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

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

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

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

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

151 wherein it was held as under. "Section 68 of the Income-tax Act, 1961 Cash credit (Loans) -Assessing Officer treated a part of loan taken by assessee, taken from agriculturists, as non- genuine and made addition under section 68 However, assessee produced copy of 7/12 extract from land register maintained by land revenue, loan confirmation letter, copy

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

DCIT, CENTRAL CIRCLE -1(1),, AHMEDABAD vs. SHRI DEEPAK KUMAR VASWANI,, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

SHRI RAJESH SUNDERDAS VASWANI,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. SHRI RAJESH SUNDERDAS VASWANI, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

SHRI ASHOK SUNDERDAS VASWANI,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

THE DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. SHRI ASHOK SUNDERDAS VASWANI, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

SHRI DEEPAK BUDHARMAL VASWANI,,AHMEDABAD vs. DCIT, CENTRAL CIRCLE -1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

68, 71 to 79 of the assessment order. He pointed out that there were certain messages recovered by the Revenue, and these messages were on the direction of Director i.e. Shri Dilipkumar Lalwani. According to him, these are not dumb documents. In support of his contentions, he relied upon the order of the ITAT, Ahmedabad Bench in the case

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read

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

151 by Finance Act with entire new set of provision having different conditions and procedures on which existence of subsidiary legislation TLA Act depends itself and ceased to exist, provision contained in TLA cannot have any effect after enactment of Finance Act, 2021. This decision was given after considering the specific mention of Proviso to section 149 which read