The ACIT, Circle-5, Ahmedabad vs. Nirma Chemicals Works Pvt.Ltd., Ahmedabad
In the result appeal of the revenue is dismissed
ITA 1600/AHD/2013[2009-10]Status: DisposedITAT Ahmedabad24 Feb 2022AY 2009-10
Bench: Shri Rajpal Yadav & Shri Waseem Ahmed
For Appellant: Shri S.N. Soparkar, Sr. Advocate with Shri Parin Shah, A.RFor Respondent: Shri Vijaykumar Jaiswal, CIT, D.R
Section 143(3)Section 14A
…o be allowed as the A.O, has not established nexus between borrowings and tendings by the assessee company to the subsidiary company. Further reliance in this regard is placed on the following case laws. (i) Raj Vikas Quaries and Ind. P.Ltd. v/s. ACI.T (1992) 42 TTJ 262 (ii) United Agencies V/s. ITO (1990) 37 TTJ 374 (Ahd.) (iii) CIT v/s.Dhampur Sugar Mills Ltd (2006) 1,48 Taxman 321 (All.) (iv) CIT v/s.Radico Khaitan Ltd. 274 ITR 354 (All.) ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 21 It will also be pertinent to note here that the Ld A.O. in this regard had placed reliance on the case of CIT vs Abhishek…