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

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

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

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

DHARAMTAR MOTORS SERVICES PETROLEUM PRODUCT,,AHMEDABAD vs. THE ITO, WARD-6(1)(4),, AHMEDABAD

In the results, both the appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 1438 & 2534/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 M/S Dharamtar Motor Services Income Tax Officer, Petroleum Product, Vs. Ward 6(1)(4) C/O. Ketan H. Shah, Advocate 903, Ahmedabad. Sapphire Complex, C.G. Road, Navrangpura, Ahmedabad. Pan: Aabfd9182F

201 to 217 of the paper book. Thus, it is clear that the same cannot be added in the year under consideration as the same were not obtained in the current year. It is also important to refer the provisions of section 68 of the Income Tax Act, which reads as under; Cash credits. 68. Where

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

201-500 2,08,71,143 56,127 15.71% 23.14% 3 501-1000 10,87,10,735 1,21,084

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

201-500 2,08,71,143 56,127 15.71% 23.14% 3 501-1000 10,87,10,735 1,21,084

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

201-500 2,08,71,143 56,127 15.71% 23.14% 3 501-1000 10,87,10,735 1,21,084

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

201-500 2,08,71,143 56,127 15.71% 23.14% 3 501-1000 10,87,10,735 1,21,084

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

201 of Act were carried out for non-withholding of tax at source at the time of making payment for availing HR Shell Services. The Hon'ble Mumbai ITAT in case of SIMPL (ITA No. 6064, 6065, 6066 and 6067/Mum/2019) has held that the payments made by SIMPL to the assessee on account of HR Shell Services is not taxable