch Bank and Trust Company (Cayman) Ltd are undisclosed and the deposits made in these Foreign Bank Accounts are unexplained. .' 29 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. 4. Details of deposits

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

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

money from Africa to London. In view of these facts, these bank accounts with Merrill Lynch Bank and Trust Company (Cayman) Ltd are undisclosed and the deposits made in these Foreign Bank Accounts are unexplained. .' 29 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. 4. Details of deposits

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

money from Africa to London. In view of these facts, these bank accounts with Merrill Lynch Bank and Trust Company (Cayman) Ltd are undisclosed and the deposits made in these Foreign Bank Accounts are unexplained. .' 29 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. 4. Details of deposits

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

money from Africa to London. In view of these facts, these bank accounts with Merrill Lynch Bank and Trust Company (Cayman) Ltd are undisclosed and the deposits made in these Foreign Bank Accounts are unexplained. .' 29 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. 4. Details of deposits