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

section 80-IA of the Act. 69. The learned CIT (A) disregarded the contention of the assessee by observing that the impugned income does not have nexus with the distribution of power activity of the assessee. Thus the learned CIT (A) upheld the finding of the AO. 70. Being aggrieved by the order of the learned CIT (A), the assessee

THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD vs. M/S. ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS M/S. CADILA HEALTHCARE LTD.), AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: DR. BRR KUMAR (Vice President), SHRI SIDDHATHA NAUTIYAL (Judicial Member)

207/- 63.93.138/- paid on 03.06.2009 Zydus Animal Health Ltd. (wholly 4,41,59,816/- 75,04,960/- owned subsidiary) paid on 27.09.2010 Net 51,69,37,536/- 8,78,53,540/- Less: tax paid by assessee 9,53,58,500/- company on 11/08/2009 Excess tax paid claimed against 75,04,960/- the income tax payable as per the return

M/S. JUGALKISHORE R. AGRAWAL INFRASTRUCTURE PVT. LTD.,,DEESA vs. THE JT. CIT, B.K.RANGE,, PALANPUR

In the result, this ground of the assessee’s appeal is dismissed

section 133(6) of the Act was " 89, 78, 907/- only. The assessee submitted that TDS was deducted on the total amount of " 96,31,203/- and payment was made through cheque. Further the creditor had claimed TDS credit of the entire amount during the year under consideration. However, the AO held that the assessee has not been able

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

207 to 249 of the paper book. The AO has not pointed out any defect in the details furnished by the assessee. In the event, the AO had any doubt on the genuineness of such expenses, he was empowered under section 133 (6)/131 of the Act to carry out the necessary verification. But he has not done

ARVINDKUMAR AMULKH TANNA,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2 (3), AHMEADABAD

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

section 68/69A of the Act because based on the investigations made and the findings therefrom the AO has the basis of to be not satisfied with the explanations furnished by the appellant. The satisfaction of the AO is not arbitrary and is not based on whims and fancy". (ii) The Ld. CIT (A) has erred in law and on facts

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

207 (Pune). The assessee also relied on the decision of Hon’ble Apex Court in the case of CIT Vs. Glaxo Smithkline Asia P.Ltd., (2010) 195 Taxman 35 (SC) for the proposition that there ought to be no ALP adjustment if it is a revenue neutral exercise. 14. Having heard contentions of the ld.counsel for the assessee, and having gone

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

207 (Pune). The assessee also relied on the decision of Hon’ble Apex Court in the case of CIT Vs. Glaxo Smithkline Asia P.Ltd., (2010) 195 Taxman 35 (SC) for the proposition that there ought to be no ALP adjustment if it is a revenue neutral exercise. 14. Having heard contentions of the ld.counsel for the assessee, and having gone

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

207/-. However, in the Profit and Loss (P&L) account, the total contract income was shown as Rs. 19,62,06,649/-, which led to a discrepancy of Rs. 30,25,558/-. In view of these findings, the Assessing Officer issued a show cause notice to the assessee, asking why their books of accounts should not be Sarandhar Umashankar Gupta

ITO, WARD-4(1)(3), AHMEDABAD vs. SHIVGANGA PROPERTY HOLDERS PVT. LTD, AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 69A of the Act. 8.6. During the appellate proceedings before CIT(A), the assessee contended that it had obtained a loan of Rs.1,50,00,000/- on 19.08.2011 through “account payee cheque” from Green Stone Agro Product and Infrastructure Pvt. Ltd., which was duly recorded in its bank account and books of accounts. The said loan was repaid

SHIVGANGA PROPERTY HOLDERS PVT. LTD,AHMEDABAD vs. ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 69A of the Act. 8.6. During the appellate proceedings before CIT(A), the assessee contended that it had obtained a loan of Rs.1,50,00,000/- on 19.08.2011 through “account payee cheque” from Green Stone Agro Product and Infrastructure Pvt. Ltd., which was duly recorded in its bank account and books of accounts. The said loan was repaid

THE ITO, WARD-4(1)(3), AHMEDABAD vs. SHRI VIGHNAHARTA REALITY PVT. LTD., AHMEDABAD

The appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) / Cos By :

Section 69A of the Act. 8.6. During the appellate proceedings before CIT(A), the assessee contended that it had obtained a loan of Rs.1,50,00,000/- on 19.08.2011 through “account payee cheque” from Green Stone Agro Product and Infrastructure Pvt. Ltd., which was duly recorded in its bank account and books of accounts. The said loan was repaid

SHRI VIGHNAHARTA REALTY PVT. LTD,AHMEDABAD vs. THE ITO, WARD-4(1)(3), AHMEDABAD

The appeal of the Revenue is dismissed

Section 69A of the Act.\n8.6.\nDuring the appellate proceedings before CIT(A), the assessee\ncontended that it had obtained a loan of Rs.1,50,00,000/- on 19.08.2011\nthrough \"account payee cheque\" from Green Stone Agro Product and\nInfrastructure Pvt. Ltd., which was duly recorded in its bank account and\nbooks of accounts. The said loan was repaid

M/S. PRAMUKH COTPRESS INDIA PVT. LTD.,,SABARKANTHA vs. THE INCOME TAX OFFICER, S.K.WARD- 2,, HIMATNAGAR

section 40(A)(3) of the Act ,provided in Rule 6DD(b) of the Income Tax Rules,1962,since the assessee has not established that the payment in cash was made as prescribed by the Rules of the Government organization, which finding the Ld.Counsel for the assessee was unable to displace before us. 6.1 The balance disallowance of Rs.67

ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LA RENON HEALTHCARE PVT. LTD.,, AHMEDABAD

The appeal of the Revenue is dismissed, whereas the Cross Objection filed by the Assessee is allowed in part

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

207-208, ISCON Elegance बनाम/ Ahmedabad Circle P Vs. Prahladnagar Cross Road S.G. Highway Ahmedabad – 380 051 "थायी लेखा सं./PAN: AABCL 3431 G अपीलाथ"/ (Appellant) ….. "" यथ"/ (Respondent & Cross Objector) Assessee by : Shri Vartik Chokshi, AR Revenue by : Shri Ashok Kumar Suthar, Sr.DR सुनवाई क" तार"ख/Date of Hearing : 30/07/2024 घोषणा क" तार"ख /Date of Pronouncement: 06/08/2024 आदेश