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

47,75,048 (share capital of Rs.9,05,15,220plus free reserves of Rs. 128,42,59,828) for the year ended 31 March 2011. As against these owned funds, investment yielding exempt income amounted to only Rs.37,54,06,040. • That RBHIL had generated net cash from its operating activities amounting to Rs. 104,15,44,432 whereas additional

ACIT, EXEMPTIONS, CIRCLE-1, AHMEDABAD, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

v. Rajneesh Foundation [2006] ACIT Exemptions vs. Vyakti Vikas Kendra India Page 8 of 15 280 ITR 533/[2005] 148 Taxman 396 (Bom.) were relied upon. It was held that yoga was one of the six systems of Vedic philosophy developed by Maharishi Patanjali, who was characterized as "The Father of Yoga" and who had compiled and refined various aspects

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

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

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

TDS by invoking Explanation 2 to Section 9(1)(vii) of the Act considering same as "fees for technical services" ignoring fact that said testing were done out of India and payee does not have any permanent establishment in India and it is not fees for technical services. Tax Effect: Rs. 85,250/- Your appellant craves leave to add, amend

INCOME TAX OFFICER (TDS-3), AHMEDABAD, AHMEDABAD vs. TARUN SANTRAMDAS VARMA, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

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

2(47) (v) and (vi) of the Income Tax Act wherein the term immovable property would include rights in or with respect to such immovable property. Therefore, there is no requirement of deducting Tax at Source under section 194-IA on payments made by a transferee to a 'Confirming Party', as he is not the transferor of "immovable property

THE ACIT, CIRCLE- 2(1)(1),, AHMEDABAD vs. M/S. GUJARAT AMBUJA EXPORTS LIMITED,, AHMEDABAD

Bench: Us.

v) Sundry balances of vendors written off Rs.12.91.362/- Rs. 19,33,215/- Total 2.4. It is here to be mentioned that the AO has not granted the deduction on the aforesaid amounts by saying that none of the above income can be held to be generated from the manufacturing activities of the undertaking, and therefore, the nature of above incomes

GUJARAT INFRAPIPES PVT. LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) relating to the Assessment Year (AY) 2013-14. For the sake of convenience, these appeals were ITA Nos. 813 & 987/Ahd/2017 A.Y. 2013-14 M/s. Gujarat Infrapipes Pvt. Ltd. Vs. DCIT 2 heard together and are being disposed of by way of this consolidated order. 2

THE DCIT, CIRCLE-1(1)(1),, VADODARA vs. M/S. GUJARAT INFRA PIPES PVT. LTD.,, VADODARA

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumar

section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) relating to the Assessment Year (AY) 2013-14. For the sake of convenience, these appeals were ITA Nos. 813 & 987/Ahd/2017 A.Y. 2013-14 M/s. Gujarat Infrapipes Pvt. Ltd. Vs. DCIT 2 heard together and are being disposed of by way of this consolidated order. 2

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

v. PHL Pharma (P) Ltd. [2017] 49 CCH 124 (Mum), wherein the Tribunal after deliberating at length on two aspects viz. (i) validity of the circular in the backdrop of enlargement of scope of MCI regulation to the pharmaceutical companies by the CBDT, without any enabling provisions either under the Income Tax Law or under the Indian Medical Council

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

v. PHL Pharma (P) Ltd. [2017] 49 CCH 124 (Mum), wherein the Tribunal after deliberating at length on two aspects viz. (i) validity of the circular in the backdrop of enlargement of scope of MCI regulation to the pharmaceutical companies by the CBDT, without any enabling provisions either under the Income Tax Law or under the Indian Medical Council

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:-

47. On the question of cost, the CIT(A) rightly held that the goodwill arose as a result of an actual transaction supported by a court-sanctioned scheme and a valuation report, and not merely by accounting jugglery. The CIT(A) distinguished Explanation 7 to section 43(1) and Explanation 2 to section 43(6) by observing that they apply

THE ORCHID HEIGHTS CO.OP HOUSING SERVICE SOCIETY LIMITED,AHMEDABAD vs. ITO, WARD-3(3)(5), AHMEDABAD, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice- & Ms Suchitra Kamblethe Orchid Heights Co-Op Income Tax Officer, Vs. Housing Service Society Ward-3(3)(5), Limited, Ahmedabad. Applewood Township, Nr. Shantipura Circle, Ahmedabad-382210.. [Pan :Aagat8437 K] (Appellant) .. (Respondent) Appellant By : Shri M J Ranpura, Ar Respondent By: Shri Suresh Chand Meena, Sr. Dr Date Of Hearing 03.07.2025 Date Of Pronouncement 09.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- Delay Condoned This Appeal Is Filed By The Assessee Against The Appellate Order Dated 29.04.2024 Passed By The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, Relating To The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeals:

47,375/- out of total disallowance of Rs.40,97,375/- on the alleged ground that the appellant is not eligible to claim deduction u/s.80P(2)(d) in respect of interest/dividend from other co- operative Society. The disallowance confirmed is unjustified and uncalled for, which deserves to be deleted, may kindly be deleted. 3. The only issue required to be adjudicated

SHREE HARI ENTERPRISE ,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is partly allowed in the\nfollowing terms:\n\ni) Issue No

V. Nandakumar, CIT-DR\n\nसुनवाई की तारीख /Date of Hearing : 17/12/2024\nघोषणा की तारीख / Date of Pronouncement: 07/02/2025\n\nआदेश/ORDER\n\nPER ANNAPURNA GUPTA, ACCOUNTANT MEMBER\n\nThe above appeal is filed by the assessee against order passed by the ld.Pr.Commissioner of Income-1, Ahmedabad in exercise of revisionary jurisdiction under section 263 of the Income

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

47,709.74 lacs on which dividend earned was at Rs.508.18 lacs. The AO's objection was that on one hand the assessee has diverted the huge funds towards such investment having exempted income and on the other hand borrowed huge funds of Rs.3,46,272.51 lacs on which claimed interest of Rs. 19360.59 lacs. Therefore

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

In the result the appeal filed by the assessee is allowed

TDS of INR 5,78,321/-. 5. Validity of the order passed by the Hon'ble CIT(A) On the facts and circumstances of the case and in law, the Hon'ble CTT(A) erred in observing that the Ld. Assessing Officer (Ld. AO) be directed to verify the claim of the Appellant in relation to refund of excess

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

TDS certificate issued by the Executive Engineer. The assessee has raised RA bills, contractor & construction work bills for the activities undertaken by it at the part rate as agreed by in the tender and work contract & collected the payment for the same. g. The receipt of payment u/s.194C itself clearly indicates that the assessee company has acted as a contractor

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

TDS certificate issued by the Executive Engineer. The assessee has raised RA bills, contractor & construction work bills for the activities undertaken by it at the part rate as agreed by in the tender and work contract & collected the payment for the same. g. The receipt of payment u/s.194C itself clearly indicates that the assessee company has acted as a contractor

KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

TDS certificate issued by the Executive Engineer. The assessee has raised RA bills, contractor & construction work bills for the activities undertaken by it at the part rate as agreed by in the tender and work contract & collected the payment for the same. g. The receipt of payment u/s.194C itself clearly indicates that the assessee company has acted as a contractor