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 68 of the Act primarily on the basis of certain affidavits found during search and enquiries conducted by the Investigation Wing. Further, on the basis of entries in a seized Excel file, the Assessing Officer made an addition of Rs.5,00,000/- u/s 69C treating the same as unexplained expenditure. 6

EAGLE STEEL INDUSTRIES PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, AHMEDABAD

In the result, appeal filed by the Assessee is allowed

Bench: Shri P. K. Kedia & Shri Mahavir Prasad)

6. Write "Z" if no deduction is on account of payment being notified under section 197A(1F). 7. List of section codes is as under: It was also stated by the assessee that the details of non deduction of tax had been revised by the assessee in the TDS return during the current F.Y. i.e. 2014-15. However

ITO WARD-4(1)(4),, AHMEDABAD vs. VALLEY COMTRADE PVT LTD ( EARLIER KNOWN AS JHAWAR COMTRADE PVT. LTD.,), AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 2034/Ahd/2017 िनधा"रण वष"/Asstt. Year:2012-2013 I.T.O, M/S. Valley Comtrade Pvt. Ltd., Ward-4(1)(4), Vs. (Earlier Known As Jhawar Comtrade Ahmedabad. Pvt. Ltd.,) C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N & आयकर अपील सं./Ita No. 68/Srt/2017 िनधा"रण वष"/Asstt. Year:2012-2013 M/S. Valley Comtrade Pvt. Ltd., I.T.O, (Earlier Known As Jhawar Comtrade Vs. Ward-1(1)(3), Pvt. Ltd.,) Surat. C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N

section 68 of the Act and added the same to the total income of the assessee. 5. Aggrieved assessee preferred an appeal to the learned CIT-A. 6

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 6 can be made, as per settled judicial position. It was further submitted that even otherwise, there

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.

6. Yamini Marketing has paid first installment of tax of Rs 4,45,00,000/-on 28.11.2016. Therefore, the income declared by Yamini Marketing P Ltd justifies the identity, genuineness and credit worthiness on their part, as per provisions of section 68

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 of the Act. Thus the onus has been shifted upon the revenue to disprove the contention of the assessee and that too based on the cogent materials. It is also pertinent to note that the AO has not carried out any exercise by resorting to the provisions of section 133(6

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 of the Act. Thus the onus has been shifted upon the revenue to disprove the contention of the assessee and that too based on the cogent materials. It is also pertinent to note that the AO has not carried out any exercise by resorting to the provisions of section 133(6

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 of the Act. Thus the onus has been shifted upon the revenue to disprove the contention of the assessee and that too based on the cogent materials. It is also pertinent to note that the AO has not carried out any exercise by resorting to the provisions of section 133(6

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 of the Act. Thus the onus has been shifted upon the revenue to disprove the contention of the assessee and that too based on the cogent materials. It is also pertinent to note that the AO has not carried out any exercise by resorting to the provisions of section 133(6

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 ...

6) of the Act to the Branch\nManager of the ICICI Bank Ltd. The AO proceeded to complete\nthe reassessment ex-parte on 13.12.2017. In the reassessment\norder, the Assessing Officer made a substantive addition of\nRs.16,94,93,035/- under section 68

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

6 assessment years. This question has been answered by the jurisdictional ITAT in the case of Shaialesh S Patel vs. ITO reported in 97 taxmann.com 570 wherein it was held as under: With C.O.No.170/Ahd/2019 Asstt. Year 2010-11 11 The overriding provisions of section 153C merely enables the Assessing Officer to set aside the pending reassessment proceedings

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

6) there is no justification for applying Section 41(1) since CIT(A), ultimately in his appeal order is para 5.6 has applied the aforesaid Section. In para 5.20, it is held that the assessee has not established genuineness on the unsecured loans even though stated by the assessee that the unsecured loans carried forward from

THE DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S. SARTHAV BUILDERS, AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 908/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Sarthav Builders, Central Circle-1(2), Vs. B-1, Abhishree Complex, Ahmedabad. Opp. Star Bazar, Satellite, Ahmedabad. Pan: Abffs3812C

section 68 of the Act by making the addition to the total income of the assessee. Asstt. Year 2010-11 5 5. Aggrieved assessee preferred an appeal to the learned CIT-A. 6

SHRI UMIYA COOPERATIVE CREDIT SOCIETY LTD. ,1, SENETARY ROAD , KUTCHHI PATIDAR VADI, PETLAD TAL. PETLAD DIST. ANAND vs. INCOME TAX OFFICER, WARD-1(3)(1), PETLAD

In the result, Ground No. 2 of the assessee’s appeal is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

6– 9. In the result, Ground No. 1 of the assessee’s appeal is allowed for statistical purposes. Ground No.2:- Addition of Rs. 1,06,47,500/- under Section 68

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

6. On the other hand, the learned DR submitted that the proceedings under section 153C of the Act can be initiated by the AO if, there was any document found during the search proceedings at the premises of the 3rd party pertaining/belonging to the assessee. As such, there was no document found in the search proceedings pertaining/belonging

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 of the Act is deleted. Hence, Ground No. 1 is allowed.” ITA Nos. 418&419/Ahd/2023 ACIT vs. Mayora India Pvt. Ltd. Asst. Years –2017-18 & 2018-19 - 4– 5. The Department is in appeal before us against the aforesaid order passed by Ld. CIT(A). 6

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 of the Act is deleted. Hence, Ground No. 1 is allowed.” ITA Nos. 418&419/Ahd/2023 ACIT vs. Mayora India Pvt. Ltd. Asst. Years –2017-18 & 2018-19 - 4– 5. The Department is in appeal before us against the aforesaid order passed by Ld. CIT(A). 6

AMARPADMA CREDITS PRIVATE LIMITED,JODHPUR vs. THE INCOME TAX OFFICER, WARD-1(1)(1), AHMEDABAD

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

Bench: MRS. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

68 read with section 115BBE of the Act is found correct and accordingly ground of appeal No.3 is dismissed.” 5 Amarpadma Credits Pvt Ltd Vs. ITO AY : 2017-18 6