KESHAVPRIYA CORP PVT. LTD,AHMEDABAD vs. THE ADDL.CIT, TDS, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

TDS of Rs. 6,02,000 u/s 201(1) of the Income Tax Act, 1961. ITA Nos. 181&182/Ahd/2022 Keshavpriya Corp Pvt. Ltd. vs. Addl.CIT Asst. Year –2015-16 3. Ld. Commissioner of Income Tax ( Appeals ), National Faceless Appeal Centre (NF AC ) grievously erred in law as well as in facts in upholding the order passed by Id. Assessing Officer

KESHAVPRIYA CORP PVT. LTD,AHMEDABAD vs. THE ITO, WARD-2 TDS, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

TDS of Rs. 6,02,000 u/s 201(1) of the Income Tax Act, 1961. ITA Nos. 181&182/Ahd/2022 Keshavpriya Corp Pvt. Ltd. vs. Addl.CIT Asst. Year –2015-16 3. Ld. Commissioner of Income Tax ( Appeals ), National Faceless Appeal Centre (NF AC ) grievously erred in law as well as in facts in upholding the order passed by Id. Assessing Officer

RY MIDAS METACAST PRIVATE LIMITED,AHMEDABAD vs. THE ITO, WARD-3(1)(2), AHMEDABAD

In the result, the appeal of the assessee stands allowed

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.435/Ahd/2025 िनधा"रण वष" /Assessment Year : 2021-22 Ry Midas Metacast Private The Ito बनाम/ Limited Ward-3(1)(2) V/S. A-21,Zaveri Industrial Estate Ahmedabad – 380 015 Kathwada Road Kathwada Ahmedabad – 382 415 "थायी लेखा सं./Pan: Aaecr 5807 M (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Veerabadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 07/10/2025 आदेश/O R D E R Per Sanjay Garg:

section 40(a)(ia) of the Act on the ground that the TDS is not deducted on Job work expenses of INR 28,64,747 (75,96,250 - 47,31,507) in as much as the company has duly deducted the TDS under applicable provisions on the amounts which are required to be deductible and therefore the disallowance

M S HOSTEL,NEW SAMA SAVLI ROAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(3), VADODARA, AAYAKAR BHAVAN, VADODARA

In the result, appeal preferred by the assessee is allowed

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

TDS of Rs.43,260/-. Upon deduction of the same, the remaining amount has been shown as unsecured loan obtained from Smt. Palak A Shah during the year under consideration. Relevant to mention that Smt. Palak A Shah is the Administrative Head, possesses the degree of Masters in Business Administration from University of Houston-Downtown engaged in looking upon areas related

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

260/- . The assessee has claimed deduction under section 80IA(4) of the Act , to the tune of Rs. 1,87,70,901/-. The case of the assessee was selected by Revenue for framing scrutiny assessment u/s 143(3) read with Section 143(2) of the 1961 Act. The AO has claimed to have issued and served statutory notices

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

260/- . The assessee has claimed deduction under section 80IA(4) of the Act , to the tune of Rs. 1,87,70,901/-. The case of the assessee was selected by Revenue for framing scrutiny assessment u/s 143(3) read with Section 143(2) of the 1961 Act. The AO has claimed to have issued and served statutory notices

THE ACIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

260/- . The assessee has claimed deduction under section 80IA(4) of the Act , to the tune of Rs. 1,87,70,901/-. The case of the assessee was selected by Revenue for framing scrutiny assessment u/s 143(3) read with Section 143(2) of the 1961 Act. The AO has claimed to have issued and served statutory notices

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

260/- . The assessee has claimed deduction under section 80IA(4) of the Act , to the tune of Rs. 1,87,70,901/-. The case of the assessee was selected by Revenue for framing scrutiny assessment u/s 143(3) read with Section 143(2) of the 1961 Act. The AO has claimed to have issued and served statutory notices

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. AJAY ENGG. INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

260/- . The assessee has claimed deduction under section 80IA(4) of the Act , to the tune of Rs. 1,87,70,901/-. The case of the assessee was selected by Revenue for framing scrutiny assessment u/s 143(3) read with Section 143(2) of the 1961 Act. The AO has claimed to have issued and served statutory notices

THE ACIT., PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

TDS certificates issued by Tax deductor i.e. Municipal Corporation, Irrigation Department, Road & Building Division, Salinity Control Division wherein the nature of work shown as contract and tax deducted under Section 194C of the Act which proves that the assessee company is a “Contractor” and not as a “Owner” of the project/enterprises. The Ld. DR further submitted that the assessee company

DEPUTY COMMISIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEBABAD vs. TECHNO INDUSTRIES, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Deputy Commissioner Of Techno Industries, Vs. Income Tax, Plot No.613, Phase Iv Gidc, Circle 3(1)(1), Vatva, Ahmedabad-382245. Ahmedabad. [Pan :Aacft1503 D] (Appellant) .. (Respondent) Appellant By : Shri Abhijit, Sr. Dr Respondent By: Shri Bandish Soparkar, Ar Date Of Hearing 14.08.2025 Date Of Pronouncement 25.09.2025

260/-. Subsequently, based on information received from the Investigation Wing , the Assessing Officer formed a belief that the assessee had availed bogus accommodation entries in the form of loans and advances and claimed DCIT Vs. Techno Industries Asst. Year : 2014-15 - 2– repayment thereof including interest during AY 2014-15. During reassessment proceedings, the Assessing Officer noted that the assessee