JATINKUMAR PATEL,CHHATRAL KALOL vs. INCOME TAX OFFICE, WARD 1, MEHSANA, MEHSANA

The appeal is allowed for statistical purposes in the above terms

Bench: Dr. B.R.R Kumar & Shri Siddhartha Nautiyal

sections 144 read with 263 and 144B and treated the entire sum of Rs.169,75,68,149/- as unexplained

VINEETSINGH GULABSINGH RORE,AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal filed by the assessee is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

section 263 to us, appears to be a plausible explanation, and there is no doubt that in the consequent assessment, the assessee was assessed multiple times to its returned income, which forced him into action and he came to the consult another legal adviser on whose advise the present appeal was filed before us. The delay in filing

OLYMPIC DECOR LLP,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, the Appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2018-19 Olympic Décor Llp Pr.Commissioner Of 6, Patel Avenue, Nr.Gurudwara Vs Income Tax-3 Sg Highway, Bodakdev Ambawadi Ahmedabad. Ahmedabad. Pan : Adafs 2113 H (Applicant) (Responent) : Assessee By Shri Tushar Hemani, Sr.Advocate & Parimalsinh B. Parmar, Ars : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 23/05/2025 आदेश आदेश/O R D E R आदेश आदेश

263 was issued, pointing out various issues, including: Allowance of depreciation on goodwill allegedly created upon i. amalgamation of a subsidiary, Allowance of deduction under section 80IA, ii. Non-taxation of alleged unexplained credit of Rs. 10.80 crore iii. under section 68

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], dated 31.03.2025, for the assessment years 2017-18, 2018-19, 2019-20 and 2020-21. By the impugned orders, the learned PCIT held that the assessments framed by the Assessing Officer (AO) u/s. 153C of the Act (except A.Y. 2020-21 where proceedings were

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokar

section 263 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], dated 31.03.2025, for the assessment years 2017-18, 2018-19, 2019-20 and 2020-21. By the impugned orders, the learned PCIT held that the assessments framed by the Assessing Officer (AO) u/s. 153C of the Act (except A.Y. 2020-21 where proceedings were

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

263 in the context of differential treatment of additions under sections 68 and 69C vis- à-vis applicability of section

SHAH JITENDRAKUMAR MAFATLAL HUF,ELLISBRIDGE, AHMEDABAD vs. PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68 read with section 115BBE of the Act. However, in the order passed under section 263, the PCIT

HBC LIFESCIENCES PRIVATE LIMITED,GANDHINAGAR vs. THE PR. CIT-3, AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 328/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2018-19) िनधा"रण वष" Hbc Lifesciences Private Principal Commissioner बनाम बनाम/ बनाम बनाम Limited Of Income Tax-3 Vs. B-218, Mayur House, Ahmedabad G.I.D.C., Electronic Estate Sector-25, Gandhinagar, Gujarat, 382016 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacch1407M (Appellant) .. (Respondent) Shri S. N. Soparkar, Sr. Advocate & अपीलाथ" ओर से /Appellant By : Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr 20/06/2024 Date Of Hearing Date Of Pronouncement 05/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax-3, Ahmedabad, (In Short The ‘Pcit’) Dated 25.03.2023 In Exercise Of The Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act” In Short], For The Assessment Year 2018-19. 2. The Brief Facts Of The Case Are That The Return Of Income For A.Y. 2018-19 Was Filed By The Assessee On 30.10.2018 Declaring

263 of the Act dated 17.02.2023 that the business promotion expense claimed by the assessee was in the nature of freebies/monetary grant for promoting products and was required to be disallowed. Further that the AO had passed the assessment order without making proper enquiry and the required addition in respect of this claim. It is not apparent

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

263 of the Income-tax Act, 1961 [hereinafter referred to as “the\nAct"], dated 31.03.2025, for the assessment years 2017-18, 2018-19,\n2019-20 and 2020-21. By the impugned orders, the learned PCIT held\nthat the assessments framed by the Assessing Officer (AO) u/s.153C\nof the Act (except A.Y. 2020-21 where proceedings were u/s.143

RAJESH BALVANTRAI BRAHMBHATT,AHMEDABAD vs. THE PR. CIT(CENTRAL), AHMEDABAD

In the result, the appeals of the assessee is allowed

263 of the Income-tax Act, 1961 [hereinafter referred to as “the\nAct"], dated 31.03.2025, for the assessment years 2017-18, 2018-19,\n2019-20 and 2020-21. By the impugned orders, the learned PCIT held\nthat the assessments framed by the Assessing Officer (AO) u/s.153C\nof the Act (except A.Y. 2020-21 where proceedings were u/s.143

M/S.HDB FINANCIAL SERVICES LTD.,,AHMEDABAD vs. THE PR. CIT-1 , AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

68, read with section 263, of the Income-tax Act, 1961 - Cash credit (Gift) - Assessment years 2007-08 and 2008-09- Assessee

VISHAL BALVANTRAI AGARWAL,AHMEDABAD vs. THE PR. COMMISSIONER OF INCOME TAX, AHMEDABAD -1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.226/Ahd/2023 िनधा"रण वष" /Assessment Year : 2018-19 Vishal Balvantrai Agarwal The Pr.Cit बनाम/ 249 New Cloth Market Ahmedabad-1 V/S. O/S. Raipur Gate Ahmedabad – 380 002 (Gujarat) "थायी लेखा सं./Pan: Adbpa 4462 G (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Divyakant Parikh, Ar Revenue By : Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am:

68 of the Act and these transactions undertaken by the assessee company during the relevant Financial Year.” 7.2. The non-consideration of the effect of these transactions due to a lack of inquiry constituted an omission that justified invoking Section 263

M/S. BLUERAY TRADING PVT LTD.,MAHARASTRA vs. THE PR. CIT (CENTRAL), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

263(1) of the Act.” 3. The brief facts of the case are that for the impugned year under consideration, the assesee filed return of income declaring total income at Rs. 1,03,630/-. Subsequently, the assessment of the assessee was completed under Section 143(3) r.w.s. 147 of the Act wherein share capital Blueray Trading

MR. PRANJAL PATEL,,AHMEDABAD vs. THE PR. CIT-2,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

sections etc. whether applicable or not merely on assumption or presumption without applying the mind. Your appellant therefore submits that the notice u/s. 263 dated 09-03-2017 and order passed u/s. 263 dated 28-03-2017 are bad in law and the same should be cancelled.” 3. In this case, return of income declaring income

GHANSHYAMBHAI AMBALAL PATEL,KHEDA vs. THE PCIT-1, AHMEDABAD

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

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

section 263 proceedings. On this count also, the revision order passed by the Id. PCIT u/s.263 of the Act deserves to be quashed. 4.2. In view of the aforesaid observations, we have no hesitation in quashing the revision order passed by the ld. PCIT u/s.263 of the Act for more than one reason as detailed supra” 5.1 Second reason

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

68 to non-resident shareholders, which requires the nature of source of any amount found in the books of the assessee to be proved to the satisfaction of the AO. The Ld. D.R. submitted that even if source of source is not proved at least the source of receipts in the hands of the non-resident shareholder needs

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

68 to non-resident shareholders, which requires the nature of source of any amount found in the books of the assessee to be proved to the satisfaction of the AO. The Ld. D.R. submitted that even if source of source is not proved at least the source of receipts in the hands of the non-resident shareholder needs

STHAPTHYA BUILDCON PVT. LTD.,,AHMEDABAD vs. THE DCIT, WARD-4(1)(1),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 814/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2013-2014 Sthapathya Buildcon Pvt Ltd., D.C.I.T, Pavan Petroleum, Vs. Circle-4(1)(1), Nutun Mill Compund, Ahmedabad. Near City Gold Cinema, Saraspur, Ahmedabad. Pan: Aalcs8818G

68,19,850.00 under normal computation of income and the book profit u/s 115JB of the Act was determined at Rs. 84,74,996.00. 3.2 Before coming to the specific issue raised under section 263