THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRA SPACE PRIVATE LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 69B of the Act. 46. At the outset we note that the issues raised by the Revenue in its ground of appeal for the AY 2013-14 are identical to the issues raised by the Revenue in ITA No. 2130/AHD/2017 for the assessment year 2012-13. Therefore, the findings given in ITA No. 2130/AHD/2017 shall also be applicable

JAS INFRASPACE PVT. LTD.,AHMEDABAD vs. DCIT, CIRCLE-2(2)(1),, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 69B of the Act. 46. At the outset we note that the issues raised by the Revenue in its ground of appeal for the AY 2013-14 are identical to the issues raised by the Revenue in ITA No. 2130/AHD/2017 for the assessment year 2012-13. Therefore, the findings given in ITA No. 2130/AHD/2017 shall also be applicable

SHAILESHKUMAR DAHYABHAI PATEL,VADODARA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(1)(2) (NOW DCIT CIRCLE 2(1)(1), VADODARA, GUJARAT, VADODARA, GUJARAT

In the result, Ground Number 7 of the assessee’s appeal is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68 of the Act and he confirmed the addition of ₹60,50,000/- as unexplained cash credits. 6. In relation to the disallowance of interest expenditure of ₹8,98,956/- under section 69C of the Act, the Ld. CIT(Appeals) held that once the principal loan itself was held to be unexplained, the interest claimed thereon could

THE ACIT,ANAND CIRCLE,, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. No.1384/Ahd/2014 ("नधा"रण वष" / Assessment Year : 2007-08)

68,33,606/- which is arising out of the payment made towards interest under section 234B of the Act. Copy

DUSHYANT SHANTILAL PATEL,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

68, 69, and 69A.\nInterest under sections 234A, 234B, 234C and 234D was also levied.\nAccordingly, the assessed income

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234B of the Act. 10. The learned AO based on the directions of the DRP has erred in initiating penalty proceedings under section 274 r.w.s 271(1)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative

ITO, WARD-4(2)(3), AHMEDABAD, AHMEDABAD vs. MAHESHWARI SALES CORPORATION, AHMEDABAD

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

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1306/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Ito Maheshwari Sales Corporation बनाम/ Ward-4(2)(3) C-111, Ganesh Meridin V/S. Ahmedabad Nr.Sola Bridge, Sola Ahmedabad-380 058 "थायी लेखा सं./Pan: Aalfm 4917 H (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Smt. Mamta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/09/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal By The Revenue Is Directed Against The Order Of The Ld.Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Dated 11/04/2025, Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2018-2019. 2. The Revenue Has Raised The Following Grounds Of Appeal: Ito Vs. Maheshwari Sales Corporation Asst. Year : 2018-19

68 of the Act, holding that the assessee had satisfactorily explained the nature and source of the transaction. Grounds relating to levy of interest under sections 234B

AYUSH PAVANKUMAR AGRAWAL,AHMEDABAD vs. THE ITO, WARD-1(2)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical\npurposes

68. In addition, based on the presumption that such entries\nentail commission ranging from 2%-4%, the AO estimated an amount of\nRs.4,58,206/- as commission paid by the assessee and added it under\nsection 69C of the Act. He also initiated penalty proceedings under section\n271AAC and levied interest under sections 234B

D. J. STOCK BROKING PRIVATE LIMITED,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(4),, AHMEDABAD

In the result, ground number 1 of the assessee’s appeal is allowed

68 of the Act and therefore the ld.AO should be directed to delete the said addition, while computing total income. 4 That the learned CIT(A) has erred in Rs. 7,782/- law and facts by confirming the disallowance of Rs. 25,184/- under section 14A of the I.T Act and therefore the ld. Assessing Officer