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

43 80. Before the CIT(A), the assessee submitted that the disallowance was unjustified and that it had substantial interest-free funds available throughout the year, far in excess of the average CWIP balance. It was submitted that as on 31.03.2015, the assessee had own funds comprising share capital and reserves aggregating Rs.4198.37 crores and as on 31.03.2014, Rs.2803.45 crores

JCIT(OSD), CIR-3(1)(2), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE (INDIA) LTD, HARYANA

In the result, appeal of the Revenue is dismissed

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

43– Chapter VI-A of the Income-tax Act, 1961 ("the Act"), provides for deductions in respect of certain incomes. In computing the profits and gains of a business

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

43– Chapter VI-A of the Income-tax Act, 1961 ("the Act"), provides for deductions in respect of certain incomes. In computing the profits and gains of a business

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

43(1) of the Act. 3.1. The assessee company was earlier known as M/s. Dintex Dyechem Ltd. In accordance with the scheme of amalgamation of M/s. Bodal Chemicals Pvt. Ltd., with erstwhile M/s Dintex Dyechem Ltd. (Bodal Chemicals Ltd.) sanctioned by the Hon’ble High Court of Gujarat vide order dated 27.04.2006, all the assets and liabilities of M/s Dintex

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

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

2. (a) Ld. AO / DRP erred in law and on facts in making disallowance of Rs.8,26,43,616/- invoking provision of section 14A ignoring submission & contention of the appellant. (b) Ld. AO / DRP erred in law and on facts in making disallowance without recording satisfaction that disallowance made by appellant is not proper. (c) Ld. AO / DRP erred

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

43 the Act and under the explanation to Section 73 of the Act. Accordingly, the Learned CIT (A) deleted the addition made by the AO for such loss of Rs. 17,02,013.00. Thus, the Learned CIT (A) allowed the ground of appeal of the assessee in part. 70. Being aggrieved by the order of the Learned CIT (A) both

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

43 the Act and under the explanation to Section 73 of the Act. Accordingly, the Learned CIT (A) deleted the addition made by the AO for such loss of Rs. 17,02,013.00. Thus, the Learned CIT (A) allowed the ground of appeal of the assessee in part. 70. Being aggrieved by the order of the Learned CIT (A) both

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

43 the Act and under the explanation to Section 73 of the Act. Accordingly, the Learned CIT (A) deleted the addition made by the AO for such loss of Rs. 17,02,013.00. Thus, the Learned CIT (A) allowed the ground of appeal of the assessee in part. 70. Being aggrieved by the order of the Learned CIT (A) both

M/S. EDELWEISS BROKING LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(3), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

Section 40(a)(ia) of Rs. 9,16,306/-. The Ld. AO has discussed the issues at Paras 7 to 7.12 on pages 23 to 43 and Ld. CIT(A) has discussed in Paras 19 to 22 on Pages 17 to 24. 8. On identical issue has covered in favour of the assessee in its own case vide ITAT order

DCIT, CIRCLE-1(3), , AHMEDABAD vs. EDELWEISS BROKING LTD.(ON BEHALF OF AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

Section 40(a)(ia) of Rs. 9,16,306/-. The Ld. AO has discussed the issues at Paras 7 to 7.12 on pages 23 to 43 and Ld. CIT(A) has discussed in Paras 19 to 22 on Pages 17 to 24. 8. On identical issue has covered in favour of the assessee in its own case vide ITAT order

THE DCIT, CIRCLE-4(1)(2), AHMEDABAD vs. TROIKAA PHARMACEUTICALS LTD, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

43. The AO during the assessment proceedings found that the assessee made payment of commission expenses of Rs. 57,07,675/- to foreign agents without deducting withholding tax under section 195 of the Act. On question, the assessee submitted that commission was paid to different agents based in foreign countries for services provided in foreign countries. They do not have

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD vs. TROIKAA PHARMACEUTICLAS LIMITED,, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

43. The AO during the assessment proceedings found that the assessee made payment of commission expenses of Rs. 57,07,675/- to foreign agents without deducting withholding tax under section 195 of the Act. On question, the assessee submitted that commission was paid to different agents based in foreign countries for services provided in foreign countries. They do not have

ASHVINKUMAR NARANBHAI PATEL,AHMEDABAD vs. THE ITO, TDS-WARD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.722/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Ashvinkumar Naranbhai Patel The Ito बनाम/ 43, Shankar Society Part-1 Tds Ward-1 V/S. Near Meerambica Road Ahmedabad – 380 014 Opp. Amikunj Bus Stand Naranpura Ahmedabad – 380 013 "थायी लेखा सं./Pan: Aeipp 9274 R अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Jaimin Shah, Ar Revenue By : Shri Umesh Kumar Agrawal, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/07/2025 घोषणा की तारीख /Date Of Pronouncement: 28/07/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Dated 28.02.2025 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)”], Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Confirming The Demand Raised Under Section 201(1) & 201(1A) By The Ito, Tds Ward 1, Ahmedabad [Hereinafter Referred To As “Assessing Officer Or Ao”], In Relation To A.Y. 2015–16. Ashvinkumar Naranbhai Patel Vs. Ito Asst. Year : 2015-16

43, Shankar Society Part-1 TDS Ward-1 v/s. Near Meerambica Road Ahmedabad – 380 014 Opp. Amikunj Bus Stand Naranpura Ahmedabad – 380 013 "थायी लेखा सं./PAN: AEIPP 9274 R अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee by : Shri Jaimin Shah, AR Revenue by : Shri Umesh Kumar Agrawal, Sr.DR सुनवाई की तारीख/Date of Hearing : 24/07/2025 घोषणा की तारीख /Date of Pronouncement

M S HOSTEL,NEW SAMA SAVLI ROAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(3), VADODARA, AAYAKAR BHAVAN, VADODARA

In the result, appeal preferred by the assessee is allowed

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

TDS was made good by payment of self assessment tax on 7th April 2015 6 Since she was not in need of funds she has not withdrawn the same and kept with the appellant firm to the credit of her account" 2.1 Vide notices dated 06/01/2021, 11/06/2021, 06/04/2022, 25/04/2023 the appellant was requested to file its reply, In response

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

TDS as per section 195(6) of the Act relating to various parties. One among this is Mr.Binod Shah, Form No.15CB clearly mentioned that he belongs to Nepal and he was paid commission 72,1000/- on 5.6.2013 and also Rs.2,41,966/- on the very same day. However, these copies of the chart, Form no.15CB and form no.CA were

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 56(2) of the I T Act. Such interest on loans is ordinary business income and cannot be treated as Income from Other Sources. This is particularly because the employees are retained to run the business of the Company and accordingly the loans given to them are out of such business expediency(in line with approved HR policies

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

43) of Act and, hence, is chargeable as per Section 4, which is subject to other provisions, which include Section 90 and sub-clause (2) thereof, then specially in case of Avoidance of Double Tax, the provisions more beneficial to assessee must be preferred. Considering that the international treaties involve extensive negotiations between two nations, and definitely being conscious

M/S. SABARMATI GAS LTD.,GANDHINAGAR vs. THE PR. CIT-3, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2018-19 Sabarmati Gas Ltd. The Ld.Pr.Cit Plot No.907, Sector 21 Vs Ahmedabad-3. Gandhinagar 382 021 Pan : Aakcs 0110 N

43(6) of the Act, does not provide for any adjustment to WDV of block of assets on account of any reclassification of assets. The Ld.PCIT has in effect applied the 11 provision of section 32 of the Act for holding prior period claim of depreciation not allowable, to only part of the impact of reclassification of asset effected