SAFAL HOSPITALITY AND MAINTANANCE SERVICE,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(2), AHMEDABAD

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

Bench: Ms. Suchitra Kamble (Judicial Member)

x) section 36(1)(va) and section 43B Your Honour would observe that primarily any sum received by the assessee from his employees as contributions to any provident fund or superannuation fund or any fund set up under the provisions of the Employees' State Insurance Act 4 I.T.A No. 76/Ahd/2019 A.Y. 2015-16 Page No. Safal Hospitality and Maintainance Service

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

x) of the Act, despite of the issue being covered by the completed assessment u/s 143(1) of the Act. 7. Alternatively, and without prejudice, the CIT(A) have erred in law and on the facts of the case in making a disallowance of payments of PF & ESImade within the grace period. 8. Alternatively, and without prejudice

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

x) of the Act, despite of the issue being covered by the completed assessment u/s 143(1) of the Act. 7. Alternatively, and without prejudice, the CIT(A) have erred in law and on the facts of the case in making a disallowance of payments of PF & ESImade within the grace period. 8. Alternatively, and without prejudice

KIFS SECURITIES PVT. LTD.,AHMEDABAD vs. THE ACIT, CIRCLE-1(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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

DY.COMMISSIONER OF INCOME TAX CIRCLE-1(3),, AHMEDABAD vs. KIFS 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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(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

x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the "due date" mentioned in explanation to section 36(J) (va). Consequently

DHANLAXMI CREDIT CO. OP. SOCIETY LTD.,MEHSANA vs. THE ITO, WARD-2, PATAN

In the result, Ground Number 3 of the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

24-09-2024], wherein the Gujarat High Court held that deduction under section 80P(2)(d) of the Act is available to cooperative societies on income earned as interest on investment made with Dhanlaxmi Credit Co. Op. Society Ltd. vs. ITO Asst.Year –2017-18 - 3– cooperative bank which in turn, is a cooperative society itself. In this case, Principal Commissioner

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company