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

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

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

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

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, 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 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.,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

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

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

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

SAVLI TALUKA SECONDARY AND HIGHER SECONDARY EMPLOYEES CO OP. CREDIT SOCIETY LIMITED,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(2), VADODARA

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1772/Ahd/2024 िनधा"रण वष" /Assessment Year : 2019-20 Savli Taluka Secondary & The Income Tax Officer बनाम/ Higher Secondary Employees Ward-1(2)(2) V/S. Co-Op. Credit Society Ltd. Vadodara – 390 007 18, Rayakaka Park Savli Desar Road Vadodara – 391 770. "थायी लेखा सं./Pan: Aafas 6647 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Sanket Bakshi, Ar Revenue By : Shri Abhijit Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

68 of the Act without considering the fact that the amount deposited to the bank account were the recovery of loans which were extended to the members of the society in the earlier years. 7. The learned CIT(A) and the learned AO erred in fact and in law in making the order without giving a proper opportunity of being

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

In the result the appeal filed by assessee is partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

68 of the IT Act. 9. On the facts and in the circumstances of the case and in law, the NFAC erred in confirming the action of the Ld. AO in levying interest under section 234A, 234B