ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. MS. JAGSON COLORCHEM LIMITED, PHASE -II GIDC ESTATE VATVA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years:2018-19

TDS was made thereon. However, the AO did not agree with the submissions of the assessee. He, therefore, disallowed the commission of Rs.5,63,28,206/- under the provision of section

M/S. ORION STEEL CORPORATION,ANAND vs. THE ACIT.,CPC-TDS, GHAZIYABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Amarjit Singh & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 2432/Ahd/2018 ("नधा"रण वष" / Assessment Year: 2014-15(26Q, Q1)) M/S. Orion Steel Corporation The Acit बनाम/ Centralized Processing 58, Ajanta Station Road, Vs. Cell-Tax Deducted At Anand, Gujarat-388001 Source, Income Tax Office, Sector-3, Vaishali, Ghaziyabad, Uttar Pradesh-201010 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaafo3831D .. (अपीलाथ"/Appellant) (""यथ" / Respondent)

TDS statement in Form No. 26Q for A.Y. 2014-15 (Quarter-1) which was processed under Section 200A on 24.03.2014 charging late fees under Section 234E at Rs. 48,600/-. Against the order passed under Section 200A r.w.s. 154 by CPC Ghaziabad, the assessee filed appeal before the Ld. CIT(A)-5, Vadodara. The Ld. CIT(A) has dismissed

SHRI GIRISHKUMAR RAMNARAYAN SHAH,AHMEDABAD vs. THE ITO, TDS-2, AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

TDS whereby the appellant is treated in default u/s 206C and demand of Rs.3,07,689/- is raised u/s. 206C(1), and Rs. 2,46,151/- is raised u/s 206C(7), totaling to Rs.5,53,840/-. Girishkumar Ramnarayan Shah vs.ITO Asst.Year –2012-13 - 2– (4) That the learned CIT(A) has grievously erred in not giving adequate and reasonable opportunity

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

206), the jurisdictional Gujarat High had applied the decisions of the Supreme Court in Empire Jute Co. Ltd. v. CIT (124 ITR 1) and CIT v. Madras Auto Service P. Ltd. (233 ITR 468) wherein it had been held that unless the expenditure was in the capital field, it could not be regarded as expenditure for the acquisition

AHMEDABAD STRIPS PRIVATE LIMITED,AHMEDABAD vs. THE DY.CIT, TDS CIRCLE, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kambleassessment Year 2012-13

TDS, Circle, Ahmedabad dated 27/03/2019 needs to be rectified. I.T.A No. 2211/Ahd/2025 Ahmedabad Strips Pvt. Ltd., A.Y. 2012-13 03. That the Appellant Company has paid all the Taxes and liabilities of TDS/TCS for the year under consideration. However, the order passed u/s 2026C(6A) r.w.s. 206C (7) of the Act without appreciating the facts on records is erroneous

RADHE FINSEC INDIA LTD.,AHMEDABAD vs. THE ITO, WARD-3(1)(2), AHMEDABAD

In the result, the appeal filed by the Assessee allowed for statistical purpose

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T. R. Senthil Kumar (Judicial Member)

206/ which after taking credit of TDS of Rs. 4,12,868/- was paid off 3. The Income Tax Officer, Central Processing Centre, Bengaluru issued an intimation u/s. 143(1) of the IT Act dated 15.12.2014 to the company, wherein they doubly counted the income under the normal provisions of the Act at Rs 64,59 670/- and calculated

SARANADHAR UMASHANKAR GUPTA,PALANPUR vs. THE ACIT, CIRCLE, PALANPUR

In the result, appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

206 different individuals. The second significant finding was that with regards to other major expenses such as raw material expenses (amounting to Rs. 6,37,40,829/-) and labour expenses (Rs. 3,08,44,613/-), a major portion of these expenses was also paid in cash, and the entries lacked any narrative description, with only the notation "cash on hand

ISHIT KAMLESHBHAI SHETH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

206\nITD 149 (Mumbai-Trib.) and the decision of Calcutta High Court in\nCommissioner of Income Tax, Central-III, Kolkata vs Brijendra Gupta\n[2015] 234 Τaxman 51 (Calcutta) in order to submit that if there was\nno disallowance or addition made by the Assessing Officer in the\nincome as disclosed in pursuance of notice under Section

ITO WARD-4(1)(4),, AHMEDABAD vs. VALLEY COMTRADE PVT LTD ( EARLIER KNOWN AS JHAWAR COMTRADE PVT. LTD.,), AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 2034/Ahd/2017 िनधा"रण वष"/Asstt. Year:2012-2013 I.T.O, M/S. Valley Comtrade Pvt. Ltd., Ward-4(1)(4), Vs. (Earlier Known As Jhawar Comtrade Ahmedabad. Pvt. Ltd.,) C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N & आयकर अपील सं./Ita No. 68/Srt/2017 िनधा"रण वष"/Asstt. Year:2012-2013 M/S. Valley Comtrade Pvt. Ltd., I.T.O, (Earlier Known As Jhawar Comtrade Vs. Ward-1(1)(3), Pvt. Ltd.,) Surat. C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N

section 143(1) of the Act. The relevant undisputed submission of the assessee reads as under: We enclosed herewith intimation u/s 143(1} of the Act in the-.case of SEEMA-HOLDING (P) LTD for A Y 2012-13 in which its total income has been accepted and a TDS Credit of Rs. 7,00,476/- has been granted. Refund

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 INCOME TAX OFFICER,,WARD-2(1)(2), AHMEDABAD vs. M/S. KANAK CASTOR PRODUCTS PVT. LTD.,, AHMEDABAD

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

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedasst.Year : 2008-09

TDS which are placed on pages 45 to 109 and 706 to 710 of the paper book. 8.3 The learned AR also drew our attention on the details of freight inward expenses, freight outward expenses, loading and unloading expenses, stores and spares expenses and packing expenses which are placed on record in the paper book. 8.4 The learned AR with

SHRI UMESHKUMAR HARILALA SHAH,AHMEDABAD vs. THE ITO, TDS-3, AHMEDABAD

Appeal of the assessee is dismissed

Bench: Ms. Suchitra Kamble

TDS)-3 A/401, Sukan Apartment, Nr. St. Ahmedabad Merry School, Naroda, Ahmedabad-382330 [PAN No.AGSPS6516P] (Appellant) .. (Respondent) Shri Jinesh Shah, A.R. Appellant by : Respondent by: Shri Dr. Mukesh Jain, Sr. D.R. Date of Hearing 15.09.2022 02.11.2022 Date of Pronouncement O R D E R This appeal is filed by the assessee against the order dated 12.06.2018 passed

TORRENT ENERGY LIMITED (NOW MERGED WITH TORRENT POWER LIMITED),AHMEDABAD vs. THE ACIT CIRCLE 4(1)(1), AHMEDABAD

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2011-12 Torrent Energy Limited The Acit, Cir.4(1)(1) (Now Merged With Torrent Power Ltd) Ahmedabad. Samanvay, 600, Tapovan Ambawadi, Ahmedabad Pan : Aacct 8570 B (Applicant) (Responent) Assessee By : Shri Vartik Chokshi, Ar : Smt.Trupti Patel, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 08/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

section 139(5). However, it was submitted that this reliance is wholly misplaced in the present case, as the issue of admissibility had already been adjudicated in assessee’s favour by the CIT(A) and not disturbed by the Co-ordinate Bench. The limited mandate before the AO was to re-examine the claim on merits, not to reopen

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

206 wherein it was held that when the customers of the company are located outside India, then the source is outside India. 25. In response, Ld. D.R. placed reliance on the observations made by the DRP and AO. 26. We have heard the rival contentions and perused the material on record. On going through the facts of the instant case

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

206 wherein it was held that when the customers of the company are located outside India, then the source is outside India. 25. In response, Ld. D.R. placed reliance on the observations made by the DRP and AO. 26. We have heard the rival contentions and perused the material on record. On going through the facts of the instant case

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1) , AHMEDABAD, AHMEDABAD vs. PRAKASH MISRIMAL SANGHVI, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

TDS), Ahmedabad (iv) Chief Commissioner of Income-tax, Rajkot (v) Chief Commissioner of Income-tax, Surat (vi) Chief Commissioner of Income-tax, Vadodara 16. It is evident from the above Notification that the PCCIT, Ahmedabad was having jurisdiction only over Chief Commissioner charges of Gujarat region. The PCCIT, Ahmedabad did not have jurisdiction over DGIT

PRAKASH MISRIMAL SANGHVI,AHMEDABAD vs. DCIT CC (1) AHMEDABAD, AHMEDABAD

In the result, the appeal of the Revenue in ITA No

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1138 To 1146/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2013-14 To 2021-22) बनाम/ Prakash Misrimal Deputy Commissioner Of Sanghvi Income-Tax Vs. 17, Rajmugat Soc. Central Circle-1(1), Naranpura Char Rasta, Ahmedabad Naranpura, Ahmedabad 380013 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeps7266A (Appellant) .. (Respondent)

TDS), Ahmedabad (iv) Chief Commissioner of Income-tax, Rajkot (v) Chief Commissioner of Income-tax, Surat (vi) Chief Commissioner of Income-tax, Vadodara 16. It is evident from the above Notification that the PCCIT, Ahmedabad was having jurisdiction only over Chief Commissioner charges of Gujarat region. The PCCIT, Ahmedabad did not have jurisdiction over DGIT