ASIAN MILLS PVT.LTD.,,AHMEDABAD vs. THE ADDL.CIT, RANGE-1,,, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No. 1397/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2011-2012 Asian Mills Pvt. Ltd., A.C.I.T., 104, Sakar Iii, Vs. Range-1, Opp. Old High Court, Ahmedabad. Ashram Road, Ahmedabad-380014. Pan: Aabca8236G & आयकर अपील सं./Ita No. 1531/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2011-2012 D.C.I.T., Asian Mills Pvt. Ltd., Circle-1(1)(1), Vs. 104, Sakar Iii, Ahmedabad. Opp. Old High Court, Ashram Road, Ahmedabad-380014. Pan: Aabca8236G

TDS. 17. We have heard the rival contentions of both the parties and perused the materials available on record. From the foregoing discussion we find that the discount offered by the assessee to its parties has been disallowed on account of 2 reasons. Firstly, these parties own their own go-down in Mumbai and therefore there was no occasion/reason

THE DCIT, CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD., AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

sections 198 and 199, there is no justification not to grant credit of TDS to the assessee from whose income

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

sections 198 and 199, there is no justification not to grant credit of TDS to the assessee from whose income

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

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

TDS was deducted, and ignoring the facts of the case these payment was made for utilization of their services for procuring orders from the overseas companies and therefore the assessee company was under obligation to deduct tax at source as envisaged u/s 195 of the Act from the payments of commission made to nonresident agents towards the services rendered

AXIS BANK LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-1 NOW CIRCLE-1(1)(1), AHMEDABAD

In the result appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedsl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 311/Ahd/2016 2010-11 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 2. 2176/Ahd/2016 2011-12 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 3. 2173/Ahd/2016 2011-12 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 4. 165/Ahd/2017 2012-13 Axis Bank Limited, D.C.I.T., Ahmedabad. Circle-1(1)(1) Ahmedabad. Pan: Aaacu2414K 5. 287/Ahd/2017 2012-13 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 6-7 520 & 2013-14 Axis Bank Limited, D.C.I.T., 521/Ahd/2018 & Ahmedabad. Circle-1(1)(1) 2014-15 Ahmedabad. Pan: Aaacu2414K 8-9 604 & 605/ 2013-14 D.C.I.T., Axis Bank Limited, Ahd/2018 & Circle-1(1)(1) Ahmedabad. 2014-15 Ahmedabad. Pan: Aaacu2414K

198/- only. Accordingly, the AO made the disallowance of the balance amount of Rs. 26,19,72,629/- and added to the total income of the assessee. 4. The aggrieved assessee preferred an appeal to the Ld.CIT(A), who found that his predecessor in the own case of the assessee for the Assessment Year 2008- 09 has also made

DCIT, CENTRAL CIRCLE - 1(3), AHMEDABAD vs. M/S LOK PRAKASHAN LTD., AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

LOK PRAKASHAN LIMITED,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(3),, AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

LOK PRAKASHAN LIMITED,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(3),, AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

DCIT, CENTRAL CIRCLE- 1(3), AHMEDABAD vs. M/S LOK PRAKASHAN LTD., AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

section 115JB of the Act. Thus, the ground of appeal raised by the Revenue is hereby dismissed. 52. The next issue raised by the Revenue vide ground Nos. 17 & 18 of its appeal is that the learned CIT(A) erred in deleting the addition of Rs. 42,15,37,467/- made on account credit of dividend distribution

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

section 115JB of the Act. Thus, the ground of appeal raised by the Revenue is hereby dismissed. 52. The next issue raised by the Revenue vide ground Nos. 17 & 18 of its appeal is that the learned CIT(A) erred in deleting the addition of Rs. 42,15,37,467/- made on account credit of dividend distribution

THE ITO, WARD-1(1)(4),, AHMEDABAD vs. M/S. DHWANI INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result, both the appeal filed by revenue and cross objection filed by assessee are dismissed

TDS and have also paid back the said ICD along with interest. Appellant's main objection was that in view of the various decisions including special bench of ITAT Mumbai in the case of Asstt. CIT v/s. Bhaumik Colour (P.) Ltd.[2009] 118 ITD 1 (Mum.) (SB) and jurisdictional High Court decision in the case of CIT v/s Daisy Packers

ADVANCE LIFESPACES PRIVATE LIMITED,ASARVA, AHMEDABAD vs. ACIT CIRCLE 1(1)(1), AHMEDABAD, INCOME TAX OFFICE, VEJALPUR

In the result, the appeal filed by the Assessee is partly allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

TDS of Rs.884. The Return was selected for scrutiny assessment. The Assessing Officer rejected the books of account under section 145(3) of the Act, citing fall in gross profit to 0.71% from 4.49% in the immediately preceding year and also absence of unit-wise stock details. Therefore, the AO estimated gross profit at 9.94% (average of three years

DCIT CC- 1(3), AAYKAR BHAVAN vs. MONTECARLO LIMITED , SINDHU BHAWAN ROAD, BODAKDEV

In the result, the appeal filed by the revenue in ITA

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

198/-, claimed as deduction u/s.801A(4) for the year, including the deduction of Rs.1,55,09,903/-, claimed on profits of JVs, as a constituent, as claimed in return of income. Accordingly, this ground of appeal is treated as ALLOWED." 15.3 Hon’ble Supreme Court in the case of PCIT vs. Backbone Projects Ltd. dismissed the SLP filed by Revenue

DCIT CC- 1(3), AAYKAR BHAWAN vs. MONTECARLO LIMITED, MONTECARLO HOUSE, SINDHU BHAWA

In the result, the appeal filed by the revenue in ITA

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

198/-, claimed as deduction u/s.801A(4) for the year, including the deduction of Rs.1,55,09,903/-, claimed on profits of JVs, as a constituent, as claimed in return of income. Accordingly, this ground of appeal is treated as ALLOWED." 15.3 Hon’ble Supreme Court in the case of PCIT vs. Backbone Projects Ltd. dismissed the SLP filed by Revenue

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

TDS credit. The addition appears to have been sustained summarily without independent verification or reasoning. 18. As regards the addition of Rs. 10,00,000/- under section 69C of the Act, the same has been made by the Assessing Officer on the basis of an alert generated through NMS software indicating that Green Channel Travel Services Ltd. (amalgamated with

CREST SPECIALITY RESINS PRIVATE LIMITED,KHEDA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), AHMEDABAD (NOW DCIT, CIRCLE 1(1)(1), AHMEDABAD), AHMEDABAD, GUJARAT

In the result, the appeal of the assessee is allowed for both the years under consideration

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

198 ITD 158 held that amendment to provisions of Rule 6(7A)(b) w.e.f. 01-07-2016 whereby prescribed authority can quantify expenditure eligible for weighted deduction under sub-section (2AB) of section 35, would apply only for assessment year 2017-18. Further, we observe that the Gujarat High Court in the case of CIT vs. Sun pharmaceutical Industries