MR. PRANJAL PATEL,,AHMEDABAD vs. THE PR. CIT-2,, AHMEDABAD

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

68. 8. In Para- 9 of your notice, Your honour have mentioned that no copy of agreement was furnished for booking of plots and therefore why the claim of expenses of Rs.36,75,000/-should not be disallowed. In this respect I have to submit that in real estate transaction while booking the plot, no agreement is required

JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

u/s 263 as well as consequential orders passed subsequent to revision proceeding are Null and VOID and deserves to be quashed and set aside. The same please be held accordingly. 5. The order passed by the learned CIT (Appeals) is bad in law and contrary to the provisions of law and facts. It is submitted that the same be held

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

68,97,83 Income /- - 0/- ITA No.1157 to 1160/Ahd/2025 6 (s.153C return) Date of AO’s 29.09.2022 29.09.2022 29.09.2022 29.09.2022 Order u/s. 143(3)/153C Date of PCIT’s 31.03.2025 31.03.2025 31.03.2025 31.03.2025 263 Order 3. Aggrieved by the orders of the PCIT, the assessee is in appeals before us raising following assessment year-wise grounds of appeal: In ITA/No.1157/Ahd/2025

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

68,97,83 Income /- - 0/- ITA No.1157 to 1160/Ahd/2025 6 (s.153C return) Date of AO’s 29.09.2022 29.09.2022 29.09.2022 29.09.2022 Order u/s. 143(3)/153C Date of PCIT’s 31.03.2025 31.03.2025 31.03.2025 31.03.2025 263 Order 3. Aggrieved by the orders of the PCIT, the assessee is in appeals before us raising following assessment year-wise grounds of appeal: In ITA/No.1157/Ahd/2025

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.

68 of the Act were not complied with by the assessee. Accordingly, the ld. PCIT issued a notice under section 263 of the Act dated 3rd March 2020 proposing the order of the AO as erroneous and prejudicial to the interest of Revenue which was subsequently affirmed vide order dated 31-3-2021 for the reasons which have been elaborately

M/S. GREENSTONE AGRO PRODUCT & INFASTRUCTURE (P) LTD.,AHMEDABAD vs. THE P. CIT (CENTRAL), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 134 To 139/Ahd/2021 िनधा"रण वष"/Asstt. Year: 2009-10 To 2014-15 M/S. Greenstone Agro Product & P.C.I.T.(Central), Infrastructure(P) Ltd., Vs. Ahmedabad. D-2, New Garden Flat, Near Sbi, Navrangpura, Ahmedabad-380006. Pan: Aaccg2751P

u/s 143(3) r.w.s. 153C of the Act, vide order dated 28/12/2017 by accepting the income declared by the assessee in the return of income. 4.1 However, the Ld. Pr. CIT on perusal of the case records found that the assessee was engaged in providing accommodation entries to various associated concerns. The AO during the assessment proceedings vide notice dated

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

u/s 263 of the Act. 10. We have heard the rival contentions and perused the material on record. 10.1. The short issue for our consideration is whether the learned Principal Commissioner was justified in assuming revisionary jurisdiction under section 263 of the Act on the ground that the Assessing Officer ought to have invoked section 69C read with section 115BBE

VINEETSINGH GULABSINGH RORE,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

section 263 to us, appears to be a plausible explanation, and there is no doubt that in the consequent assessment, the assessee was assessed multiple times to its returned income, which forced him into action and he came to the consult another legal adviser on whose advise the present appeal was filed before us. The delay in filing of appeal

OLYMPIC DECOR LLP,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, the Appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2018-19 Olympic Décor Llp Pr.Commissioner Of 6, Patel Avenue, Nr.Gurudwara Vs Income Tax-3 Sg Highway, Bodakdev Ambawadi Ahmedabad. Ahmedabad. Pan : Adafs 2113 H (Applicant) (Responent) : Assessee By Shri Tushar Hemani, Sr.Advocate & Parimalsinh B. Parmar, Ars : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 23/05/2025 आदेश आदेश/O R D E R आदेश आदेश

u/s. 68 r.w.s. 115BBE of the Act. 8. The Ld. PCIT has further erred in law and on facts in not appreciating that the view taken by the AO during the assessment proceedings is a possible view and hence the revisionary proceedings are illegal and bad in law. 9. The Id. PCIT has further erred in law in not coming

MADRESA MOHAMMADIYAN AND PANJATANIYA,DAHOD GUJARAT vs. CIT(E), AHMEDABAD, AHMEDABAD

In the result the appeal filed by the assessee is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Madressa Mohammadiyn & Cit(Exemption) Panjataniya, Madresa Raildings Nehru Bridge B/H. Tower Talav Road, Dahod. Ahmedabad. Pan : Brdmo 8620 D (Applicant) (Responent) : Shri Ankit Chokshi, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 26/09/2025 आदेश आदेश/O R D E R आदेश आदेश

68,533/- for non-production of bills. The assessee, in reply dated 15.03.2023 and 20.03.2023, stated that it runs educational institutions, that accounts are audited under the Bombay Public Trusts Act, that bank reconciliations explain credits including corpus donations, opening cheque clearances and reimbursements, and that exemption under section 10(23C)(iiiad) is available since receipts of each educational institution

SHAH JITENDRAKUMAR MAFATLAL HUF,ELLISBRIDGE, AHMEDABAD vs. PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

revision under section 263 of the Act as held by Hon'ble ITAT Ahmedabad in case of Jignesh Shah vs Pr. CIT (ITA No 149/Ahd/2021). On this count also, the order u/s 263 of the Act is illegal and unjust and be set aside in the interest of justice. 6. Without prejudice to the above

M/S.HDB FINANCIAL SERVICES LTD.,,AHMEDABAD vs. THE PR. CIT-1 , AHMEDABAD

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

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

u/s. 143(2) dated 21.11.2019 filed by the assessee already reproduced in Paragraph 6 of this order. Thus both the ingredients i.e order must be erroneous in nature; and the error must be such that it is prejudicial to the interest of Revenue are present in a given case, it is not legally permissible for a Commissioner to initiate

VISHAL BALVANTRAI AGARWAL,AHMEDABAD vs. THE PR. COMMISSIONER OF INCOME TAX, AHMEDABAD -1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.226/Ahd/2023 िनधा"रण वष" /Assessment Year : 2018-19 Vishal Balvantrai Agarwal The Pr.Cit बनाम/ 249 New Cloth Market Ahmedabad-1 V/S. O/S. Raipur Gate Ahmedabad – 380 002 (Gujarat) "थायी लेखा सं./Pan: Adbpa 4462 G (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Divyakant Parikh, Ar Revenue By : Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am:

u/s. 263 of the Act is not limited to reasons for which the limited scrutiny was made, and he can go beyond the scope of the limited scrutiny. The DR placed reliance on the judgement of High Court of Kerala in case of Sahyadri Agencies Ltd. Vs. Vishal Balvantrai Agarwal vs. The Pr.CIT Asst. Year : 2018-19 PCIT reported

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. PINAC STOCK BROKERS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Dr.Brr Kumar & Shri T.R Senthil Kumar

68 of the Act Hence, the ground of appeal of the assessee is hereby portly allowed." (iii) The appellant against the addition of Rs 52,00,000/-confirmed by the Hon'bie ITAT, as discussed in para 5.1 (iii) above, a Miscellaneous Application was filed by the assessee claiming that the Hon'ble ITAT has inadvertently overlooked documents in respect

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

68,97,83\n/-\n0/-\n(s.153C\nreturn)\nDate of AO'S\nOrder u/s.\n143(3)/153C\n29.09.2022\n29.09.2022\n29.09.2022\n29.09.2022\nDate of PCIT'S\n263 Order\n31.03.2025\n31.03.2025\n31.03.2025\n31.03.2025\n3. Aggrieved by the orders of the PCIT, the assessee is in appeals\nbefore us raising following assessment year-wise grounds of appeal:\nIn ITA/No.1157/Ahd/2025

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

68,97,83\n/-\n0/-\n(s.153C\nreturn)\nDate of AO'S\nOrder u/s.\n29.09.2022\n29.09.2022\n29.09.2022\n29.09.2022\n143(3)/153C\nDate of PCIT'S\n263 Order\n31.03.2025\n31.03.2025\n31.03.2025\n31.03.2025\n3.\nAggrieved by the orders of the PCIT, the assessee is in appeals\nbefore us raising following assessment year-wise grounds of appeal:\nIn ITA/No.1157/Ahd/2025

SHRI RAJENDRA J KESHWANI (HUF),AHMEDABAD vs. THE PR. CIT- CENTRAL, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.118/Ahd/2021 िनधा"रण वष" /Assessment Year : 2015-16 Shri Rajendra J. Keshwani The Pr.Cit बनाम/ (Huf) Central Circle V/S. 44, Asopalav Bungalows Ahmedabad Nr.Mukthidham Jain Temple Thaltej – 380 054 (Gujarat) "थायी लेखा सं./Pan: Aaehk 1973 J अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) ….. Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 12/02/2025 घोषणा की तारीख /Date Of Pronouncement: 18/02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

u/s. 143(3) of the Act. The AR argued that the assessment order dated 20-11-2017 had merged with the CIT(A)’s order dated 22-01-2021, and since the addition itself had been deleted, there was no surviving basis for revision under Shri Rajendra J. Keshwani (HUF) Asst. Year : 2015-16 Section 263

SHRI HIRALAL D. THAKKAR,AHMEDABAD vs. THE PR. CIT (CENTRAL), , AHMEDABAD

Bench: S/Shri Pramod M. Jagtap & T.R. Senthil Kumar

U/s 263(b) explanation, the higher officer should have done at the stage of approval before passing the assessment order by AO, what he proposed to do U/s.263 of the Income Tax Act 2. The assessment order passed by the assessing officer is not erroneous and not prejudicial to the interest of the revenue. The inquirer conducted