THY ACIT, CIRCLE-2(1)(2), , AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

Section 9 of the Act, which reads as under:- “Income deemed to accrue or arise in India. 659. 66(1) The following incomes shall be deemed67 to accrue or arise in India :— 68(i) all income accruing or arising, whether directly or indirectly, through or from any business connection69 in India, or through or from any property69 in India

HARISHKUMAR KHUSHALRAY BHATT,AHMEDABAD vs. THE ITO, WARD-3(3)(2) NOW WARD-3(3)(1), AHMEDABAD

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

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Harishkumar Khushalray Bhatt Ito, Ward-3(3)(2) P/1, Chandragupta Apartment Vs. Ahmedabad. Nr. Gordhandas Patel Hospital Vastrapur Ahmedabad. Pan : Abspb 3786 F (Applicant) (Responent) Assessee By : Shri Pritesh L. Shah, Ar : Shri Uday Kishanrao Kakne, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 15/07/2025 आदेश/O R D E R आदेश आदेश आदेश

68 6 can be made, as per settled judicial position. It was further submitted that even otherwise, there could not be an addition under section 69A for amounts duly entered in the books of account. The assessee had also submitted breakup of cash sales aggregating to Rs.18,30,920/- (Paper Book, Page 13-14) along with supporting sale bills

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

In the result, the revenue’s appeal is thus dismissed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

Section 9 of the Act, which reads as under:- “Income deemed to accrue or arise in India. 659. 66(1) The following incomes shall be deemed67 to accrue or arise in India :— 68(i) all income accruing or arising, whether directly or indirectly, through or from any business connection69 in India, or through or from any property69 in India

THE DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. AMOL DICALITE LTD.,, AHMEDABAD

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Royआयकर अपील सं./Ita No. 539/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2008-2009 & आयकर अपील सं./Ita No. 1246/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2010-2011 The D.C.I.T, Amol Dicalite Ltd. Circle-1(1)(1), Vs. 301, Akshay, 53, Ahmedabad Shirmali Society Navrangpura, Ahmedabad

195 read with section 40(a)(i) of the Act. 18. At the outset, we note that the issue raised is identical to the issue raised by the Revenue in ITA 539/Ahd/2018 which we have decided against the Revenue and in favor of the assessee vide Paragraph No. 14 of this order. Therefore respectfully following the same

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. AMOL DICALITE LTD.,, AHMEDABAD

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Royआयकर अपील सं./Ita No. 539/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2008-2009 & आयकर अपील सं./Ita No. 1246/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2010-2011 The D.C.I.T, Amol Dicalite Ltd. Circle-1(1)(1), Vs. 301, Akshay, 53, Ahmedabad Shirmali Society Navrangpura, Ahmedabad

195 read with section 40(a)(i) of the Act. 18. At the outset, we note that the issue raised is identical to the issue raised by the Revenue in ITA 539/Ahd/2018 which we have decided against the Revenue and in favor of the assessee vide Paragraph No. 14 of this order. Therefore respectfully following the same

M/S. ASIAN AGENCY,,AHMEDABAD vs. THE DCIT, CIRCEL-7(2),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

M/S. ASIAN AGENCY,,AHMEDABAD vs. THE ACIT, CIRCEL-7(2),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

M/S. ASIAN AGENCY,,AHMEDABAD vs. THE ACIT, CIRCLE-12,, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

M/S. ASIAN AGENCY,,AHMEDABAD vs. COMMISSIONER OF INCOME TAX,VII,, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

THE ITO, WARD-7(2)(1),, AHMEDABAD vs. M/S. ASIAN AGENCY,, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

M/S. ASIAN AGENCY,,AHMEDABAD vs. THE ACIT, CIRCEL-7(2),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

M/S. ASIAN AGENCY,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCEL-7(2),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt. Madhumita Roy

195 Taxman 68 has also held that where the assessment of the assessee was completed on estimated basis penalty under section

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

195/ DCIT, Cent.Cir.2 Neotech Education Ahd/2019 Vadodara. Foundation Asst.Year 2014-15, 18, Saptgiri Complex 2015-16, Opp: Gateway hotel Akota, Vadodara PAN : AADCB 8141 P अपीलाथ"/ (Appellant) "त् यथ"/(Respondent) Assessee by : Shri K.P. Singh, AR Revenue by : Shri R.R. Makwana, Sr.DR & Shri VinodTanwani, CIT-DR Shri VijaykumarJaiswal, CIT-DR सुनवाई क" तार"ख/Date of Hearing : 21/12/2021 घोषणा

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

195/ DCIT, Cent.Cir.2 Neotech Education Ahd/2019 Vadodara. Foundation Asst.Year 2014-15, 18, Saptgiri Complex 2015-16, Opp: Gateway hotel Akota, Vadodara PAN : AADCB 8141 P अपीलाथ"/ (Appellant) "त् यथ"/(Respondent) Assessee by : Shri K.P. Singh, AR Revenue by : Shri R.R. Makwana, Sr.DR & Shri VinodTanwani, CIT-DR Shri VijaykumarJaiswal, CIT-DR सुनवाई क" तार"ख/Date of Hearing : 21/12/2021 घोषणा

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

195/ DCIT, Cent.Cir.2 Neotech Education Ahd/2019 Vadodara. Foundation Asst.Year 2014-15, 18, Saptgiri Complex 2015-16, Opp: Gateway hotel Akota, Vadodara PAN : AADCB 8141 P अपीलाथ"/ (Appellant) "त् यथ"/(Respondent) Assessee by : Shri K.P. Singh, AR Revenue by : Shri R.R. Makwana, Sr.DR & Shri VinodTanwani, CIT-DR Shri VijaykumarJaiswal, CIT-DR सुनवाई क" तार"ख/Date of Hearing : 21/12/2021 घोषणा

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, Revenue’s appeal stands dismissed

Bench: Shri Waseem Ahmed & Shri Mahavir Prasadआयकर अपील सं./I.T.A. No.2503/Ahd/2016 ("नधा"रण वष" / Assessment Year : 2013-14) Dcit, M/S. Gujarat Microwax बनाम/ Cir – 2(1)(1), Pvt. Ltd., Vs. Ahmedabad. 401 & 02, Sarthik Square, Sarkhej Gandhinagar Highway, Bodakdev, Ahmedabad – 380 054 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacg 5593 P .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से / Appellant By : Dr. Jayant Jhveri, Sr.D.R. ""यथ" क" ओर से/Respondent By : Shri G.C. Pipara, C.A.

Section 9 of the Act, which reads as under:- “Income deemed to accrue or arise in India. 659. 66(1) The following incomes shall be deemed67 to accrue or arise in India :— 68(i) all income accruing or arising, whether directly or indirectly, through or from any business connection69 in India, or through or from any property69 in India

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18. It was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18.\nIt was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section