RECKITT BENCKISER HEALTHCARE INDIA PVT. LTD., ( FORMERLY KNOWN AS RECKITT BENCKISER HEALTHCARE INDIA LTD.,),HARYANA vs. DCIT, CIRCLE-3(1)(2), AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

iii). Hence, the order of the Ld. CIT(A) on these grounds are affirmed. In the result, Ground Nos. 1 & 2 of the assessee’s appeal are dismissed. 6. Ground No. 3: Disallowance under section 14A of the Act. 6.1 The brief facts relating to this issue are that the assessee has investment of Rs.47

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

14,810/- inclusive of interest u/s 244A of Rs.8,80,103/-. Subsequently, the matter was selected for scrutiny under CASS and notice dated 05.09.2012 u/s 143(2) was issued to the assessee followed by a further questionnaire dated 12.04.2013 u/s 142(1) calling for specific details and documents. In response thereto certain details and documents were filed

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

14,810/- inclusive of interest u/s 244A of Rs.8,80,103/-. Subsequently, the matter was selected for scrutiny under CASS and notice dated 05.09.2012 u/s 143(2) was issued to the assessee followed by a further questionnaire dated 12.04.2013 u/s 142(1) calling for specific details and documents. In response thereto certain details and documents were filed

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

14,810/- inclusive of interest u/s 244A of Rs.8,80,103/-. Subsequently, the matter was selected for scrutiny under CASS and notice dated 05.09.2012 u/s 143(2) was issued to the assessee followed by a further questionnaire dated 12.04.2013 u/s 142(1) calling for specific details and documents. In response thereto certain details and documents were filed

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

14,810/- inclusive of interest u/s 244A of Rs.8,80,103/-. Subsequently, the matter was selected for scrutiny under CASS and notice dated 05.09.2012 u/s 143(2) was issued to the assessee followed by a further questionnaire dated 12.04.2013 u/s 142(1) calling for specific details and documents. In response thereto certain details and documents were filed

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

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted that all the four investee companies were dormant, and no expenditure could be said to have been incurred

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted that all the four investee companies were dormant, and no expenditure could be said to have been incurred

AARK INFOSOFT PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2017-18 Vs. Aark Infosoft Private Limited, The Acit, 45, Shetrunjay, 2Nd Floor, Above Circle-1(1)(1), Central Bank Of India, Bhattha Ahmedabad Cross Road, Paldi, Ahmedabad Gujarat-380007 Pan : Aahca 9986 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Divyang Shah, Ar Revenue By : Shri Santosh Kumar, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 08.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 21.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 27.07.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Are As Under:- “1. Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Issuing A Notice U/S 143(2) Of The Act? 2. Whether On The Facts & In Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Making Disallowance Of Employees' Contribution To Pf & Esic Of Rs.5,51,657/- U/S 36(1) (Va) Of The Act?

TDS u/s 40(a)(ii) of the Act? 5. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making disallowance of Rs. 17,790/- for penalty expenses? 6. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making addition

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

14,6197- u/s. 40(a)(ia) on the ground that the appellant had not deducted TDS therefrom (out of Rs. 37,46,013 disallowed by the A. O. on this account). 8. In law and in the facts and circumstances of the appellant's case, the learned CIT(A) has grossly erred in upholding the disallowance of deduction

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

14,6197- u/s. 40(a)(ia) on the ground that the appellant had not deducted TDS therefrom (out of Rs. 37,46,013 disallowed by the A. O. on this account). 8. In law and in the facts and circumstances of the appellant's case, the learned CIT(A) has grossly erred in upholding the disallowance of deduction

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

14,6197- u/s. 40(a)(ia) on the ground that the appellant had not deducted TDS therefrom (out of Rs. 37,46,013 disallowed by the A. O. on this account). 8. In law and in the facts and circumstances of the appellant's case, the learned CIT(A) has grossly erred in upholding the disallowance of deduction

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

TDS, and late payment of taxes aggregating to Rs. 34,56,637/-, which were directly related to specific assets or statutory liabilities and had no nexus with earning exempt income. The CIT(A) accepted this contention and directed that such interest should be excluded from the computation under Rule 8D(2)(ii). On re-computation, the interest disallowance under Rule

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

iii) Dwani Infrastructure Pvt. Ltd. (Date of incorporation : 13.11.2006): Number of shares held Name of shareholder during 13.11.2006 to Percentage of holding 31.03.2007 Mr Pravin T. Kotak 9,000 90 Mr Amit M. Gupta 1,000 10 Total 10,000 100 (iv) Rich Infrastructure Pvt. Ltd. (Date of incorporation : 13.11.2006): Number of shares held Name of shareholder during

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

iii) Dwani Infrastructure Pvt. Ltd. (Date of incorporation : 13.11.2006): Number of shares held Name of shareholder during 13.11.2006 to Percentage of holding 31.03.2007 Mr Pravin T. Kotak 9,000 90 Mr Amit M. Gupta 1,000 10 Total 10,000 100 (iv) Rich Infrastructure Pvt. Ltd. (Date of incorporation : 13.11.2006): Number of shares held Name of shareholder during

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms.Annapurna Gupta & T.R. Senthil Kumarasstt.Year : 2014-15 The Dcit, Cir.2(1)(1) Gujarat Apollo Industries Ltd. Ahmedabad. ‘Apollo House’ Rashmi Society Nr.Mithakhali Six Roads Navrangpura Ahmedabad 380 009. Pan : Aaacg 7248 P

2)(iii) of the IT Rule. We order so. 14. So far as second issue i.e. whether amount of disallowance under section 14A is to be added to the income computed as per Section 115JB for MAT purpose or not, is covered in favour of the assessee by the decision of Special Bench in the case of ACIT Vs. Vireet

ARCHANABEN RAJENDRASINGH DEVAL,AHMEDABAD vs. THE INCOME TAX OFFICER, TDS WARD-1,, AHMEDABAD

In the result, the appeal filed by the assessee is allowed, as indicated\nabove

Bench: SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER\nAND\nSHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER\nआयकर अपील सं/ITA No.1465/Ahd/2024\nनिर्धारण वर्ष / Assessment Year : 2015-16\nArchanaben Rajendrasingh\nDeval\nबनाम /\nv/s.\nThe Income Tax Officer\nTDS Ward-1,\nAhmedabad – 380 014\n42, Tirth Bhumi Co-op. Society\nNear Dhara Soap Factory\nNikol Gam Road,\nNikol, Ahmedabad – 382 350\nस्थायी लेखा सं./PAN: AHZPD 2745 D\n(अपीलार्थी/ Appellant)\n(प्रत्यर्थी/ Respondent)\nAssessee by :\nShri Jaimin Sha

2(14)(iii) of the Act. Therefore, the provisions of section 194IA of the\nAct were clearly applicable and the assessee, having failed to deduct tax at\nsource, was rightly held to be in default under section 201(1) of the Act and\nliable for interest under section 201(1A) of the Act.\n9.\nWe have carefully considered the rival

THE ACIT, CIRCLE-3,, AHMEDABAD vs. KIFS SECURITIES LIMITED,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

14. The only point on which ld. CIT(A)'s order has been assailed is that the TDS was not made in terms of section 194H. Section 194H deals with provisions relating to TDS on commission or brokerage. Commission or brokerage has been defined in Explanation (i) as under: - "Explanation (i) "commission or brokerage" includes any payment received or receivable

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

14. The only point on which ld. CIT(A)'s order has been assailed is that the TDS was not made in terms of section 194H. Section 194H deals with provisions relating to TDS on commission or brokerage. Commission or brokerage has been defined in Explanation (i) as under: - "Explanation (i) "commission or brokerage" includes any payment received or receivable

THE DY. CIT., CIRCLE-3,, AHMEDABAD vs. KHANDWALA INTEGRATED FINANCIAL SERVICES PVT. LTD, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

14. The only point on which ld. CIT(A)'s order has been assailed is that the TDS was not made in terms of section 194H. Section 194H deals with provisions relating to TDS on commission or brokerage. Commission or brokerage has been defined in Explanation (i) as under: - "Explanation (i) "commission or brokerage" includes any payment received or receivable