SHELL & PEARL PORCELLANO LIMITED,,AHMEDABAD vs. THE ITO, WARD-4(1)(3),, AHMEDABAD

(Assessment Year: 2012-13) Shell & Pearl Porcellano Limited, Vs. The Income Tax Officer, 207, Sarthik-II, Ward-4(1)(3), Opp. Rajpath Club, Ahmedabad. S.G Highway, Ahmedabad-380054. [PAN No.AAGCS2593B] (Appellant) .. (Respondent) Appellant by : Shri Firoj Bodla, AR Respondent by: Shri AP Singh, CIT. DR 16.01.2025 Date of Hearing Date of Pronouncement 17.01.2025 O R D E R PER: DR. BRR KUMAR, VICE PRESIDENT: This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals)-8, Ahmedabad vide order dated 10.10.2017 passed for the Assessment Year 2012-13.

1) The Hon’ble CIT-A erred in law and on facts in confirming disallowance of Rs. 3,27,22,000/- on account of bad debts written off which were relating to the business of the appellant and hence the same addition to total income be deleted now. 2) The Hon’ble CIT-A erred in law and on facts in confirming addition of expenses of Rs. 6,29,371/- treating them as prior period expenses and hence the same addition to total income be deleted now.

Asst.Year –2012-13 - 2– 3) The Hon’ble CIT-A erred in law and on facts in confirming disallowance of additional depreciation on electrification charges which were part of cost of plant & machinery. The disallowance is without any base and justification and hence the same be allowed now. 4) The Hon’ble CIT-A has erred in law and on facts in confirming addition of Rs. 1,93,835/- in respect of interest income on the basis of Form 26AS and as shown in P & L Account though the company had fully offered interest to the income tax. The addition is without any base and justification and hence the same be deleted now. 5) The Hon’ble CIT-A has erred in law and on facts in confirming disallowance of interest expenses of Rs. 2,44,50,181/- on the ground that such expenses ought to have been capitalized under section 36(1)(iii). The addition confirmed by the Hon’ble CIT-A being without regard to the provisions of the section 36(1) (iii) and other applicable provisions of the Income Tax Act, 1961 and without any base and justification and hence the same be deleted now. 6) The Hon’ble CIT-A has erred in law and on facts in confirming addition of Rs. 1,08,61,405/- under section 41(1) and hence the same addition to total income be deleted now.