M/S GREENWELL ORCHARDS,AHMEDABAD vs. THE PR.CIT-3 , AHMEDABAD

In the result, appeal filed by the Assessee is allowed

1) calling for I.T.A No. 695/Ahd/2019 A.Y. 2009-10 Page No 19 M/s. Greenwell Orchards vs. Pr.CIT various details from the assessee and the assessee also had made detailed replies to the above notice with proper evidences and necessary records which are discussed in para 12 of this order. Thus the Assessing Officer having carried out such detailed enquiries satisfied

AMBE TRADECORP PVT. LTD.,AHMEDABAD vs. THE PR. CIT (CENTRAL), AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.53/Ahd/2021 िनधा"रण वष"/Asstt. Year: 2010-2011 Ambe Tradecorp Private Limited, The P.C.I.T.(Central) Iscon House, Vs. Ahmedabad. B/H. Rembrandt Building, C.G. Road, Ahmedabad.

68 of the Act on such receipt. Now the question arise whether the learned Principle CIT can extend the area of examination under section 263 by revising the assessment order framed under section 147 r.w.s. 143(3). To our understanding the answer stands negative for the reason that proceeding under section 147 is limited to the extent

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

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 received certain amount as gifts from his father and sister who were non-residents in India Assessing Officer after making detailed enquiries, took a view that assessee had duly proved identity, source and creditworthiness of donors Commissioner

THY ACIT, CIRCLE-2(1)(2), , AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

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

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

263 Chennai) (SB) • ACIT, Circle - 16(3)(Hyderabad-Trib) vs. Priyadarshini Spinning Mills (P.) Ltd. (2012) ITA No. 1776 (2011) ACIT (International Taxation) vs. Star Cruise India Travel Services Pvt. Ltd. [14 ITR (T) 282 (Mum.) 2.20. In view of the preceding discussions, the submissions of the appellant, including the judgments / decisions of various courts and considering the fact that

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

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 r.w.s. 115BBE in respect of loan from Crown Laminates Pvt. Ltd., Carry forward

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

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

263 and 144B and treated the entire sum of Rs.169,75,68,149/- as unexplained money under section 69A. The amount was brought to tax under section 115BBE, and penalty proceedings under sections 271(1

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

1). The Principal Commissioner sought to revise the assessment under section 263 on the ground that the addition ought to have been made under section 69C and taxed at the higher rate prescribed under section 115BBE. The Tribunal rejected this approach, holding that section 37 is the appropriate provision where the nature of expense (purchases

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68,35,63,534 3,57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68,35,63,534 3,57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68,35,63,534 3,57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

68,35,63,534 3,57,376 100.00% ITA Nos.265, 805, 806 & 2344/Ahd/2018 DCIT vs. VyaktiVikas Kendra India Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15 8.8 It further appears that various courses conducted by the appellant trust specially part-1 and part-2 and the Apex course have a direct nexus and/or co- relation with the objects

MADRESA MOHAMMADIYAN AND PANJATANIYA,DAHOD GUJARAT vs. CIT(E), AHMEDABAD, AHMEDABAD

In the result the appeal filed by the assessee is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2017-18 Madressa Mohammadiyn & Cit(Exemption) Panjataniya, Madresa Raildings Nehru Bridge B/H. Tower Talav Road, Dahod. Ahmedabad. Pan : Brdmo 8620 D (Applicant) (Responent) : Shri Ankit Chokshi, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 26/09/2025 आदेश आदेश/O R D E R आदेश आदेश

263 dated 16.11.2021 setting aside the assessment order dated 30.12.2019 passed under section 144. Pursuant thereto, the case was taken up in faceless mode. Notices under section 142(1) were issued on 04.01.2023 and 20.01.2023 seeking, inter alia, the audit report in Form No. 10B, details of activities, computation of income, income and expenditure account and balance sheet

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

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

In the result, the revenue’s appeal is thus dismissed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

263 Chennai) (SB) • ACIT, Circle - 16(3)(Hyderabad-Trib) vs. Priyadarshini Spinning Mills (P.) Ltd. (2012) ITA No. 1776 (2011) ACIT (International ACIT vs. M &B EngineeringLtd.. Asst.Year – 2014-15 Taxation) vs. Star Cruise India Travel Services Pvt. Ltd. [14 ITR (T) 282 (Mum.) 2.20. In view of the preceding discussions, the submissions of the appellant, including the judgments