Gujarat Mineral Development Corporation Ltd., Ahmedabad vs. The Dy.CIT, Circle-4, Now Circle-2(1)(1), Ahmedabad
The appeal of the assessee is partly allowed
ITA 1657/AHD/2015[2005-06]Status: DisposedITAT Ahmedabad30 Nov 2022AY 2005-06
Bench: Smt.Annapurna Gupta & T.R. Senthil Kumar & Asstt.Year: 2005-06 Gujarat Mineral Development Dcit/Jcit, Cir.4 Corporation Ltd. Vs Ahmedabad. “Khanji Bhavan” 132Ft Ring Road University Ground, Ahmedabad. Asstt.Year: 2005-06 Dcit/Jcit, Cir.4 Gujarat Mineral Development Ahmedabad. Vs Corporation Ltd. “Khanji Bhavan” 132Ft Ring Road University Ground, Ahmedabad. (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, With Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar Revenue By : Shri James Kurian, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 30/08/2022 घोषणा क" तार"ख /Date Of Pronouncement: 30/11/2022 आदेश/O R D E R Per Annapurna Guptathe Present Appeals Relate To The Same Assessee, Pertain To The Same Assessment Year & Are Against Orders Passed By The
For Respondent: Shri James Kurian, CIT-DR
Section 143(3)Section 250(6)Section 271(1)(c)
…circumstances, the impugned income is required to be taxed in the hands of the appellant for the relevant period. In this regard reliance is placed on the decision of Hon'ble Delhi High Court in the case of Saraswati Insurance Company Ltd Vs. CIT reported in 252 ITR 430. The relevant extracts of the decision are as under: ITA No.1747/A/2009, 1657 and 1471/A/2015 24 "The assessee-company had advanced certain loans to its subsidiary company on interest at the rate of 12 per cent, per annum. Interest income was included in the total income of the assessee. For the assessment years 1977-78 and 1978-79, the assesse…