JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

TDS was not deducted as per the provision. U/S 14A for Expenses The AO disallowed expenses that were related related to Exempt Income to income exempt from tax under Section 14A. The CIT(A) deleted the disallowance for certain years, finding insufficient grounds for the AO’s action in those cases. ITA No.2815/Ahd/2011 and other 17 appeals JMC Projects (India

NIRMA LIMITED,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1) NOW DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

Appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2013-14 Nirma Limited, The Dy. Commissioner Of Vs. Nirma House, Ashram Road, Income-Tax, Ahmedabad-380 009 Circle-3(1)(1), Pan : Aaacn 5350 K Ahmedabad-380009 अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Sanjay Kumar, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 11.07.2024 घोषणा क" तारीख /Date Of Pronouncement: 09.10.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-12, Ahmedabad [Hereinafter Referred To As "Cit(A)" For Short] Dated 10.04.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2013-14. 2. The Effective Ground Raised By The Assessee Is As Follows:-

TDS credit, But 244A interest is not calculated although agreed to in order 11.06:2018 34-35 Rectification application by Assessee to correct error in order of 15.03.2018 and 21.09.2017 1. Interest u/s 244A(l)(b) on refund due from Jan 17 (Assessment order) to October 17(date of part refund]; 2. Interest u/s 244A(1A) on refund from April

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated

DEPUTY COMMISSIONER OF INCOME -TAX, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1) , AHMEDABAD, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated

PRAKASH MISRIMAL SANGHVI,AHMEDABAD vs. DCIT CC (1) AHMEDABAD, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated

PRAKASH MISRIMAL SANGHVI,AHMEDABAD vs. DCIT CC 1(1) AHMEDABAD, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

153A of the Act in the absence of any asset, the Ld. CIT-DR submitted that this issue was considered by the Ld. CIT(A) and dealt properly in his order. He, therefore, placed reliance on the order of the Ld. CIT(A) in this regard. On the third issue of proceeding initiated