DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

5 1501-2000 2,46,17,851 13,148 3.68% 69.98% 6 2001-3000 10,76,50,664 41,986 11.75% 8173% 7 3001-4000 15,96,18,534 45,288 12.67% 94.40% 8 4001-5000 2,15,47,954 4,563 1.28% 95.68% 9 5001-7000 6,07,52,130 10,521 2.94% 98.62% 10

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

5 1501-2000 2,46,17,851 13,148 3.68% 69.98% 6 2001-3000 10,76,50,664 41,986 11.75% 8173% 7 3001-4000 15,96,18,534 45,288 12.67% 94.40% 8 4001-5000 2,15,47,954 4,563 1.28% 95.68% 9 5001-7000 6,07,52,130 10,521 2.94% 98.62% 10

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

5 1501-2000 2,46,17,851 13,148 3.68% 69.98% 6 2001-3000 10,76,50,664 41,986 11.75% 8173% 7 3001-4000 15,96,18,534 45,288 12.67% 94.40% 8 4001-5000 2,15,47,954 4,563 1.28% 95.68% 9 5001-7000 6,07,52,130 10,521 2.94% 98.62% 10

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

5 1501-2000 2,46,17,851 13,148 3.68% 69.98% 6 2001-3000 10,76,50,664 41,986 11.75% 8173% 7 3001-4000 15,96,18,534 45,288 12.67% 94.40% 8 4001-5000 2,15,47,954 4,563 1.28% 95.68% 9 5001-7000 6,07,52,130 10,521 2.94% 98.62% 10

THE DCIT, CENTRAL CIRCLE-2(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is allowed

5-6c) 7 8 Interest Payable a For default in furnishing the return (section 8a 234A) b For default in payment of advance tax 8b (section 234B) c For deferment of advance tax (section 8c 234C) d Total Interest Payable (8a+8b+8c) 8d 9 Aggregate liability (7+8d) 9 10 Taxes Paid a Advance

THY ACIT, CIRCLE-2(1)(2), , AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

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

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

5 (?)(h) read with section 9 (l)(i) of Income Tax Act. 2.16. Regarding the issue of obtaining no deduction certificate under section 196 ii is seen that for the applicability of the provisions of this section, the sum must be chargeable under the provisions of the Income Tax Act. Section 195 provides for deduction of tax by the person

STATE BANK OF INDIA BHAVNAGAR PARA BRANCH,BHAVNAGAR vs. ITO TDS WARD 1, AHMEDABAD, AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

section 10(5) of the Income-tax Act ("the Act") while computing TDS under section 192 of the Act. During

STATE BANK OF INDIA BHAVNAGAR PARA BRANCH,BHAVNAGAR vs. ITO TDS WARD 1, AHMEDABAD, AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

section 10(5) of the Income-tax Act ("the Act") while computing TDS under section 192 of the Act. During

AAKASH PURSHOTTAMBHAI VAGHELA,VADODARA vs. THE ITO, TDS-1, VADODARA

In the result, the appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

section 201(1) and 201(1A) and consequently calculating amount payable u/s. 201(1) of Rs.22.661/- and interest u/s. 201(1A) of Rs.14,956/- Aakash Pursottambhai Vaghela vs. ITO Page 5 of 10 5. a) The Ld. CIT (Appeals)/Addl/JCIT (A) has erred in law and facts in confirming the action of the Ld. A.O. in holding that the appellant

THE DCIT, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P.INFRASTRUCTURE LTD., AHMEDABAD

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

TDS under Section 194 of the Act. The four directors of the appellant company namely Mr. Pvaveen T. Kotak, Mr. Jayesh T. Kotak, Mr. Jatin M. Gupta & Mr. Amit M. Gupta are the common and beneficial shareholder in the assessee company as well as subsidiary companies. The case of the Revenue is this that the payment by way of loans

THE ASSTT. COMMISSIONER OF INCOME TAX, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P. INFRASTRUCTURE LTD.),, AHMEDABAD

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

TDS under Section 194 of the Act. The four directors of the appellant company namely Mr. Pvaveen T. Kotak, Mr. Jayesh T. Kotak, Mr. Jatin M. Gupta & Mr. Amit M. Gupta are the common and beneficial shareholder in the assessee company as well as subsidiary companies. The case of the Revenue is this that the payment by way of loans

M/S. EDELWEISS BROKING LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(3), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

10 earn brokerage income therefrom. It was only an eventuality that some of the clients disowned only part of the transactions which under compulsion were to be taken by the assesses as its own. I Para 28]" ITA No.2021/Ahd/2017 & 1939/A/17 [M/s. Edelweiss Broking Ltd. vs. DCIT] A.Y. 2013-14 - 5 - 75.1 In view of the above, once it has been

DCIT, CIRCLE-1(3), , AHMEDABAD vs. EDELWEISS BROKING LTD.(ON BEHALF OF AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

10 earn brokerage income therefrom. It was only an eventuality that some of the clients disowned only part of the transactions which under compulsion were to be taken by the assesses as its own. I Para 28]" ITA No.2021/Ahd/2017 & 1939/A/17 [M/s. Edelweiss Broking Ltd. vs. DCIT] A.Y. 2013-14 - 5 - 75.1 In view of the above, once it has been

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

5. On the facts of the case as well as in law, learned CIT (A) grossly erred in confirming the impugned penalty order, which was passed without affording the appellant assessee a reasonable opportunity of being heard and the order has been passed in violation of the principles of natural justice. It is therefore prayed that the impugned order

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

5. On the facts of the case as well as in law, learned CIT (A) grossly erred in confirming the impugned penalty order, which was passed without affording the appellant assessee a reasonable opportunity of being heard and the order has been passed in violation of the principles of natural justice. It is therefore prayed that the impugned order

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

5. On the facts of the case as well as in law, learned CIT (A) grossly erred in confirming the impugned penalty order, which was passed without affording the appellant assessee a reasonable opportunity of being heard and the order has been passed in violation of the principles of natural justice. It is therefore prayed that the impugned order

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

5. On the facts of the case as well as in law, learned CIT (A) grossly erred in confirming the impugned penalty order, which was passed without affording the appellant assessee a reasonable opportunity of being heard and the order has been passed in violation of the principles of natural justice. It is therefore prayed that the impugned order

RAJENDRA MAGANBHAI PATEL,MUMBAI vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE INTERNATIONAL TAXATION, VADODARA

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.105/Ahd/2023 & 106/Ahd/2023 िनधा"रण वष" /Assessment Years : 2013-14 & 2015-16 Respectively Rajendra Maganbhai Patel The Asstt.Commissioner Of बनाम/ C-1/8, Bhadran Nagar Income Tax, Circle V/S. S.V. Road, Malad West International Taxation, Mumbai – 400 064 Vadodara Maharashtra "थायी लेखा सं./Pan: Asipp 5675 N (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Tushar Hemani, Sr.Advocate & Shri Parimalsinh N. Parmar, Ar Revenue By : Shri Prathvi Raj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 26 /02/2025 घोषणा की तारीख /Date Of Pronouncement: 04 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: Both These Appeals By The Assessee Pertain To Assessment Years (Ays) 2013-14 & 2015-16 & Are Directed Against The Final Assessment Orders Passed By The Assessing Officer [Hereinafter Referred To As “Ao”] Under Section 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], Pursuant To The Directions Of The Dispute Resolution Panel [Hereinafter Referred To As “Drp”]. The Core Issue In Both The Appeals Concerns The Addition Made By The Ao On Account Of Credits In The Assessee’S Non- Resident External (Nre) Bank Accounts.

5,62,67,313/- Rs. 14,36,26,449/- - TDS Return Payments to Rs. 9,50,243/- Rs. 10,47,988/- Non-Residents - Time Deposit with Banking Rs. 11,76,46,084/- NIL Co. - Credit Card Payments: Rs. 3,04,662/- Rs. 3,96,515/- Addition Proposed