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

26 43. The AR submitted that the goodwill arose as a result of amalgamation of ILPL with the assessee-company pursuant to the approved scheme sanctioned by the Hon’ble Gujarat High Court vide order dated 03.10.2015 with effect from 01.04.2014. Under the approved scheme, 3,07,692 equity shares of Rs. 10/- each were issued to the shareholders

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

26,981/- being proportionate interest disallowing on account of\nadvances given for business purposes.\n4. The Learned Commissioner of Income Tax (Appeals) erred in confirming\naddition of Rs.15,16,966/- being expenditure incurred towards purchase of land\nwhich is supported by cheques etc.\n5. The Learned Commissioner of Income Tax (Appeals) erred in confirming the\naddition of Rs.6

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

26,981/- being proportionate interest disallowing on account of\nadvances given for business purposes.\n4.\nThe Learned Commissioner of Income Tax (Appeals) erred in confirming\naddition of Rs.15,16,966/- being expenditure incurred towards purchase of land\nwhich is supported by cheques etc.\n5.\nThe Learned Commissioner of Income Tax (Appeals) erred in confirming the\naddition of Rs.6

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

1. The order passed by Assessing Officer pursuant to direction of Hon'ble DRP is bad in law and required to be quashed Tax Effect: N.A. 4 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

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

26,981/- being proportionate interest disallowing on account of\nadvances given for business purposes.\n4.\nThe Learned Commissioner of Income Tax (Appeals) erred in confirming\naddition of Rs.15,16,966/- being expenditure incurred towards purchase of land\nwhich is supported by cheques etc.\n5.\nThe Learned Commissioner of Income Tax (Appeals) erred in confirming the\naddition of Rs.6

GELOT AGRI EXPORTS,DEESA vs. ITO WD 1 PALANPUR, BANASKANTHA

The appeal of the assessee is allowed, while that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

TDS was reported in the tax audit report furnished by the assessee along with return of income, and the AO had also picked up the same from the tax audit report itself. The contention of the Ld.Counsel for the assessee that since the assessee’s disallowance under section 40(a)(ia) was reported in audit report furnished by the assessee

ITO, WARD-1, PALANPUR, PALANPUR vs. GELOT AGRI EXPORTS, PALANPUR

The appeal of the assessee is allowed, while that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalassessment Year : 2018-19 Ito, Ward-1 Vs. Gelot Agri Exports Palanpur, Banaskantha At 13, Aditya Complex Gujarat. Opp: Jalaram Temple Deesa 385 535. Pan : Aapfg 5455 N Assessment Year : 2018-19 Gelot Agri Exports Vs. Ito, Ward-1 At 13, Aditya Complex Palanpur, Banaskantha Opp: Jalaram Temple Gujarat. Deesa 385 535. Pan : Aapfg 5455 N

TDS was reported in the tax audit report furnished by the assessee along with return of income, and the AO had also picked up the same from the tax audit report itself. The contention of the Ld.Counsel for the assessee that since the assessee’s disallowance under section 40(a)(ia) was reported in audit report furnished by the assessee

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:-

Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2016-17. 2. The Revenue has raised the following grounds:- “1) Whether on the facts and the circumstances of the case and in law, the Id. CIT(A) has erred in deleting the upward adjustment of Rs 1

NIRMA LIMITED,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1) NOW DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

Appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2013-14 Nirma Limited, The Dy. Commissioner Of Vs. Nirma House, Ashram Road, Income-Tax, Ahmedabad-380 009 Circle-3(1)(1), Pan : Aaacn 5350 K Ahmedabad-380009 अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Sanjay Kumar, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 11.07.2024 घोषणा क" तारीख /Date Of Pronouncement: 09.10.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-12, Ahmedabad [Hereinafter Referred To As "Cit(A)" For Short] Dated 10.04.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2013-14. 2. The Effective Ground Raised By The Assessee Is As Follows:-

26,718/- and as per regular assessment is Rs. 78,31,32,108/- calculated by the appellant itself. SAT paid is 1.19% of the tax payable. The contention of the AO is correct. As per proviso to section 244A, no interest on amount of SAT is eligible. Case laws cited predate the amendment in the Act wherein clauses

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

TDS at Rs. 1,46,141/- and addition in respect of bad debt of Rs. 10,60,667/-. Thereafter, the assessee filed appeal before the CIT(A). After giving effect to CIT(A) order total income was reduced to Rs. nil after setting off of unabsorbed depreciation of Rs. 3,06,93,299/-. 3.3 The case of the assessee

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

section 40(a)(ia) of the Act. The Ld. A.R. relied upon the decision of Hon’ble Apex Court in case of Tuticorin Alkali Chemicals & Fertilizers Ltd. vs. CIT (1997) 227 ITR 172 (SC), Mc Dowell & Co. Ltd. (1985) 154 ITR 148 (SC), Virtual 400 ITR 409 and 370 ITR 547 (SC). The Ld. A.R. also relied upon the decision

INTAS BIOPHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX,CIRCLE-2(1)(1),, AHMEDABAD

In the result, appeal preferred by the assessee is allowed in part

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 865/Ahd/2016 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12) िनधा"रण वष" िनधा"रण वष" Intas The Dy. Commissioner Of बनाम बनाम/ बनाम बनाम Biopharmaceuticals Ltd. Income Tax Vs. Plot 423/P/A, Sarkhej Circle-2(1)(1), Ahmedabad Bavla Highway, Moraiya, Sanand, Ahmedabad, Gujarat, 382213 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabci4722M (Appellant) .. (Respondent) Shri Bandish Soparkar & Shri Parin अपीलाथ" ओर से /Appellant By : Shah, Ars. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr & Shri Ashish Rajesh Revar, Sr. Dr Date Of Hearing 24/07/2024 Date Of Pronouncement 07/08/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-7, Ahmedabad (In Short ‘The Cit(A)’) Dated 20.01.2016 For The Assessment Year 2011-12. Ita No. 865/Ahd/2016 [Intas Biopharmaceuticals Ltd. Vs. Dcit] A.Y. 2011-12 - 2 –

26,219/-. In the course of assessment, the assessee had filed the report of the Department of Scientific and Industrial Research (DSIR) in Form No.3CL and it was found that expenditure to the extent of Rs.313.99 lacs only was approved by the DSIR. It was explained by the assessee that the quantum of expenditure certified in Form No.3CL excluded clinical

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT. LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

iii), the same is identical to Ground No. 3 of assessee’s appeal for A.Y. 2009-10 which is decided by us. Hence, Ground No. 4 is allowed. 44. As regards Ground No. 5 of assessee’s appeal related to disallowance of Rs. 12,67,467/- on account of difference in income as per TDS certificate and books of accounts

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. DY. COMMISSIONER OF INCOME TAX,(OSD),, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

iii), the same is identical to Ground No. 3 of assessee’s appeal for A.Y. 2009-10 which is decided by us. Hence, Ground No. 4 is allowed. 44. As regards Ground No. 5 of assessee’s appeal related to disallowance of Rs. 12,67,467/- on account of difference in income as per TDS certificate and books of accounts

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

iii), the same is identical to Ground No. 3 of assessee’s appeal for A.Y. 2009-10 which is decided by us. Hence, Ground No. 4 is allowed. 44. As regards Ground No. 5 of assessee’s appeal related to disallowance of Rs. 12,67,467/- on account of difference in income as per TDS certificate and books of accounts

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

iii), the same is identical to Ground No. 3 of assessee’s appeal for A.Y. 2009-10 which is decided by us. Hence, Ground No. 4 is allowed. 44. As regards Ground No. 5 of assessee’s appeal related to disallowance of Rs. 12,67,467/- on account of difference in income as per TDS certificate and books of accounts