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 14A ought to be deleted in full.\n19.\nWith regard to the disallowance of administrative

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., 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 14A ought to be deleted in full.\n19.\nWith regard to the disallowance of administrative

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

BHAUMIK JEWELLERS PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-1(1)(2), AHMEDABAD

In the result, the appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1642/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Bhaumik Jewellers Private The Ito बनाम/ Limited Ward-1(1)(2) V/S. 111, Gold Souk Complex Ahmedabad B/H. Sapphire Complex Cg Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aagcb 2423 B (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 17/12/2025 घोषणा की तारीख /Date Of Pronouncement: 03/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals) National Faceless Appeal Centre (Nfac), Delhi [In Short “The Cit(A)”] Passed Under Section 250 Of The Income Tax Act, 1961 (In Short “The Act”), Dated 26/07/2024 Arising Out Of The Assessment Order Passed By The Assessing Officer (In Short “The Ao”) Under Section 143(3) Of The Act For The Assessment Year 2017-18. The Assessee In This Appeal Has Agitated The Confirmation Of The Addition Of Rs. 9,65,97,834/- Made By The Ao Under Section 68 Of The Act Bhaumik Jewellers Private Limited Vs. The Ito Asst. Year : 2017-18

68 of the Act read with section 115BBE of the Act, treating the same as income from undisclosed sources. 4. Aggrieved by the order of the AO, the assessee preferred an appeal before the CIT(A). The CIT(A), however, confirmed the action of the AO. The CIT(A) relied heavily upon the decision of the Hyderabad Bench

SHRI SUBHASH BECHULAL SONI,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-6(4),, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 220/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2009-10 Subhash Bechulal Soni, I.T.O., B/H Shahwadi Bus Stand, Vs. Ward-6(4), Shahwadi, Ahmedabad. Narol, Ahmedabad-382405. Pan: Adzps9498J

197 and contended that the assessee has neither concealed nor furnished inaccurate particulars of income. According to the learned AR, there were, all the necessary details, furnished with respect to the cash credit entries which are available in the paper book. 8.1 The learned AR also submitted that there is no question of treating the entire gross amount of sale

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

Bench: Shri Rajpal Yadav & Shri Amarjit Singh

68,49,830/-. A notice under section 143(2) of the Act was issued on 1.11.2007 which was duly served upon the assessee. The ld.AO has observed that the assessee had received advance payment from two projects viz. Kalhar Project and Kings Square Project. He has worked out the total amount received by the assessee and how much work

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

68,49,830/-. A notice under section 143(2) of the Act was issued on 1.11.2007 which was duly served upon the assessee. The ld.AO has observed that the assessee had received advance payment from two projects viz. Kalhar Project and Kings Square Project. He has worked out the total amount received by the assessee and how much work

M/S. SHRI RANG INFRASTRUCTURE PVT. LTD.,,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 68 the onus on assessee has been duly discharged in reassessment proceedings. It has been held in Apex Court and jurisdictional High Court that when the primary onus on the assessee is discharged then the Ld. A.O. cannot proceed further for making addition u/s. 68 of the Act.” 10.1 The Ld. AR also relied upon the following decisions

SHRI RAVINDRASINH N.GOHIL,,BHAVNAGAR vs. INCOME TAX OFFICE,WARD-1(1),, BHAVNAGAR

Appeal is allowed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

section 147 of the Act. Resultantly, the case was reopened by issuance of notice u/s 148 of the Act dated 19.04.2012 upon the assessee. In appeal, the issue of reopening was challenged by the assessee along with other grounds that such proceeding was wrongly initiated by the Assessing Officer. Further that, no reasons for such reopening has been provided

SHRI RAVINDRASINH N.GOHIL,,BHAVNAGAR vs. INCOME TAX OFFICE,WARD-1(1),, BHAVNAGAR

Appeal is allowed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

section 147 of the Act. Resultantly, the case was reopened by issuance of notice u/s 148 of the Act dated 19.04.2012 upon the assessee. In appeal, the issue of reopening was challenged by the assessee along with other grounds that such proceeding was wrongly initiated by the Assessing Officer. Further that, no reasons for such reopening has been provided

LOPA CHIRAG SHAH,AHMEDABAD vs. ITO, WARD-5(2)(3), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasadआयकर अपील सं./I.T.A. No. 1800/Ahd/2018 ("नधा"रण वष" / Assessment Year : 2015-16)

197, Manekbaug Society, Ward 5(2)(3), Narayan Vs. Ambawadi, Ahmedabad - Chambers, Near Nehru 380015 Bridge, Ashram Road, Ahmedabad - 380009 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : ALXPS5771Q .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant by : Shri Himanshu Gandhi, A.R. ""यथ" क" ओर से / Shri Vidhyut Trivedi, Sr. D.R. Respondent by : सुनवाई क" तार"ख / Date of 02/09/2020 Hearing

INCOME TAX OFFICER, WARD-1(2)(1), AHMEDABAD, AHMEDABAD vs. CHHAGANLAL DALAJI SONI, AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

197 Taxman 58 (Delhi), the High Court held that profit margins of a taxpayer as declared by him can be varied and disturbed only if profit margins in case of other assessees engaged in similar business are higher. Since the Assessing Officer had not brought on record any comparable case wherein net profit declared by a taxpayer in similar business

RAMESHKUMAR G. PATEL,VADODARA vs. THE ITO, WARD-3(1)(5) PRESENT JURISDICTION ITO, WARD-3(1)(2), VADODARA

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

68,096/-\nand the assessee was required to pay 25% thereof, amounting to\nRs.10,42,024/- by 30.11.2016. However, the assessee paid only\nRs.4,18,096/-, failing to comply with the full payment requirement under\nthe Scheme. Consequently, the declaration under IDS was treated as\ninvalid.\n3.2 Based on this, the Assessing Officer recorded reasons to believe that\nincome

EAGLE STEEL INDUSTRIES PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, AHMEDABAD

In the result, appeal filed by the Assessee is allowed

Bench: Shri P. K. Kedia & Shri Mahavir Prasad)

68,187/- to Appu Logistic and Shree Enterprises. It is further seen that the said payments made by assessee without deducting tax at source u/s 194C of the Act. Therefore, assessee was asked to explain as to why provisions of section 40(a)(ia) of the I T Act should not be invoked in light of non compliance

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. SHRI UMANG H. THAKKAR, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

68 of Rs.4,67,78,466/- pertaining to unexplained capital and Rs.3,28,02,305/- pertaining to unexplained cash credits have been rightly deleted by the ld. CIT(A) after appreciating all evidences filed by the assessee. Ground No.2 raised by the Revenue is, therefore, found to be devoid of any merit and is accordingly dismissed. 7. Ground No.3 raised

SHRI UMANG HIRALAL THAKKAR,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

68 of Rs.4,67,78,466/- pertaining to unexplained capital and Rs.3,28,02,305/- pertaining to unexplained cash credits have been rightly deleted by the ld. CIT(A) after appreciating all evidences filed by the assessee. Ground No.2 raised by the Revenue is, therefore, found to be devoid of any merit and is accordingly dismissed. 7. Ground No.3 raised

SHRI SANDEEP JAGDISHCHANDRA DAVE,,AHMEDABAD vs. TEH PR. CIT -3, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 197 of the Act and the Assessing Officer did not make any effort to retrieve Form 13 and verify the details therein. Secondly, the PCIT observed that the assessee had claimed a huge expenditure amounting to Rs. 11,68

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

section 192 of the Act. But the assessee has claimed such expenses without deducting the TDS. Thus the impugned expenses cannot be allowed under section 40(a)(ia) of the Act. The ld. DR vehemently supported the order of the lower authorities. 17. We have heard the rival contentions of both the parties and perused the material available