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

Section 69C of the Act, treating it as unexplained expenditure. 10.3 On appeal, the Ld. CIT(A) upheld the AO's finding that the suppliers were non-genuine but disagreed with the 100% disallowance. Relying on jurisdictional precedents, the Ld. CIT(A) restricted the addition to 6% of the purchase value, concluding that in cases where sales

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. With C.O.No.172/Ahd/2019 Asstt. Year 2010-11 20 22. The learned CIT(A) after considering the submission of the assessee deleted the addition made by the AO by observing as under: The appellant contended that the AO in Para 8.5.1 at Page No.24 of the assessment order has observed that "It is noticed that

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.

section 54 of the Act even on the amount invested by the assessee within a period of 3 years. Thus the AO has computed the long-term capital gain at Rs. 4,05,20,000.00 but made the addition of Rs. 2,48,49,050.00 after reducing the amount ( 1,56,70,950.00) already offered by the assessee

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

68,93,96,668/- instead of deleting the same in entirety. 50. There was a survey operation under section 133A of the Act dated 17th October 2013 at the premises of the assessee. In the course of survey operation, a diary marked as annexure AS-2 was found wherein the construction cost as on the date of survey

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

68,93,96,668/- instead of deleting the same in entirety. 50. There was a survey operation under section 133A of the Act dated 17th October 2013 at the premises of the assessee. In the course of survey operation, a diary marked as annexure AS-2 was found wherein the construction cost as on the date of survey

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

68,93,96,668/- instead of deleting the same in entirety. 50. There was a survey operation under section 133A of the Act dated 17th October 2013 at the premises of the assessee. In the course of survey operation, a diary marked as annexure AS-2 was found wherein the construction cost as on the date of survey

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

68,93,96,668/- instead of deleting the same in entirety. 50. There was a survey operation under section 133A of the Act dated 17th October 2013 at the premises of the assessee. In the course of survey operation, a diary marked as annexure AS-2 was found wherein the construction cost as on the date of survey

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 148 for the concerned assessment year 2010-11 so as to say that the case of the Respondent cannot be reopened on the strength of subject matter of reasons recorded by the Ld. AO as the reasons are based out of seized material so impounded from the premises of Barter Group relevant to A.Y. 2011-12 and thus

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. 20.2 The learned CIT(A) after considering the submission of the assessee deleted the addition made by the AO by observing as under: The appellant contended that the AO in Para 8.5.1 at Page No.24 of the assessment order has observed that "It is noticed that unaccounted cash receipt of various' projects and land

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

section 68 of the Act. 23. The learned CIT(A) after considering the submission of the assessee deleted the addition made by the AO by observing as under: The appellant firm has placed before me the said relevant page no.99. In respect of the unsecured loan received from Saral Management and Consultancy the AO had the details about their

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

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

68=87” actually represented Rs. 6,887/- and entries like “540=00” represented Rs. 54,000/-. The Assessing Officer further noted that each day’s entries were supported by cash vouchers which were kept in green and pink coloured envelopes. The green vouchers represented receipts of cash, while the pink vouchers represented expenditures or payments made. These vouchers were also

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

Bench: Shri Sanjay Garg & Makarand V. Mahadeokar

68=87” actually represented Rs. 6,887/- and entries like “540=00” represented Rs. 54,000/-. The Assessing Officer further noted that each day’s entries were supported by cash vouchers which were kept in green and pink coloured envelopes. The green vouchers represented receipts of cash, while the pink vouchers represented expenditures or payments made. These vouchers were also

PARTH DINESH PATEL,MEHSANA vs. THE INCOME TAX OFFICER, WARD-1,, PATAN

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.137/Ahd/2024 & 138/Ahd/2024 िनधा"रण वष" /Assessment Years : 2015-16 & 2016-17 Parth Dinesh Patel The Income Tax Officer बनाम/ 18/19, Utkarsh Society Ward-1, V/S. Opp. Market Yard Patan – 384 265 Tal. Visnagar, Mehsana Gujarat – 384 315 "थायी लेखा सं./Pan: Bwrpp 7811 A (अपीलाथ&/ Appellant) ('( यथ&/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 23/04/2025 घोषणा की तारीख /Date Of Pronouncement: 25/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: These Two Appeals Are Filed By The Assessee Against The Separate Orders Dated 01.12.2023 Passed By The Learned Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter Referred To As “Cit(A)”], Arising Out Of Reassessment Orders Framed Under Section 147 R.W.S. 144B Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], By The National Faceless Assessment Centre (Nfac), Delhi [Hereinafter Referred To As “Assessing Officer /Ao”] For The Assessment Years (Ays) 2015–16 & 2016–17, Respectively. As The Issues Involved In Both The Appeals Are Common

section 68 totalling to Rs.70,54,000/-, of which Rs.35,00,000/- pertained to amounts allegedly received through entities

YASH ASHITBHAI VASHI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1, INTERNATIONAL TAXATION, AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1476/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Yash Ashitbhai Vashi The Income Tax Officer बनाम/ E/1, Pranav Apartment Ward-1, V/S. Shreyas Tekra International Taxation Ambawadi Ahmedabad-380 014 Ahmedabad – 380 015 "थायी लेखा सं./Pan: Aiipv 9386 Q (अपीलाथ&/ Appellant) ('( यथ&/ Respondent) Assessee By : None (Written Submission) Revenue By : Shri Waghe Prasadrao, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24 /02/2025 घोषणा की तारीख /Date Of Pronouncement: 26 /02/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 54 of the Act mandates that the new property must be purchased in the name of the assessee to qualify for exemption. Although the assessee transferred ₹17,68

THE DCIT.CIRCLE-8,, AHMEDABAD vs. SHREE SANAND TEXTILE INDS.LTD.,, AHMEDABAD

In the result the appeal filed by the assessee is allowed and the appeal filed by the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed1. आयकर अपील सं./Ita No.995/Ahd/2014 With Co No.167/Ahd/2014 (In Ita No.1166/Ahd/2014) ("नधा"रण वष"/Assessment Year : 1995-96) Shree Sanand Textiles The Dy.Cit (Osd) बनाम/ Industries Ltd. Circle-8 Vs. 10-A, Sattar Taluka Society Ahmedabad B/H. C.U. Shah College Navjivan Press Road Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aamc 8881 G (Appellant & Cross Objector) .. (""यथ" / Respondent) & 2. आयकर अपील सं./Ita No.1166/Ahd/2014 ("नधा"रण वष"/Assessment Year : 1995-96) The Dcit Shree Sanand Textile बनाम/ Circle-8 Industries Ltd., Vs. Ahmedabad Ahmedabad .. (अपीलाथ"/Appellant) (""यथ" / Respondent) Assessee By : Shri Anil R.Shah, Shri Tushar Hemani & Ms.Kinjal Shah, Ars Revenue By : Shri Vidhut Trivedi, Sr.Dr

54,000). The appellant gets part relief.” Being aggrieved by the order of the learned CIT (A), both the assessee and the Revenue are in appeal before us. The assessee is in appeal before us against the confirmation of the addition for Rs.3,76,44,053/- on account of unexplained cash credit under section 68

SHREE SANAND TEXTILE INDUSTRIES LTD.,,AHMEDABAD vs. THE DY.CIT, (OSD), CIRCLE-8,, AHMEDABAD

In the result the appeal filed by the assessee is allowed and the appeal filed by the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed1. आयकर अपील सं./Ita No.995/Ahd/2014 With Co No.167/Ahd/2014 (In Ita No.1166/Ahd/2014) ("नधा"रण वष"/Assessment Year : 1995-96) Shree Sanand Textiles The Dy.Cit (Osd) बनाम/ Industries Ltd. Circle-8 Vs. 10-A, Sattar Taluka Society Ahmedabad B/H. C.U. Shah College Navjivan Press Road Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aamc 8881 G (Appellant & Cross Objector) .. (""यथ" / Respondent) & 2. आयकर अपील सं./Ita No.1166/Ahd/2014 ("नधा"रण वष"/Assessment Year : 1995-96) The Dcit Shree Sanand Textile बनाम/ Circle-8 Industries Ltd., Vs. Ahmedabad Ahmedabad .. (अपीलाथ"/Appellant) (""यथ" / Respondent) Assessee By : Shri Anil R.Shah, Shri Tushar Hemani & Ms.Kinjal Shah, Ars Revenue By : Shri Vidhut Trivedi, Sr.Dr

54,000). The appellant gets part relief.” Being aggrieved by the order of the learned CIT (A), both the assessee and the Revenue are in appeal before us. The assessee is in appeal before us against the confirmation of the addition for Rs.3,76,44,053/- on account of unexplained cash credit under section 68

PARTH DINESH PATEL,MEHSANA vs. THE INCOME TAX OFFICER, WARD-1,, PATAN

In the result, both the appeals of the assessee are allowed for statistical\npurposes

section 68\ntotalling to Rs.70,54,000/-, of which Rs.35,00,000/- pertained to amounts\nallegedly received through entities

NARENDRA CHANDUBHAI RAFALIYA,AHMEDABAD vs. ITO, WARD-3(3)(8), AHMEDABAD

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

68 of the Act amounting to " 63,58,700/- being the total amount of cash deposits made in the bank account held by the assessee. 5. In appeal, Ld. CIT(Appeals) give partial relief to the assessee and restricted addition under section 44AD of the Act to " 37,07,260/- (" I.T.A No. 103/Ahd/2019 A.Y. 2015-16 Page