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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act even though the Assessee has filed its return within the due date prescribed under Section 139 of the Act. 14. The learned AO has erred in levying interest under Section 234B of the Act. 15. The learned AO has erred on the facts and in law in initiating penalty proceedings under Section 274 r.w.s

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

IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

In the result the appeal filed by assessee is partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

234A, 234B, 234C, and 234D of the IT Act. 10. On the facts and in the circumstances of the case and in law, the NFAC erred in not quashing the action of the Ld. AO of initiating penalty proceedings under section 271(1)(c) of the IT Act. 11. The Appellant craves leave to add, alter, amend, delete

SHELL INTERNATIONAL B.V.,NETHERLANDS vs. THE ASSTT.CIT., CIRCLE(INTNL.TAXN.)-1, AHMEDABAD

In the result,\nwe hold that the above services did not qualify as FTS under the\nIndia-Netherlands Tax Treaty, since the “make available” clause\nhas not been satisfied in the instant facts

234A of the Act\nand incremental consequential interest under Section 234B of the Act.\n18. The learned AO has erred on the facts and in circumstances of the case and in\nlaw in giving short credit of TDS

PIRAMAL FINANCE PVT. LTD.,,MUMBAI vs. THE ACIT, CIRCLE-2(1)(2),, VADODARA

In the result, appeal preferred by the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

TDS claim should be allowed in accordance with provision of Section 199 of the Act. The ground is allowed for statistical purpose. Ground No.7 – Levy of interest/s.234A of the Act ITA No.1273/Ahd/2018 (PiramalFinance Pvt. Ltd.vs. ACIT) A.Y.– 2014-15 - 16 – 22. The ld. AR submitted that the due date of filing of Income Tax Return for this year was extended

SHRI RUSHABHDEV SWETAMBAR MURTIPUJAK JAIN SANGH,AHMEDABAD vs. THE ITO, WARD-2 (EXEMPTION), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar&Shri Makarand V. Mahadeokar

234A, 234B, 234C of the Act. 5. Aggrieved by the assessment order passed under section 144 read with section 147, the assessee preferred an appeal before the learned CIT(A). The assessee raised multiple legal and factual grounds, contending that the reopening of assessment under section 147 was invalid and that the addition of Rs. 75,41,227/- made

ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

234A of the Act. 12. On the facts and circumstances of the case and in law, the Ld. AO erred in computing an interest of INR 23,048 under section 234C of the Act. The Appellant prays that the Ld. AO be directed to delete the interest of INR 23,048 computed under section 234C

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, CIRCLE (INTERNATIONAL TAXATION-1), AHMEDABAD

In the result, Ground No. 10 of the assessee’s appeal is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

234A of the Act and incremental consequential interest under Section 234B of the Act. Shell International B.V. vs. ACIT (International Taxation) Asst.Year –2020-21 - 4– 20. The learned AO has erred on the facts and in circumstances of the case and in law in giving short credit of TDS

ROTOMAG MOTORS & CONTROLS (P) LTD.,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

Appeal is allowed

TDS was deducted in AY 2014-15,\nthe right to receive the interest was under dispute and the amount was not\nactually received. The assessee has brought on record ledger accounts and\nsupporting documents evidencing that the amount was finally recognised\nand offered to tax in AY 2017-18 upon resolution of the dispute.\n6.5.5 In principle, the submission

CHIRAG MAHENDRABHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(2)(1),, AHMEDABAD

In the result, the appeal filed by the assessee is allowed for statistical purpose

TDS amount of Rs. 2,96,734/- was not duly given credit by the CPC Centre. Aggrieved by this intimation order the assessee filed an rectification application under Section 154 on 03.07.2015 to the jurisdictional AO namely ITO, Ward-4(2)(1) and also e-filed rectification to the CPC Centre Bangalore. The assessee also claimed that the CPC Centre

LUBRIZOL ADVANCED MATERIALS INC.,MUMBAI vs. THE ACIT (INTERNATIONAL TAXATION), VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 2455/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2015-16 Lubrizol Advanced Materials Inc., A.C.I.T(International C/O. 6Th & 7Th Floor, Vs. Taxation), Jaswanti Landmark, Vadodara. Mehra Industrial Estate, Lbs Marg, Vikhroli (West), Mumbai-400079. Pan: Aabcl7375B

234A of the Act. 10. On the facts and in the circumstances of the case and in law, the Ld.AO erred in computing consequential interest under Section 234B of the Act. 11. On the facts and circumstances of the case and in law, the ld.AO erred in computing tax liability, by erroneously considering a refund of Rs.976,810 without appreciating