SHRI VISHAL MOHANLAL TILVA,BARODA vs. THE ADDL.CIT, CENTRAL RANGE, BARODA

In the result, all the appeals of the assessees are allowed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarsr.

68 of the Act. Only the reason for the Revenue was that the receipt of the loan was in cash, which was in violation of section 269SS of the Act. Thus, the Revenue authorities imposed penalty, as if the provision of section 271D is mandatory, without considering the ‘reasonable cause’ explained by the assessee both during the penalty

SHRI MOHANLAL SAVJIBHAI TILVA,BARODA vs. THE ADDL.CIT, CENTRAL RANGE, BARODA

In the result, all the appeals of the assessees are allowed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarsr.

68 of the Act. Only the reason for the Revenue was that the receipt of the loan was in cash, which was in violation of section 269SS of the Act. Thus, the Revenue authorities imposed penalty, as if the provision of section 271D is mandatory, without considering the ‘reasonable cause’ explained by the assessee both during the penalty

SHRI MOHANLAL SAVJIBHAI TILVA,BARODA vs. THE ADDL.CIT, CENTRAL RANGE, BARODA

In the result, all the appeals of the assessees are allowed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarsr.

68 of the Act. Only the reason for the Revenue was that the receipt of the loan was in cash, which was in violation of section 269SS of the Act. Thus, the Revenue authorities imposed penalty, as if the provision of section 271D is mandatory, without considering the ‘reasonable cause’ explained by the assessee both during the penalty

SHRI VISHAL MOHANLAL TILVA,BARODA vs. THE ADDL.CIT, CENTRAL RANGE, BARODA

In the result, all the appeals of the assessees are allowed

Bench: Smt.Annapurna Gupta & T.R. Senthil Kumarsr.

68 of the Act. Only the reason for the Revenue was that the receipt of the loan was in cash, which was in violation of section 269SS of the Act. Thus, the Revenue authorities imposed penalty, as if the provision of section 271D is mandatory, without considering the ‘reasonable cause’ explained by the assessee both during the penalty

DCIT CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. PINAC STOCK BROKERS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Dr.Brr Kumar & Shri T.R Senthil Kumar

68 of the Act Hence, the ground of appeal of the assessee is hereby portly allowed." (iii) The appellant against the addition of Rs 52,00,000/-confirmed by the Hon'bie ITAT, as discussed in para 5.1 (iii) above, a Miscellaneous Application was filed by the assessee claiming that the Hon'ble ITAT has inadvertently overlooked documents in respect

ALKABEN KETULKUMAR PATEL,AHMEDABAD vs. THE DCIT, CIRCLE-3(2), AHMEDABAD

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

Bench: Shri Ramit Kochar (Accountant Member)

68 of the 1961 Act read with Section 115BBE and added to the income of the assessee. 5.Aggrieved, the assessee filed first appeal with ld. CIT(A), who issued notice of hearings dated 13th January, 2021,10th August, 2023, 23rd August, 2023 and 29th September, 2023 which were claimed by the CIT(A) to have delivered

SMT. RESHMIBEN P. KANUGO,VADODARA vs. ITO, WARD-3(1)(3), VADODARA

In the result appeal filed the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 2131/Ahd/2018 2014-15 Smt. Reshmiben P. Income Tax Kanugo, Officer, 26, Jawahar Society, Nr. Ward 3(1)(3), Bakrawadi, R.V. Desai Vadodara. Road, Vadodara, Gujarat-390001. Pan: Azupk6721B 2. 2132/Ahd/2018 2014-15 Shri Alpesh P. Income Tax Kanugo(Huf), Officer, 26, Jawahar Society, Ward 3(1)(3), Nr. Bakrawadi, Ahmedabad. R.V. Desai Road, Vadodara-390001. Pan: Aajha5173P 3. 2133/Ahd/2018 2014-15 Shri Parasmal B. Kanugo Income Tax Officer, (Huf), Ward-3(1)(3), 26, Jawahar Society, Nr. Ahmedabad. Bakrawadi, R.V. Desai Road, Vadodara, Gujarat-390001. Pan: Aakhp0126Q

section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act) has challenged the order dated 21.10,2016 made by the Income Tax Appellate Tribunal, Ahmedabad Bench B in ITA No.926/And/2015 for assessment year 2008-09, by proposing the following questions stated to be substantial questions of law: [A] Whether the Appellate Tribunal Is correct

SMT. MEERA ALPESH KANUGO,VADODARA vs. ITO, WARD-3(1)(3), VADODARA

In the result, appeal filed by the assessee is allowed

68 of the I.T. Act. Reliance was also placed on the latest decision of Nishant Kantilal Patel(2013-14/5/SRT/2019) vide order dated 07.01.2021 of Surat Bench of ITAT on the same facts. It was requested that based on facts of the case, appeal may kindly be allowed. The assessee submitted that the Assessing Officer has not been able

CENTRAL CIRCLE 1(1) AHMEDABAD, AHMEDABAD vs. SUNIT SUDHIRBHAI CHOKSHI, AHMEDABAD

In the result, the appeals filed by the Revenue are hereby dismissed

Bench: Ld. Cit(A) On The Quantum Addition, Wherein Ld. Cit(A) Confirmed The Addition To Rs.4,71,46,684/- Only. Thus The Assessing Officer Levied Penalty Of Rs.2,80,88,610/- Being 60% Of Addition Confirmed By Ld. Cit(A) U/S. 271Aab Of The Act.

68,140/- as against the total addition made by the Assessing Officer of Rs.28.37 crores. The summary of additions/disallowances confirmed by Ld. CIT(A) and the Hon’ble ITAT are as follows: Sr. No Particulars Amount as per Amount Amount confirmed/ assessment order confirmed/upheld upheld by ITAT by CIT(A) 1. Addition on account

DCIT CENTRAL CIRCLE 1(1) , AHMEDABAD vs. SUNIT SUDHIRBHAI CHOKSHI, AHMEDABAD

In the result, the appeals filed by the Revenue are hereby dismissed

Bench: Ld. Cit(A) On The Quantum Addition, Wherein Ld. Cit(A) Confirmed The Addition To Rs.4,71,46,684/- Only. Thus The Assessing Officer Levied Penalty Of Rs.2,80,88,610/- Being 60% Of Addition Confirmed By Ld. Cit(A) U/S. 271Aab Of The Act.

68,140/- as against the total addition made by the Assessing Officer of Rs.28.37 crores. The summary of additions/disallowances confirmed by Ld. CIT(A) and the Hon’ble ITAT are as follows: Sr. No Particulars Amount as per Amount Amount confirmed/ assessment order confirmed/upheld upheld by ITAT by CIT(A) 1. Addition on account

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

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

section 260A of the Act before the High Court. 29. The Hon’ble High Court decision in the case of UED (supra) being rendered in the facts of the case, it cannot be said to be laying down any proposition of law. And therefore no benefit whatsoever can be derived by the assessee from the said decision. In view

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

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

section 260A of the Act before the High Court. 29. The Hon’ble High Court decision in the case of UED (supra) being rendered in the facts of the case, it cannot be said to be laying down any proposition of law. And therefore no benefit whatsoever can be derived by the assessee from the said decision. In view

THE DY.COMMISSIONER OF INCOME TAX,(EXEMPTIONS)CIRCLE-2,, AHMEDABAD vs. SURAT URBAN DEVELOPMENT AUTHORITY(SUDA), SURAT

In the result, the appeal preferred by the Revenue is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

68,09,114/- 3. Claim of exemptions for additions to fixed assets Rs. 1,07,76,025/- 4. Claim of exemptions for expdt on Gen Dev Rs. 58,59,82,648/- The above were, in turn, deleted by the Ld. CIT(A) in appeal preferred by the assessee. Hence, the instant appeal before us by Revenue. ACIT vs. Surat Urban

VINODCHANDRA T PARIKH,AHMEDABAD vs. ITO, WARD-2(1)(2),, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 457/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2013-2014 Vinodchandra T. Parikh, I.T.O, 31, Shail, Vs. Ward-2(1)(2), Opp. Madhusudan House, Ahmedabad. Navrangpura, Ahmedabad.

68,00,000 Balance amount has been paid towards purchase of land for construction. Asstt. Year 2013-14 5 7. 28/04-2011 - Land N.A made as assessee’s application dated 21.02.2011 in Revenue Record. 8. 29-07-2010 - A.Y. 2010-11, return of income filed for Net LTCG of Rs.2,76,10,400/- and 20% Tax paid after taking benefit

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(2)(FORMERLY ITO, WARD-3(3)(3)), AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

68 of the Act. Alternatively , the AO observed that since the assessee has not furnished any details during assessment proceedings, therefore it cannot be ascertained whether or not the assessee has recorded this transaction in his books of accounts or not. In case the assessee does not maintain books of account, then as per AO, the said amount shall

NIRAJ PRATAPBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-3(3)(2), (FORMERLY ITO, WARD-3(3)(3),, AHMEDABAD

In the result, the appeal of the assessee in ITA No

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench

68 of the Act. Alternatively , the AO observed that since the assessee has not furnished any details during assessment proceedings, therefore it cannot be ascertained whether or not the assessee has recorded this transaction in his books of accounts or not. In case the assessee does not maintain books of account, then as per AO, the said amount shall

SHAILESHBHAI BHA vs. ANGBHAI CHAVDA,BHAVNAGARVS.THE INCOME TAX OFFICER WARD 1(4) BHAVNAGAR, BHAVNAGAR

In the result, the appeal of the assessee in ITA No

Bench: Shri Ramit Kochar (Accountant Member)

68 to the tune of I.T.A No. 248/Ahd/2024 A.Y. 2012-13 Page No. 3 Shaileshbhai Bhavsangbhai Chavda vs. ITO Rs 16,79,307/- ignoring the evidences and submissions filed before Ld AO. 6. The appellant further reserves its right to add, alter, amend or modify any of the aforesaid grounds before or at the time of hearing of an appeal

PREMILA MUKESHBHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

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

Bench: Income Tax Appellate Tribunal, Ahmedabad Has Arisen From The Appellate Order Dated 16Th October, 2023 Passed By 2

68 of the 1961 Act as unexplained cash credit. 3. Aggrieved, the assessee filed first appeal with ld. CIT(A). The ld. CIT(A),NFAC issued notices to the assessee, but the assessee did not reply. The CIT(A), NFAC dismissed the appeal of the assessee ex-parte in-limine without adjudicating the issues on merits raised by the assessee

M/S. VENUS INFRABUILD,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmed

Section limitati Year Order on? IT(SS)A 102/Ahd/2019 2009- 143(3) r.w.s. Assessee 29.12.17 No 10 153A IT(SS)A 103/Ahd/2019 2010- 143(3) r.w.s. Assessee 29.12.17 No 11 153A IT(SS)A 104/Ahd/2019 2011- 143(3) r.w.s. Assessee 29.12.17 No 12 153A IT(SS)A 105/Ahd/2019 2012- 143(3) r.w.s. Assessee 29.12.17 No 13 153A