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24 results for “TDS”+ Section 197clear

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Key Topics

Section 143(3)27Section 145(3)18Disallowance16Addition to Income15Section 2509Section 14A9Section 1478Section 1487Section 143(2)7Section 263

JYOTI LIMITED,,VADODARA vs. DCIT,(INTERNATIONAL TAXATION), , BARODA

In the result, the appeal filed by the assessee is allowed

ITA 666/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad22 Mar 2021AY 2014-15

Bench: Shri Pradip Kumar Kedia& Ms. Madhumita Roy

For Appellant: ShriManish Shah, ARFor Respondent: ShriR. K. Makwana, SR. DR
Section 201Section 206A

TDS @ 20%, DTAA would override the provision of this particular domestic Act since the provision of DTAA are more beneficial to the assessee.In this regard we have considered the Article 12 of DTAA which prescribes such rate of tax to be deducted @ 10%. 7. We have considered the Section 206AA of the Income Tax Act which reads as follows

SHRI SANDEEP JAGDISHCHANDRA DAVE,,AHMEDABAD vs. TEH PR. CIT -3, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Showing 1–20 of 24 · Page 1 of 2

6
Reassessment6
Depreciation5
ITA 176/AHD/2020[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Dipen Shukhadia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R
Section 143(3)Section 197Section 263Section 36(1)(va)

Section 197 for NIL or lower rate of TDS) it is seen that the sum was neither produce before the Assessing

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

ITA 2683/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad15 Jun 2022AY 2012-13

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10BSection 143(3)Section 92E

197 (Delhi), ITA No. 4405(Del)/2009 order dated 24.12.2010: "4.2. The second ground is that the position should be seen as a whole with respect to all the transactions and not only with respect to the disputed transactions. In other words, if transfer pricing study is made for all the transactions, the variation made by the AO would

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

ITA 2682/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad15 Jun 2022AY 2011-12

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10BSection 143(3)Section 92E

197 (Delhi), ITA No. 4405(Del)/2009 order dated 24.12.2010: "4.2. The second ground is that the position should be seen as a whole with respect to all the transactions and not only with respect to the disputed transactions. In other words, if transfer pricing study is made for all the transactions, the variation made by the AO would

ROTOMAG MOTORS & CONTROLS (P) LTD.,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

Appeal is allowed

ITA 796/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad09 Sept 2025AY 2014-15
Section 143(3)Section 14ASection 195Section 271(1)(c)Section 36(1)(va)Section 37(1)Section 40

TDS was deducted, the AO invoked section 40(a)(i)\nand disallowed Rs.1,42,197/-.\nBefore the AO, the assessee

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

ITA 776/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad08 Dec 2021AY 2008-09

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Vinod Tanwani, CIT.D.R
Section 143(3)Section 254

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

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

In the result, the appeal filed by the assessee is allowed

ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

TDS. The Appellant prays that the aforesaid addition be deleted 3 On the facts and circumstances of the case and m law the Ld. AO under the directions of Hon’ble DRP erred in disallowing devaluation of inventory amounting to Rs. 1,40,79,555. While making this addition the Ld. AO erred in law and on facts

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

In the result, the appeal filed by the assessee is allowed

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

TDS. The Appellant prays that the aforesaid addition be deleted 3 On the facts and circumstances of the case and m law the Ld. AO under the directions of Hon’ble DRP erred in disallowing devaluation of inventory amounting to Rs. 1,40,79,555. While making this addition the Ld. AO erred in law and on facts

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, (INTL.TAXA)-1, AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 711/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad09 Sept 2022AY 2013-14
For Appellant: Shri Mukesh Patel, A.R. &For Respondent: Shri Atul Pandey, Sr. D.R
Section 250

TDS u/s 195 of IT Act, 1961 on payment made to Cliantha Research Mexico, Mexica for technical services during F.Y. 2012-13. The order of the A.O. is upheld. As a result, this ground of appeal of the appellant is dismissed.” 9. Both the Department and the assessee are in appeal against the aforesaid order of Ld. CIT(Appeals) before

ACIT, (INT. TAXA)-1, AHMEDABAD vs. CADILA HEALTHCARE LTD., AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 1140/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad09 Sept 2022AY 2013-14
For Appellant: Shri Mukesh Patel, A.R. &For Respondent: Shri Atul Pandey, Sr. D.R
Section 250

TDS u/s 195 of IT Act, 1961 on payment made to Cliantha Research Mexico, Mexica for technical services during F.Y. 2012-13. The order of the A.O. is upheld. As a result, this ground of appeal of the appellant is dismissed.” 9. Both the Department and the assessee are in appeal against the aforesaid order of Ld. CIT(Appeals) before

INCOME TAX OFFICER, WARD-1(3)(1), AHMEDABAD, AHMEDABAD vs. RAJESHKUMAR RAMESHCHANDRA SHAH, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

ITA 1074/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad04 Sept 2025AY 2017-18

Bench: SHRI SANJAY GARG (Judicial Member), SMT. ANNAPURNA GUPTA (Accountant Member)

For Appellant: Shri Alpesh Parmar, CIT. DRFor Respondent: Shri Tushar Hemani, Sr. Advocate &
Section 250Section 68

197 DTR 121, decided on 17th of November, 2020, ITA No. 1074/Ahd/2023 [ITO vs. Rajeshkumar Rameshchandra Shah] A.Y. 2017-18 - 9 – in which, the issue was with regard to cash deposits in the bank account of the assessee, which the assessee had stated out of the sale proceeds and the Assessing Officer had framed the assessment by making the addition

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

ITA 477/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: \nMs. Amrin Pathan, ARFor Respondent: \nShri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

TDS, and late payment of taxes aggregating to Rs.\n34,56,637/-, which were directly related to specific assets or statutory\nliabilities and had no nexus with earning exempt income. The CIT(A)\naccepted this contention and directed that such interest should be excluded\nfrom the computation under Rule 8D(2)(ii). On re-computation, the interest\ndisallowance under Rule

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

ITA 529/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2013-14
For Appellant: \nMs. Amrin Pathan, ARFor Respondent: \nShri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

TDS, and late payment of taxes aggregating to Rs.\n34,56,637/-, which were directly related to specific assets or statutory\nliabilities and had no nexus with earning exempt income. The CIT(A)\naccepted this contention and directed that such interest should be excluded\nfrom the computation under Rule 8D(2)(ii). On re-computation, the interest\ndisallowance under Rule

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

ITA 478/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad20 Aug 2025AY 2014-15
For Appellant: Ms. Amrin Pathan, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 115JSection 139(1)Section 143(2)Section 143(3)Section 14ASection 36Section 68Section 80G

TDS, and late payment of taxes aggregating to Rs.\n34,56,637/-, which were directly related to specific assets or statutory\nliabilities and had no nexus with earning exempt income. The CIT(A)\naccepted this contention and directed that such interest should be excluded\nfrom the computation under Rule 8D(2)(ii). On re-computation, the interest\ndisallowance under Rule

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD vs. M/S.DHARMEN MARBLE & STONE, AHMEDABAD

In the result appeal of the Revenue is dismissed

ITA 794/AHD/2019[2010-11]Status: DisposedITAT Ahmedabad27 Apr 2022AY 2010-11

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 794/Ahd/2019 With C.O.No.171/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T., M/S. Dharmen Marble & Stone, Central Circle-1(2), Vs. 16-B, Jadav Chamber, Ahmedabad. Ashram Road, Ahmedabad-380009. Pan: Aabfd5172B

For Appellant: Ms Nupur Shah, A.RFor Respondent: Shri Vijaykumar Jaiswal, CIT, D.R
Section 143(3)Section 147Section 148Section 68

TDS of Rs. 16,897/- credited from city union bank and Prism Cement, thus the corresponding income of Rs. 1,68,970 also remain unexplained and escaped assessment. Therefore, the AO initiated the proceedings under section 147 of the Act by issuing a notice under section 148 of the Act. With C.O.No.171/Ahd/2019 Asstt. Year 2010-11 5 4.3 However

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

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

ITA 954/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad17 Aug 2021AY 2012-13
Section 143(3)

197/-(-) Rs. 6,96,88,570/- already offered by the assessee) is required to be made to the income of the assessee company on account of guarantee fee to be charged from the associate enterprises in addition to the amount already charged as guarantee fee by the assessee. (Upward adjustment of Rs. 10,45,32,835/-) 7. When the Assessing

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

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

ITA 213/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad17 Aug 2021AY 2013-14
Section 143(3)

197/-(-) Rs. 6,96,88,570/- already offered by the assessee) is required to be made to the income of the assessee company on account of guarantee fee to be charged from the associate enterprises in addition to the amount already charged as guarantee fee by the assessee. (Upward adjustment of Rs. 10,45,32,835/-) 7. When the Assessing

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 276/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

section 145(3) and applied a GP rate of 12.5%, resulting in substantial additions. The CIT(A), however, granted partial relief by restricting the GP ITA No.254 to 256 and 274 to 276 /Ahd/2024 10 rate to 6%, which has been challenged in cross appeals. Before the CIT(A), the assessee submitted that it is engaged in the business

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 254/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

section 145(3) and applied a GP rate of 12.5%, resulting in substantial additions. The CIT(A), however, granted partial relief by restricting the GP ITA No.254 to 256 and 274 to 276 /Ahd/2024 10 rate to 6%, which has been challenged in cross appeals. Before the CIT(A), the assessee submitted that it is engaged in the business

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

ITA 256/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

For Appellant: Shri Tushar Hemani, Sr.Adv., and Shri Parimalsinh B. Parmar, ARFor Respondent: Shri R.P. Rastogi, CIT-DR, and Shri Abhijit, Sr.DR
Section 143(3)Section 145(3)Section 147Section 148Section 250

section 145(3) and applied a GP rate of 12.5%, resulting in substantial additions. The CIT(A), however, granted partial relief by restricting the GP ITA No.254 to 256 and 274 to 276 /Ahd/2024 10 rate to 6%, which has been challenged in cross appeals. Before the CIT(A), the assessee submitted that it is engaged in the business