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

150 and 206 of the Companies Act, 1956. 7. In view of the above, since there is no requirement of TDS in the present case under section 194 of the Income-tax Act, 1961, the assessee company cannot be held assessee in default under section 01 of the Income-tax Act, 1961. Thus, ground No.2 of the assessee is allowed

COSMOS ENGITECH PRIVATE LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(1), VADODARA, CIRCLE 1(1)(1), VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Tr Senthil Kumarcosmos Engitech Private Ltd., The Assistant Vs. Plot No.85/2, Cosmos House, Commissioner Padra Road, Atladara, Of Income Tax, Vadodara-380015. Circle-1(1)(1), Vadodara. [Pan :Aaacc7647 J] (Appellant) .. (Respondent) Appellant By : Shri Tej Shah, Ar Respondent By: Shri Rameshwar P Meena, Sr. Dr Date Of Hearing 11.11.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

TDS of Rs.8,730/-. During the year the assessee had claimed sales promotion expenses of Rs.61,975/- and sales commission expenses of Rs.9,54,524/-. However, during the assessment proceedings the assessee had not furnished any details despite being specifically asked vide notice u/s 142(1) dated 08.10.2019, 07.11.2019 and 15.06.2019. Subsequently, the Assessing Officer completed the assessment

M/S. EDELWEISS BROKING LTD. ( AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.),AHMEDABAD vs. THE JT. CIT, RANGE-3,, AHMEDABAD

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

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

Section 32 of the Act provides for depreciation in respect of buildings, machinery, plant or furniture owned by an assessee and used for the purposes of the business or profession. Under this section, for getting depreciation, the following two conditions should be satisfied: (i) The asset in question should be owned by the assessee; and (ii) The asset should

THE DCIT, CIRCLE-1(3), AHMEDABAD vs. EDELWEISS BROKING LTD., AHMEDABAD

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

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

Section 32 of the Act provides for depreciation in respect of buildings, machinery, plant or furniture owned by an assessee and used for the purposes of the business or profession. Under this section, for getting depreciation, the following two conditions should be satisfied: (i) The asset in question should be owned by the assessee; and (ii) The asset should

THE DCIT, CIRCLE-1(3), AHMEDABAD vs. EDELWEISS FINANCIAL ADVISORS LTD., ( FORMERLY KNOWN ANAGRAM STOCK BROKING LTD.,), AHMEDABAD

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

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

Section 32 of the Act provides for depreciation in respect of buildings, machinery, plant or furniture owned by an assessee and used for the purposes of the business or profession. Under this section, for getting depreciation, the following two conditions should be satisfied: (i) The asset in question should be owned by the assessee; and (ii) The asset should

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

SANKALP RECREATION PRIVATE LIMITED,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

TDS provisions, etc. and the assessee has not provided the details of expenses which will determine whether they are incurred wholly and exclusively incurred for the purpose of business, whether they are of capital nature or revenue and therefore, such expenses incurred in violation of the provisions cannot be allowed as a deduction under Section 37(1

THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. SANKALP RECREATION PVT. LTD., AHMEDABAD

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar

TDS provisions, etc. and the assessee has not provided the details of expenses which will determine whether they are incurred wholly and exclusively incurred for the purpose of business, whether they are of capital nature or revenue and therefore, such expenses incurred in violation of the provisions cannot be allowed as a deduction under Section 37(1

TORRENT POWER LTD.,,AHMEDABAD vs. THE ACIT.,RANGE-8,, AHMEDABAD

In the result cross objection filed by the assessee is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 80-IA of the Act. 69. The learned CIT (A) disregarded the contention of the assessee by observing that the impugned income does not have nexus with the distribution of power activity of the assessee. Thus the learned CIT (A) upheld the finding of the AO. 70. Being aggrieved by the order of the learned CIT (A), the assessee

LAKHI ELECTRONICS PVT. LTD.,AHMEDABAD vs. ITO, WARD-2(1)(3), AHMEDABAD

In the result, this ground of appeal of the assessee is allowed for statistical purposes

150/-. Since it was mistake apparent on record, the assessee has applied for rectification u/s. 154 vide dated 11th July, 2016. The Assessing Officer had rejected the application u/s. 154 on the ground that application of rectification of the assessee was time barred. In this regard, we observed that ld. CIT(A) has not considered the aforesaid material facts reported

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section 271(1)(c) of the Act. (3) The ld. CIT(A) ought to have upheld

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. THE ACIT.,(OSD) RANGE-1,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section 271(1)(c) of the Act. (3) The ld. CIT(A) ought to have upheld

THE DCIT(OSD)RANGE-1,, AHMEDABAD vs. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section 271(1)(c) of the Act. (3) The ld. CIT(A) ought to have upheld

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section 271(1)(c) of the Act. (3) The ld. CIT(A) ought to have upheld

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT. LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section 271(1)(c) of the Act. (3) The ld. CIT(A) ought to have upheld