DILIPKUMAR BABABHAI ZAVERI,PATAN, GUJARAT vs. PCIT, AHMEDABAD

In the result, the appeal of the assessee is dismissed

section 263 along with Explanation-1(b) is reproduced\nhereunder:\n263. (1) The Principal Chief Commissioner or Chief Commissioner or\nPrincipal Commissioner or Commissioner may call for and examine the\nrecord of any proceeding under this Act, and if he considers that any order\npassed therein by the Assessing Officer 81a[or the Transfer Pricing

MEHAAN ENTERPRISE,AHMEDABAD vs. THE PCIT, CENTRAL, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

Section 263 of the Act read as under:- “Revision of orders prejudicial to revenue. 263. (1) The Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer or the Transfer Pricing

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

263 of the Act passed by the Ld. PCIT. ITA Nos.1052 to 1054/Ahd/2025 Asst. Years 2017-18 to 2020-21 7 8. From the digital images found and seized from the mobile phone of Shri Suresh R Thakkar, it transpired that he had brokered a deal for Shri Rajeshbhai Brahmbhatt and Smt. Arunaben Kishorkumar Zhaveri (the assessee) for sale

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

263 of the Act passed by the Ld. PCIT. ITA Nos.1052 to 1054/Ahd/2025 Asst. Years 2017-18 to 2020-21 7 8. From the digital images found and seized from the mobile phone of Shri Suresh R Thakkar, it transpired that he had brokered a deal for Shri Rajeshbhai Brahmbhatt and Smt. Arunaben Kishorkumar Zhaveri (the assessee) for sale

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

263 of the Act passed by the Ld. PCIT. ITA Nos.1052 to 1054/Ahd/2025 Asst. Years 2017-18 to 2020-21 7 8. From the digital images found and seized from the mobile phone of Shri Suresh R Thakkar, it transpired that he had brokered a deal for Shri Rajeshbhai Brahmbhatt and Smt. Arunaben Kishorkumar Zhaveri (the assessee) for sale

JIGNASA ATULKUMAR SHAH,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 263 provides as follows: I.T.A No. 1140/Ahd/2025 A.Y. 2018-19 Page No 6 Jignasa Atulkumar Shah vs. PR.CIT “Revision of orders prejudicial to revenue 263: (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may call for and examine the record at any proceeding under this Act, and if he considers that any order passed

GFL LIMITED (EARLIER KNOWN AS GUJARAT FLUOROCHEMICALS LTD.),VADODARA vs. THE PR. CIT-1, VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

Section 263. It was further submitted before us that the disallowance of ₹4,03,67,698/- forms part of the total transfer pricing

OVEZ ARIFBHAI LAKHANI,BHAVNAGAR vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Income Tax Appellate Tribunal, Ahmedabad Benches, Has Arisen From The Revisionary Order Dated 12.03.2024 Passed By Ld. Principal

transferred 1000 shares in financial year 2011-12 itself, and the remaining shares were held in demat account . The remaining 18400 shares of KDJHRL were sold in the financial year 2013-14 i.e. impugned assessment year The assessee submitted before the AO during reassessment proceedings bank statements, cross ledger of M/s Prabhudas Liladhar Private Limited and ledger accounts

D S TRADING,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

transfer pricing report and assessee's argument appeared to be a desperate measure to somehow increase its NCPM - Whether if in order to avoid any sealing assessee decided to shift its office premise to a commercial area and in that process incurred aforesaid abnormal expenses, rejection of assessee's claim towards comparability adjustment on ground that its premises

NAVIN KALIDAS PATEL,AHMEDABAD vs. THE PR. CIT-3, AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 109/Ahd/2021 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2015-16) िनधा"रण वष" िनधा"रण वष" बनाम बनाम/ बनाम बनाम Navin Kalidas Patel The Pr.Cit-3 802, Block –A, Status Ahmedabad Vs. Appartment, Opp. T. V. Tower, Drive-In-Road, Ahmedabad, Gujarat, 380054 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Achpp0215B (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri S. N. Soparkar, Sr. Advocate & Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Shri Sudhendu Das, Cit. Dr Date Of Hearing 05/08/2024 Date Of Pronouncement 14/08/2024 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, Ahmedabad-3, (In Short ‘The Pr. Cit’) Dated 29.03.2021 In Exercise Of His Revisionary Power Under Section 263 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The Assessment Year 2015-16. 2. The Brief Facts Of The Case Are That The Return Of Income For A.Y. 2015-16 Was Filed By The Assessee On 25.01.2016 Showing Total Income Of Rs.2,03,730/-. The Case Was Selected For Scrutiny

263 of the Act, which is found as under: Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3[or the Transfer Pricing

AXIS BANK LIMITED,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is partly allowed for statistical purposes

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2018-19 Axis Bank Limited, Vs. Assistant Commissioner Of “Trishul”, 3Rd Floor, Opp. Income-Tax, Samartheshwar Temple, Nr. Law Circle 1(1)(1), Garden, Ellisbridge, Ahmedabad Ahmedabad-380006 Pan : Aaacu 2414 K अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.11.2023/03.04.2024 घोषणा क" तारीख /Date Of Pronouncement: 10.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: By Way Of This Appeal, The Assessee-Appellant Has Challenged Correctness Of The Order Dated 28Th July, 2022 Passed By The Assessing Officer Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act” For Short], For The Assessment Year (Ay) 2018-19. 2. Ground No.1 Raised By The Assessee Reads As Under:- “1. Disallowance In Respect Of Annual Technical Fees (Tax Effect - Rs. 16,84,276) 1.1 The Learned Drp Has Erred In Upholding Addition Made By Ao In Respect Of Treating Annual Technical Services (Ats) Fees Paid To Infosys Limited To The Extent Of Rs. 48.66 Lacs As Prior Period Expense. 1.2. It Is Submitted That The Expenditure Relates To Amount Payable To Infosys & No Part Of The Amount Was Claimed As Expenditure At Any Time In The 2 Axis Bank Limited Vs. Acit Ay : 2018-19

263 October 4,500 5,048 4,774 November 5,048 4,845 4,947 December 4,845 4,682 4,764 January 4,682 4,721 4,702 February 4,721 5,286 5,004 March 5,286 5,421 5,354 Total 53,546 Annual Average of Monthly Average tax free investments (April 17 to March

J vs. INDUSTRIES PVT. LTD.,VADODARAVS.THE PR. CIT, VADODARA-1, VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

transfer has to be done in prescribed manner i.e. FMV as per rule 11UAE shall be deemed as full value of consideration. Further, As per sub section 3 of section 50B of income tax Act Every assessee in the case of slump sale is required to furnish a report of accountant as defined in the explanation below sub section

MADHYA GUJARAT VIJ COMPANY LTD.,,VADODARA vs. THE PR. COMMISSIONER OF INCOME TAX, -2,, VADODARA

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2013-14 Madhya Gujarat Vij Co. Ltd., The Principal Commissioner Of Vs. Sardar Patel Vidyut Bhavan, Income-Tax-2, Race Course, Vadodara-390007 Vadodara Pan : Aadcm 7439 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Mehul K. Patel, Advocate Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.01.2024 घोषणा क" तारीख /Date Of Pronouncement: 02.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Vadodara-2 [Herein-After Referred To As “Pcit”] Dated 27.03.2019, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2013-14. 2. The Grounds Raised By The Assessee Are As Under:- “(1) That On Facts & In Law, The Learned Cit Has Grievously Erred In Assuming Jurisdiction U/S.263 Of The Act, Without Recording A Satisfaction As To How The Assessment Order Passed U/S 143(3) Of The Act Is Erroneous & Prejudicial To The Interest Of Revenue. (2) That On Facts & In Law, The Proceedings U/S.263 Are Void As The Original Assessment Order Was Passed U/S.143 (3) Of The Act After Due Inquiry & Application Of Mind / & Is Not Erroneous & Prejudicial To The Interest Of The Revenue.

Section 263 itself is very clearly worded as under: “263. (1) The [Principal Chief Commissioner or Chief Commissioner or Principal Commissioner] or Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer [or the Transfer Pricing

A MENARINI INDIA PVT. LTD.,AHMEDABAD vs. THE PCIT-1, AHMEDABAD

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

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Price on the basis of the amendment introduced in Section 263 by Finance Act, 2022 with effect from 01/04/2022 which is not applicable to the A.Y. 2018-19. 9. The appellant prays that an interim relief restraining the Assessing Officer and also the Transfer

THE VARDHMAN STAMPINGS PVT. LTD.,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD

In the result, both the appeals of the assessee are allowed

transfer of the commodity or scrips:\nProvided that for the purposes of this clause-\n(α)\n(b)\n(c)\n[(d)\n87 [(e)\na contract in respect of raw materials or merchandise entered into by a person in the course\nof his manufacturing or merchanting business to guard against loss through future price\nfluctuations in respect of his contracts

ANKIT PRANLAL PATEL,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

263 of the Act, which is found as under: Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3[or the Transfer Pricing

SHRIKANTSINGH RAMDAYAL SHAKYA,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

263 of the Act, which is found as under: Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3[or the Transfer Pricing

WILSON MIKHAEL TOPNO,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

263 of the Act, which is found as under: Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3[or the Transfer Pricing

BHARATSINGH AMARSINGH RAJPUT,BHARATPUR vs. THE PCIT, VADODARA-1, VADODARA

In the result, the appeal filed by all the nine assessees is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

263 of the Act, which is found as under: Explanation 2.—For the purposes of this section, it is hereby declared that an order passed by the Assessing Officer 3[or the Transfer Pricing