THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. STHAPATYA SHILP CONSTRUCTION, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 907/Ahd/2019 With C.O.No.170/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sthapatya Shilp Construction, Central Circle-1(2), Vs. 2, Abhiraj Complex, Ahmedabad. 68-B, Swastic Society, Ahmedabad. Pan: Abffs2922P

153(C) r.w.s. 143(3) were also made in the case of some of the loan parties. Accordingly, the assessee prayed to delete the addition made under section 68

THE DCIT, CENTRAL CIIRCLE-1(2), AHMEDABAD vs. SHRENA S SUTARIA, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 796/Ahd/2019 With C.O.No.172/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Shrena S. Sutaria, Central Circle-1(2), Vs. 8, Amrashagun Bunglows, Ahmedabad. Nr. Hathisingh Park, Satellite, Ahmedabad-380015. Pan: Asqps7606E

153 referred to as the relevant assessment year) : 7.2 From the above, it is transpired that it is necessary for the AO before initiating the proceedings under section 147 of the Act to form reasons to believe for the escapement of income. The words ‘reasons to believe’ contains 2 components. Firstly, the ‘reasons’ which refers to the cause

THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. SARTHAV BUILDERS, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 908/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sarthav Builders, Central Circle-1(2), Vs. B-1, Abhishree Complex, Ahmedabad. Opp. Star Bazar, Satellite, Ahmedabad. Pan: Abffs3812C

153(C) r.w.s. 143(3) were also made in the case of some of the loan parties. Accordingly, the assessee prayed to delete the addition made under section 68

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S.DHARMEN MARBLE & STONE, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 794/Ahd/2019 With C.O.No.171/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Dharmen Marble & Stone, Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aabfd5172B

68,970 also remain unexplained and escaped assessment. Therefore, the AO initiated the proceedings under section 147 of the Act by issuing a notice under section 148 of the Act. With C.O.No.171/Ahd/2019 Asstt. Year 2010-11 5 4.3 However, the assessee before the AO has challenged the initiation of the proceedings under section

DCIT, CENTRAL CIRCLE-(1)(2), AHMEDABAD vs. SHREYASI DHARMEN SUTARIA, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 797/Ahd/2019 With C.O.No.173/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Shreyasi Dharmen Sutaria, Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. 2Nd Address: 8, Amrashagun Bunglows, Nr. Hathisingh Park, Satellite, Ahmedabad-380015. Pan: Awops1881R

153 referred to as the relevant assessment year) : 7.2 From the above, it is transpired that it is necessary for the AO before initiating the proceedings under section 147 of the Act to form reasons to believe for the escapement of income. The words ‘reasons to believe’ contains 2 components. Firstly, the ‘reasons’ which refers to the cause

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

153 referred to as the relevant assessment year) : 8.2 From the above, it is transpired that it is necessary for the AO before initiating the proceedings under section 147 of the Act to form reasons to believe for the escapement of income. The words ‘reasons to believe’ contains 2 components. Firstly, the ‘reasons’ which refers to the cause

THE ITO, WARD-2(1)(4),, AHMEDABAD vs. M/S. M.G.F. GROWTH RESEARCH AND INVESTMENT LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

68 of the Income Tax Act, 1961. In the CO the assessee has taken up jurisdictional issue whereby it has pleaded that the assessment order is time ITA No.2311/Ahd/2016 with CO barred and the ld.CIT(A) has erred in not quashing the assessment order being time barred. 3. Brief facts of the case are that the assessee has filed

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

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 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

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

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 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

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 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

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

68 to 69D of the Act. As such, it is the onus of the revenue to bring out the necessary evidence to hold that the assessee has made investments in the impugned land which is unexplained under the provisions of section 69B of the Act. Likewise, the contents of the email having attachments of page 157 and 158 were

SHRI PRAVINCHANDRA R PATEL,VADODARA vs. DCIT, CENTRAL CIRCLE-2, VADODARA

68 to 69D of the Act. As such, it is the onus of the revenue to bring out the necessary evidence to hold that the assessee has made investments in the impugned land which is unexplained under the provisions of section 69B of the Act. Likewise, the contents of the email having attachments of page 157 and 158 were

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

68 to 69D of the Act. As such, it is the onus of the revenue to bring out the necessary evidence to hold that the assessee has made investments in the impugned land which is unexplained under the provisions of section 69B of the Act. Likewise, the contents of the email having attachments of page 157 and 158 were