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Assessment Framed Pursuant to Quashed Section 263 Order Held Void Ab Initio; Revenue Appeal and Assessee Cross-Objection Dismissed as Infructuous: ACIT vs. Linde Engineering Pvt. Ltd. (ITAT Ahmedabad)
Facts of the CaseThe Revenue filed an appeal for Assessment Year 2011-12
against the order dated 20.08.2025 passed by the Commissioner of Income Tax
(Appeals), Ahmedabad-13, wherein the CIT(A) deleted disallowance of d...
TDS credit follows the PAN on TDS / 26AS - not merely who offers the income, ITAT Ahmedabad in Jerambhai Ratnabhai Patel vs. CPC Bangalore & ITO Ward-5(1)(2), Ahmedabad
In the case of Jerambhai Ratnabhai Patel v. Central Processing
Unit (ITAT Ahmedabad, AY 2022-23, order dated 09.01.2026), the assessee sought
TDS credit from the sale of property based on an unregistered family
arrang...
Ex-Parte Appellate Order Set Aside for Violation of Natural Justice and Non-Adjudication on Merits: Aatash Norcontrol Ltd. vs. DCIT (ITAT Ahmedabad)
Facts of
the CaseThe
assessee, Aatash Norcontrol Limited, filed its appeal for Assessment Year
2019-20 against the order dated 15.09.2025 passed by the Commissioner of Income
Tax (Appeals), National Faceless Appeal C...
Deduction under Section 43B Allowed for Gratuity Actually Paid on Employee Discontinuation Where Documentary Evidence Was On Record: True Sparrow Systems Pvt. Ltd. vs. DCIT (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, True Sparrow Systems Private Limited, filed its return of income for
Assessment Year 2021-22. During assessment, the Assessing Officer disallowed
₹11,84,163 claimed as deduction under...
Unsecured Loans from NRIs and Family Members Held Genuine Despite Absence of Loan Agreement or Interest: Section 68 Addition Deleted – Sabbirbhai Abdeali Gangardiwala vs. ITO (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, Sabbirbhai Abdeali Gangardiwala, was assessed for Assessment Year
2019-20. During the assessment proceedings, the Assessing Officer made an
addition of ₹39,00,000 under Section 68 of ...
Reopening of Assessment on Same Transaction Held Void – Change of Opinion Not Permissible”
The Delhi
High Court quashed the second reassessment notices issued under Section 148 for
AY 2009–10, holding them to be without jurisdiction and based on mere change of
opinion. The issue of interest-free loans rec...
Appeal Against Revision under Section 263 Dismissed as Withdrawn on Assessee’s Request: Nimbus Commercial Pvt. Ltd. vs. Pr. CIT (Central) (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, Nimbus Commercial Private Limited, Kolkata, filed an appeal before
the Income Tax Appellate Tribunal against the order dated 25.03.2025 passed by
the Principal Commissioner of Income Ta...
Adjustment under Section 143(1) on Income from House Property Set Aside Where Issue Requires Factual Verification of Co-Ownership: Kapila Mahendra Patel vs. DCIT (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, Kapila Mahendra Patel, an individual deriving income from house
property, capital gains and other sources, filed her return of income for
Assessment Year 2024-25 on 21.07.2024 declaring...
Orders Set Aside Where CIT(A) Interchanged Facts of Two Assessment Years Demonstrating Complete Non-Application of Mind: Precision Infratech Pvt. Ltd. vs. DCIT (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, Precision Infratech Private Limited, filed two appeals before the
Income Tax Appellate Tribunal against separate orders dated 07.10.2025 passed
by the National Faceless Appeal Centre fo...
Interest under Section 234A Leviable on Delay in Filing Original Return Even After Search Assessment under Section 153C: Hasmukhbhai Mohanlal Shah vs. DCIT (ITAT Ahmedabad)
Facts
of the CaseThe
assessee, Hasmukhbhai Mohanlal Shah, filed his original return of income for
Assessment Year 2017-18 on 29.11.2017 declaring total income of ₹27,35,910.
Subsequently, a search and seizure actio...