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

section 68 of the Act. As per amended provisions, the assessee IT(SS)A No. 73/Ahd/2025 and others Group Appeals - HK Ispat Pvt Ltd Asst.Year : 2015-16 to 2021-2022 - 8– needs to explain source to source of sum credited to his bank account, the appellant submitted that such amended provisions not applicable to current year, thus the appellant

AANYA DEVELOPERS,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Rifaur Rahman

section 68 of the Act. He further observed that the assessee has alleged payment of interest on these loans which were termed as bogus, therefore, the expenses claimed in the shape of interest deserves to be disallowed. He disallowed such interest expenditure and made addition of Rs.3,01,277/-. 5. Dissatisfied with the additions, the assessee carried the matter

NAVRANGPURA ORGANISERS & DEV. PVT. LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1),, AHMEDABAD

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

68 of the Income Tax Act contemplates that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof, or the explanation offered by the assessee is not, in the opinion of the AO satisfactory, then the sum so credited

NAVRATNA ORGANISERS & DEV. PVT. LTD.,AHMEDABAD vs. THE ACIT, CENT. CIRCLE 1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

68 of the Income Tax Act contemplates that where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation about the nature and source thereof, or the explanation offered by the assessee is not, in the opinion of the AO satisfactory, then the sum so credited

BIMAL KUNJBIHARI GORAI, HUF,AHMEDABAD vs. THE ITO, WARD-1(2)(1), AHMEDABAD

The appeal of the assessee is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

section 68 does not apply to opening stock. However, even after deleting the addition on technical grounds, the core factual defects—absence of stock records, unverifiable purchases, and the fabricated nature of transactions with M/s Hari Darshan Jewellers—remain uncontroverted. The assessee has failed to demonstrate that the opening stock figure was genuine or supported by credible inventory records

INCOME TAX OFFICER, WARD-3(1)(1), AHMEDABAD., AHMEDABAD vs. NEPTUNE OVERSEAS LTD., ASHRAM ROAD

In the result, the appeal of the Department is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

68 of the IT Act. ITO vs. Neptune Overseas Ltd. Asst. Year –2011-12 - 2– (f) The appellant craves leave to add, alter and / or to amend all or any of the ground before the final hearing of the appeal.” 3. The brief facts of the case are that the Assessing Officer received information that the assesse had purchased units

M/S GREENWELL ORCHARDS,AHMEDABAD vs. THE PR.CIT-3 , AHMEDABAD

In the result, appeal filed by the Assessee is allowed

182 taxmann.com 183 (Guj.) wherein held as follows: 17. Thus, the Commissioner of Income-tax is entitled to revise an assessment order insofar as the order is erroneous and prejudicial to the interest of the revenue, but Explanation (c) places an embargo on the Commissioner of Income-tax in case of subject- I.T.A No. 695/Ahd/2019 A.Y. 2009-10 Page

THE ITO(INTE.TAXA)-1, AHMEDABAD vs. MADHAV VASANT DALVI, AHMEDABAD

In the result, the Grounds of Appeal raised by the Revenue is rejected and the appeal filed by the Revenue is hereby dismissed

section 68 - Tribunal having determined thai assessee was a non-resident, deleted impugned addition - Whether since in none of relevant assessment years assessee stayed in India for 182

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. ALPHA NIPPON INNOVATIVES LTD.,,

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 1360/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2012-13 D.C.I.T, Alpha Nippon Innovatives Ltd., Circle-1(1)(1), Vs. (Formerly Known As Tim Engineering Ahmedabad. Technologies Pvt. Ltd.) Survey No.310, Vii, Bhamsara, Bavla, Bhamsara, Gujarat-382230. Pan: Aacct5088N

section 68 of the Income Tax Act does not arise. The appellant has submitted that identical issue arose for consideration of the Hon'ble High Court of Gujarat in the case of Sunbarg Tradelink (P) Ltd. v ITO reported in 2017 146 DTR (Guj) 182

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, Chimanbhai Jivabhai 2(2), Vs Market,Vasna, Ahmedabad. Ahmedabad-382460. PAN: AASPT6796Q [Appellant] (Respondent) Assessee Represented : Shri Mehul K. PATEL, AR Revenue Represented : Shri Sudhendu Das, CIT-DR Date of hearing : 04-07-2024 Date of pronouncement : 28-08-2024 आदेश/ORDER PER BENCH: These Appeals are filed by the Assessee and the Revenue as against separate appellate orders

RAJESHBHAI MOHANBHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both appeals of the assessee are partly allowed for statistical purposes, subject to the levy of costs

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1097/Ahd/2024 & 1098/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Rajeshbhai Mohanbhai Prajapati The Ito बनाम/ D-Ff 108 Pushp Business Ward-3(3)(5) V/S. Campus Ahmedabad Vastral Cross Roads Sp Ring Road, Vastral Ahmedabad – 382 445 (Gujarat) "थायी लेखा सं./Pan:Atspp 0059 P अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Jignesh Shah, Adv. Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2024 घोषणा की तारीख /Date Of Pronouncement: 11/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

68 read with section 115BBE of the Act for alleged unexplained cash credits amounting to Rs.1,07,80,41,291/- (AY 2016-17) and Rs.74,49,42,182

RAJESHBHAI MOHANBHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both appeals of the assessee are partly allowed for statistical purposes, subject to the levy of costs

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1097/Ahd/2024 & 1098/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Rajeshbhai Mohanbhai Prajapati The Ito बनाम/ D-Ff 108 Pushp Business Ward-3(3)(5) V/S. Campus Ahmedabad Vastral Cross Roads Sp Ring Road, Vastral Ahmedabad – 382 445 (Gujarat) "थायी लेखा सं./Pan:Atspp 0059 P अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Jignesh Shah, Adv. Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2024 घोषणा की तारीख /Date Of Pronouncement: 11/12/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

68 read with section 115BBE of the Act for alleged unexplained cash credits amounting to Rs.1,07,80,41,291/- (AY 2016-17) and Rs.74,49,42,182

GREENLAND INFRACON PVT. LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

In the result, the appeal is allowed

section 143(3) of the Income-tax Act, 1961, for the assessment year 2014-15 on the following grounds:- “1. The Id. Commissioner of Income Tax (Appeals) has grossly erred in law and on facts of the case in confirming the action of Id. AO in not allowing to withdraw the disallowance of Rs.57,68,182