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

24– creditworthiness Moreover, transactions were made through banking channels - Whether any addition could not be made to assessee's income under section 68

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

section 68, the CIT(A) granted partial relief and sustained the addition only to the extent of Rs.3,24

THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. STHAPATYA SHILP CONSTRUCTION, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 907/Ahd/2019 With C.O.No.170/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sthapatya Shilp Construction, Central Circle-1(2), Vs. 2, Abhiraj Complex, Ahmedabad. 68-B, Swastic Society, Ahmedabad. Pan: Abffs2922P

section 68 of the Act. 24. The learned CIT(A) after considering the submission of the assessee deleted the addition

THE DCIT, CENTRAL CIIRCLE-1(2), AHMEDABAD vs. SHRENA S SUTARIA, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 796/Ahd/2019 With C.O.No.172/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Shrena S. Sutaria, Central Circle-1(2), Vs. 8, Amrashagun Bunglows, Ahmedabad. Nr. Hathisingh Park, Satellite, Ahmedabad-380015. Pan: Asqps7606E

section 68 of the Act. In view of the above, we do not find any With C.O.No.172/Ahd/2019 Asstt. Year 2010-11 24

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S.DHARMEN MARBLE & STONE, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 794/Ahd/2019 With C.O.No.171/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Dharmen Marble & Stone, Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aabfd5172B

section 68 of With C.O.No.171/Ahd/2019 Asstt. Year 2010-11 24 the Act by the Hon’ble Calcutta High

DCIT, CENTRAL CIRCLE-(1)(2), AHMEDABAD vs. SHREYASI DHARMEN SUTARIA, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 797/Ahd/2019 With C.O.No.173/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Shreyasi Dharmen Sutaria, Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. 2Nd Address: 8, Amrashagun Bunglows, Nr. Hathisingh Park, Satellite, Ahmedabad-380015. Pan: Awops1881R

section 68 of the Act. With C.O.No.173/Ahd/2019 Asstt. Year 2010-11 24 24. We have heard the rival

THE DCIT, CENTRAL CIRCLE-1(4), AHMEDABAD vs. M/S. GTC OILFIELDS SERVICES P. LTD, AHMEDABAD

In the result, all the 8 appeals filed by the Revenue are dismissed

Bench: Shri P.M. Jagtap, Vice- & Ms. Madhumita Royappeal No. Ay Appellant Respondent Sn M/S. Gtc Oilfields Services P. Ltd., 2009-10 The Dcit, 61, New York Tower, A-Block, It(Ss)A Nos. 1-3 2010-11 Central Circle 1(4), Thaltej Char Rasta, S.G. Road, 314 To 316/Ahd/2019 2014-15 Ahmedabad Ahmedabad-380054 Pan : Aaacg 8684 P The Dcit, M/S. Gtc Oilfields Services P. Ltd.

Section 68 of the Act by treating the share capital and share premium amounts as unexplained cash credit were not sustainable as rightly held by the learned CIT(A). 14. At the time of hearing before us, the learned Counsel for the assessee has emphasized that the facts involved in the present cases are materially similar to the facts

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

section 68 of the Act. 2. The facts in brief are that the assessee in the present case is a partnership firm, comprising two partners namely Chandrakant N Shah and Nimesh C Shah. The assessee is engaged in the activity of trading of petroleum products. The assessee (the partnership firm) was established as partnership firm sometime in the year

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. MAYORA INDIA PRIVATE LIMITED (FORMERLY KNOWN AS , AHMEDABAD

In the result, the appeals of the Department are dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 68 would not come into play, looking into the instant facts. 13. In the result, we find no infirmity in the order of Ld. CIT(A) so as to call for any interference. Ground No. 2:- Ad-hoc disallowance of business expenditure @ 10% of Rs. 14,30,00,000/-. 14. The brief facts in relation to this ground

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. MAYORA INDIA PRIVATE LIMITED (FORMERLY KNOWN AS "INBISCO INDIA PVT. LTD.), AHMEDABAD

In the result, the appeals of the Department are dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 68 would not come into play, looking into the instant facts. 13. In the result, we find no infirmity in the order of Ld. CIT(A) so as to call for any interference. Ground No. 2:- Ad-hoc disallowance of business expenditure @ 10% of Rs. 14,30,00,000/-. 14. The brief facts in relation to this ground

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

24. During the survey proceedings under section 133A of the Act, a question was also put to Shri Pradeep Aggarwal to substantiate that the assessee has paid cash against the acquisition of shares. However, he categorically denied to substantiate his statement. For this purpose, we can refer the statement of Shri Pradeep Aggarwal. The relevant extract is reproduced

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

24. During the survey proceedings under section 133A of the Act, a question was also put to Shri Pradeep Aggarwal to substantiate that the assessee has paid cash against the acquisition of shares. However, he categorically denied to substantiate his statement. For this purpose, we can refer the statement of Shri Pradeep Aggarwal. The relevant extract is reproduced

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

24. During the survey proceedings under section 133A of the Act, a question was also put to Shri Pradeep Aggarwal to substantiate that the assessee has paid cash against the acquisition of shares. However, he categorically denied to substantiate his statement. For this purpose, we can refer the statement of Shri Pradeep Aggarwal. The relevant extract is reproduced

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRASPACE PRIVATE LIMITED,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

24. During the survey proceedings under section 133A of the Act, a question was also put to Shri Pradeep Aggarwal to substantiate that the assessee has paid cash against the acquisition of shares. However, he categorically denied to substantiate his statement. For this purpose, we can refer the statement of Shri Pradeep Aggarwal. The relevant extract is reproduced

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. DHARMENBHAI MAHENDRABHAI SUTARIA -HUF, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 795/Ahd/2019 With C.O.No.169/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., Dharmenbhai M. Sutaria, Huf Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aafhd1653K

24 27.4 Therefore, in our considered view, the assessee has discharged its onus imposed under section 68 of the Act. In view

ARVINDBHAI PUNABHAI PATEL,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Accordingly accepted in principle, and the issue is restored to the\nAssessing Officer for fresh adjudication in terms of directions\nabove.\n25. In the combined result, the appeal of the assessee ...

68 was technically inapplicable. In our considered\nview, the addition is sustainable in substance under the broader\nprovisions of the Act, including section 69 or section 69A, and\nthe mere nomenclature employed by the Assessing Officer does\nnot dilute the chargeability of the income under the Act.\n22. Having dismissed the primary ground challenging the\naddition on legal

SHRI NARENDRA B. PATEL,,SABARKANTHA vs. THE INCOME TAX OFFICER, WARD-2,, HIMATNAGAR

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 3153/Ahd/2014 िनधा"रण वष"/Asstt. Year: 2011-12 Narendra B. Patel, I.T.O., 592, Pampaliva Vas, Vs. Ward-2, Moyad, Himatnagar. Sabarkantha-383110. Pan: Asupp6989M

section 68 of the Act except the sum of Rs. 2 lacs and added the remaining amount of Rs. 46,24

THE DCIT-CIRCLE-4(1)(1), AHMEDABAD vs. SHREE SIDDHI INFRABUILD PVT. LTD, AHMEDABAD

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

68 Date Name Amount AO’s Annexure decoded written decoded inference ITA Nos. 1635 to 1637/Ahd/2019 Asst. Years: 2011-12, 2012-13 and 2014-15 14 A-129 10-Oct-2011 Kalpesh 1,75,00,000 Receipt of p.161 cash A-129 11-Oct-2011 Kalpesh 1,25,00,000 Receipt of p.166 cash A-129 11-Oct-2011 Kalpesh