M/S. 9TH STREET ARCHITECTS,AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(1), AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

68 or 69A cannot be invoked. Finally, the assessee argued that the rectification proceedings were void ab initio and without jurisdiction since the conditions precedent for invoking section 154

SHRI SANDIP BHARATBHAI VADODARIYA,BHAVANAGAR vs. THE DCIT CIRCLE-2, BHAVNAGAR

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

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 1144/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2011-2012 Shri Sandip Bharatbhai Vadodariya, D.C.I.T., Jawaharnagar, Paliyad Road, Vs. Circle-2, Botad, Bhavnagar. Bhavnagar.

68, section 69, section 69A, section 69B, section 69C or section 69D, at the rate of 30% (plus surcharge and cess as applicable). It is also proposed to provide that no deduction in respect of any expenditure or allowance shall be allowed to the assessee under any provision of the Act in computing deemed income

ITO WARD-4(1)(4),, AHMEDABAD vs. VALLEY COMTRADE PVT LTD ( EARLIER KNOWN AS JHAWAR COMTRADE PVT. LTD.,), AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 2034/Ahd/2017 िनधा"रण वष"/Asstt. Year:2012-2013 I.T.O, M/S. Valley Comtrade Pvt. Ltd., Ward-4(1)(4), Vs. (Earlier Known As Jhawar Comtrade Ahmedabad. Pvt. Ltd.,) C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N & आयकर अपील सं./Ita No. 68/Srt/2017 िनधा"रण वष"/Asstt. Year:2012-2013 M/S. Valley Comtrade Pvt. Ltd., I.T.O, (Earlier Known As Jhawar Comtrade Vs. Ward-1(1)(3), Pvt. Ltd.,) Surat. C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N

section 68 of the Act which has been elaborated in the preceding paragraphs. 14.9 In our humble understanding, we also note that the decision in the case of NRA Iron & Steel (P.) Ltd. (supra) is based on facts. Thus such case will become binding on those cases having similar facts and circumstances and not other cases having different facts

SMT. PARAMADEVI TEKRIWAL, ,BHAVNAGAR vs. THE ITO, WARD-1(5),, BHAVNAGAR

In the result, the appeal of the assessee is dismissed

Bench: Shri P.M. Jagtap, Vice- & Ms. Madhumita Royassessment Year : 2013-14 Smt. Paramadevi Tekriwal, The Income-Tax Officer, D-143, Kaliyabid, Bhavnagar Vs Ward 1(5), Pan : Addpt 3030 F Bhavnagar अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : None Revenue By : Shri Rakesh Jha, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 17/10/2022 घोषणा क" तार"ख /Date Of Pronouncement: 17/10/2022 आदेश/O R D E R Per P.M. Jagtap, Vice-: This Appeal Filed By The Assessee Is Directed Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)-6, Ahmedabad (“Cit(A)” In Short) Dated 09.07.2018. 2. The Relevant Facts Of The Case Giving Rise To This Appeal Are That The Assessee Is An Individual Who Filed Her Return Of Income For The Year Under Consideration Originally On 16.03.2014. Although The Said Return Was Originally Accepted Under Section 143(1) Of The Income-Tax Act, 1961 (“The Act” In Short), The Assessment Was Subsequently Reopened By The Assessing Officer On The Basis Of Information Received From Investigation Wing Of The Income-Tax Department That The Long Term Capital Gains Of Rs.1,13,53,982/- Arising From The Sale Of Equity Shares Of Kgn Enterprise Ltd. For A Consideration Of Rs.1,13,87,902/- Claimed As Exempt In The Return Of Income Was Bogus & It Was Actually An Accommodation Entry. The Assessing Officer Accordingly Issued A Notice Under Section 148 Of The Act To Smt. Paramadevi Tekriwal Vs. Ito Ay : 2013-14 2

Section 68 of the Act, where any sum is found credited in the books of the assessee for any previous year the same may be charged to income tax as the income of the assessee of that previous year if the explanation offered by the assessee about the nature and source thereof is, in the opinion of the Assessing

THE DCIT, CIRCLE-8,, AHMEDABAD vs. SHIVAM WATER TREATERS PVT. LTD.,, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

68,655/- with respect to these cars namely Audi-A4 and BMW and added to the total income of the assessee. 14. Aggrieved assessee preferred appeal to the learned CIT-A. The assessee before the learned CIT-A has filed the duplicate copies of the invoices for the purchase of 5 cars but the assessee has not filed

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-4(1)(1),, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

68,655/- with respect to these cars namely Audi-A4 and BMW and added to the total income of the assessee. 14. Aggrieved assessee preferred appeal to the learned CIT-A. The assessee before the learned CIT-A has filed the duplicate copies of the invoices for the purchase of 5 cars but the assessee has not filed

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE ACIT, (OSD), CIRCLE-8,, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

68,655/- with respect to these cars namely Audi-A4 and BMW and added to the total income of the assessee. 14. Aggrieved assessee preferred appeal to the learned CIT-A. The assessee before the learned CIT-A has filed the duplicate copies of the invoices for the purchase of 5 cars but the assessee has not filed

SHIVAM WATER TREATERS PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-8, AHMEDABAD

In the result appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

68,655/- with respect to these cars namely Audi-A4 and BMW and added to the total income of the assessee. 14. Aggrieved assessee preferred appeal to the learned CIT-A. The assessee before the learned CIT-A has filed the duplicate copies of the invoices for the purchase of 5 cars but the assessee has not filed

TALENT ANYWHERE SERVICES PVT. LTD. ( SUCCESSOR TO QSG RESOURCE MANAGEMENT INDIA PVT. LTD. ),VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2),, BARODA

In the result, the appeal is dismissed

154 are nothing but an extension of the assessment proceedings, and what holds good for the assessment proceedings must hold good in this context as well. He submits that even in, what he terms as, second round of proceedings before the Assessing Officer, the draft order was required to be issued. He takes us through a large number of judicial

THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD vs. M/S. ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS M/S. CADILA HEALTHCARE LTD.), AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: DR. BRR KUMAR (Vice President), SHRI SIDDHATHA NAUTIYAL (Judicial Member)

68,15,907/- under normal provisions and determining book profit of Rs 160,04,09,477/- u/s. 115JB. 2. On perusal of records, it is noticed that rectification order passed in the case of assessee company on 05/07/2017 wherein credit of DDT of Rs.9,53,58,500/- paid by the assessee was allowed against DDT demand payable

SAKARIYA METAL ROLLING MILLS,AHMEDABAD vs. ITO, WARD-3(3)(10), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 34/Ahd/2019 िनधा"रण वष"/Asstt. Year:2015-2016 Sakariya Metal Rolling Mills, I.T.O., 257, Gujrat Vapraj Mahamandal, Vs. Ward-3(3)(10), Vasahat, S.P. Ring Road, Ahmedabad. Odhav, Ahmedabad-382415. Pan: Aadfs3443A

68 of the Act cannot be applied on the amount of cash deficit as discussed above. It is for the reason that, A.Y. 2015-16 12 the same does not represent the unexplained cash credit entry. Accordingly, we are of the view that the addition made by the AO which was subsequently confirmed by the learned

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

154 taxmann.com 615 (Rajkot–Trib.), the Tribunal examined the scope of revision under section 263 in the context of differential treatment of additions under sections 68

HARISHCHANDRA NATVARLAL PATEL -HUF,AHMEDABAD vs. THE DCIT ,CIRCLE-3(2), AHMEDABAD

In the result the appeal of the assessee is allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 637/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2013-14 Harishchandra Natavarlal Patel-Huf, D.C.I.T., Revolution Cinema, Vs. Circle-3(2), Nr. Ctm Char Rasta, Ahmedabad. Ahmedabad.

154 of the Income Tax Act by the learned CIT(A) - 3, Ahmedabad, your appellant submits following grounds of appeal amongst others for your kind justice. 1. The learned CIT(A) has grossly and grievously, erred in law and on facts by rejecting rectification and disallowing a sum of interest of Rs.5,40,375/-on secured term loans from bank

ARVINDKUMAR AMULKH TANNA,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2 (3), AHMEADABAD

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

section 143(3) / 143(3) r.w.s. 153A(1)(b) of the Income Tax Act, 1961 (hereinafter referred to as "the Act") and the Assessee is in Cross Objections for AYs 2009-10 to 2014-15. 2. At the outset, ld.AR submitted that though these appeals belong to different assessment years but the issues are identical except for the assessment

ADANI AGRO PVT. LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, the assessee appeal is thus allowed

Bench: Shri O. P. Meena& Ms. Madhumita Roy

68 Taxman 344/200 ITR 567 (SC) and judgments of this Court in CIT v. Dinesh Jain, HUF [2012] 25 taxmann.com 550/211 Taxman 23/[2013] 352 ITR 629 and CIT v. Gulshan Kumar [2002] 123 Taxman 111/257 ITR 703 (Del). 25. As noted above, Section 52 of the Act was omitted by Finance Act, 1987 with effect from 1st April

AURA SECURITIES PVT. LTD.,AHMEDABAD vs. DY. COMMISSIONER OF INCOME TAX,, AHMEDABAD

In the result the appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.834/Ahd/2012 "नधा"रण वष"/Asstt. Year: 2008-2009 Dcit, Aura Securities Pvt. Ltd. Circle-1, V Akhay Building, B/H, Vadilal Ahmedabad. S. House, 53, Shrimali Society, Navrangpura, Ahmedabad-380009 Pan: Aabct4637N आयकर अपील सं./Ita No.986/Ahd/2012 िनधा"रण वष"/Asstt. Year: 2008-2009 Aura Securities Pvt. Ltd. Acit, Akhay Building, B/H, Vadilal Vs. Circle-1, House, 53, Shrimali Society, Ahmedabad. Navrangpura, Ahmedabad-380009 Pan: Aabct4637N

68 Taxman 344/200 ITR 567 (SC) and judgments of this Court in CIT v. Dinesh Jain, HUF [2012] 25 taxmann.com 550/211 Taxman 23/[2013] 352 ITR 629 and CIT v. Gulshan Kumar [2002] 123 Taxman 111/257 ITR 703 (Del). 25. As noted above, Section 52 of the Act was omitted by Finance Act, 1987 with effect from 1st April

AURA SECURITIES PVT.LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-1,, AHMEDABAD

In the result the appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.834/Ahd/2012 "नधा"रण वष"/Asstt. Year: 2008-2009 Dcit, Aura Securities Pvt. Ltd. Circle-1, V Akhay Building, B/H, Vadilal Ahmedabad. S. House, 53, Shrimali Society, Navrangpura, Ahmedabad-380009 Pan: Aabct4637N आयकर अपील सं./Ita No.986/Ahd/2012 िनधा"रण वष"/Asstt. Year: 2008-2009 Aura Securities Pvt. Ltd. Acit, Akhay Building, B/H, Vadilal Vs. Circle-1, House, 53, Shrimali Society, Ahmedabad. Navrangpura, Ahmedabad-380009 Pan: Aabct4637N

68 Taxman 344/200 ITR 567 (SC) and judgments of this Court in CIT v. Dinesh Jain, HUF [2012] 25 taxmann.com 550/211 Taxman 23/[2013] 352 ITR 629 and CIT v. Gulshan Kumar [2002] 123 Taxman 111/257 ITR 703 (Del). 25. As noted above, Section 52 of the Act was omitted by Finance Act, 1987 with effect from 1st April

DASRATHSINH GHANSHYAMSINH CHUDASAMA,BHAVNAGAR vs. THE PR. COMMISSIONER OF INCOME-TAX-6, AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2015-16

68 should have been taxed at 30% and not as per the slab rates. Thus, the PCIT passed order under Section 263 of the Act vide order dated 30.04.2020 thereby directing the Assessing Officer to calculate tax as per Section 115BBE of the Act. 4. Being aggrieved by the Order under Section