ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

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

1) of the Act. But M/s Master Developers has filed the returns of income in response to the notice issued under section 148 of the Act, declaring the income which has been elaborated in the preceding paragraph. Indeed, the returns were filed by the M/s Master Developers subsequent to the assessment order dated 30-03-2015 declaring the income

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

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

1) of the Act. But M/s Master Developers has filed the returns of income in response to the notice issued under section 148 of the Act, declaring the income which has been elaborated in the preceding paragraph. Indeed, the returns were filed by the M/s Master Developers subsequent to the assessment order dated 30-03-2015 declaring the income

RANDHEJA DUDH UTPADAK SAHAKARI MANDLI LTD.,GANDHINAGAR vs. THE ITO, WARD-3 NOW WARD-1, GANDHINAGAR

The appeal of the assessee is allowed

Bench: Smt.Annapurna Guptaasstt. Year : 2017-18 Randheja Dudh Utpadak The Ito, Ward-3 Sahakari Mandli Ltd. Vs Now Ward-1 To-Randheja Gandhinagar. Tal: Gandhinagar Pin : 382 620 Pan : Aacar 5164 K (Applicant) (Responent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri Ketan Gajjar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/04/2024 घोषणा क" तारीख /Date Of Pronouncement: 27/06/2024 आदेश/O R D E R आदेश आदेश आदेश The Present Appeal Has Been Filed By The Assessee Against Order Passed By The Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre, Delhi [In Short Referred To As Ld.Cit(A)] Under Section 250 Of The Income Tax Act, 1961 Dated 22.11.2021 Pertaining To Asst.Year 2017-18. 2. The Registry Has Notified That The Appeal Of The Assessee Is Barred By Limitation By 581 Days. In Order To Explain The Reasons For The Impugned Delay, The Ld.Counsel For The Assessee Submitted That The Cit(A)/Nfac Order Was Passed Against The Assessee On 22.11.2021. However, Due To Covid-19 Pandemic Limitation For Filing Appeal Before The Court Of Law Was Extended Till February, 2022. Therefore, After Expiry Of The Limitation For Filing Of The Appeal On Feb., 2022, The Assessee Was Required To File Appeal Within 60 Days Of The Same I.E. By April, 2022. But The Assessee Could File The Appeal On

68 taxmann.com 298 (Ker), wherein he pointed out that the Hon’ble Court held that the claims for deduction made in the return filed beyond the period stipulated under section 139(1) or 139(4) and made in returns filed u/s 142(1) or even u/s 148

WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

1 24.05.2022 SCA NO Due date of Date of reply:- Date of order Last date for issuance of notice filing reply under section under section 148 as per 148A(d) and surviving time:- notice under section 148:- 6387/2023 09.06.2022 04.06.2022 29.07.2022 22.06.2022 5688/2023 06.06.2022 - 27.07.2022 27.06.2022 22260/2022 07.06.2022 06.07.2022 30.07.2022 14.06.2022 996/2023

WAVES TRADELINE PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

The appeals of the assessee are allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

1 24.05.2022 SCA NO Due date of Date of reply:- Date of order Last date for issuance of notice filing reply under section under section 148 as per 148A(d) and surviving time:- notice under section 148:- 6387/2023 09.06.2022 04.06.2022 29.07.2022 22.06.2022 5688/2023 06.06.2022 - 27.07.2022 27.06.2022 22260/2022 07.06.2022 06.07.2022 30.07.2022 14.06.2022 996/2023

ITO, WARD-2(2)(2), AHMEDABAD vs. JASMIN JAYENDRABHAI THAKKAR, AHMEDABAD

In the result, we answer the question in the affirmative i

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

1) of Section 151 of the Income-tax Act would indicate that if an Assessing Officer wants to issue notice under Section 148 of the Act and four years have expired from the end of the relevant assessment year, then he cannot issue such notice unless an approval from the Principal Chief Commissioner or Chief Commissioner or Principal

ITO, WARD-2(2)(2), AHMEDABAD vs. JASMIN JAYENDRABHAI THAKKAR, AHMEDABAD

In the result, we answer the question in the affirmative i

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

1) of Section 151 of the Income-tax Act would indicate that if an Assessing Officer wants to issue notice under Section 148 of the Act and four years have expired from the end of the relevant assessment year, then he cannot issue such notice unless an approval from the Principal Chief Commissioner or Chief Commissioner or Principal

SHRI ANILBHAI HIRALAL SHAH,AHMEDABAD vs. DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD

In the result the appeal filed by the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

68,08,860/- of net receipt of margin money on the basis of remand report by AO without issuing show cause notice of enhancement. 20 Levy of interest u/s 234A, 234B, & 234C is not justified. 21 Initiation of penalty u/s 271(1)(c) of the Act is not justified. The appellant craves leave to add, amend, alter, edit, delete, modify

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. DHARMENBHAI MAHENDRABHAI SUTARIA -HUF, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 795/Ahd/2019 With C.O.No.169/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Dharmenbhai M. Sutaria, Huf Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aafhd1653K

68 of the Act of Rs. 1,69,20,000/-. With C.O.No.169/Ahd/2019 Asstt. Year 2010-11 3 4. Your Respondent craves right to add, amend, alter, modify, substitute, delete or modify all or any of the above grounds of cross objection. 3. The assessee in the CO has challenged the virus of the notice issued under section 148

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68

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

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

148 of the Act for proceedings u/s. 147 r.w. Explanation 2(d) of the Act. 1.04 On the facts and in circumstances of your appellant's case and in law, ld. CIT(A) erred in upholding that credit entries in alleged foreign bank statements is liable to be treated as deemed income as per section 68