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, and therefore, applying provisions of section 40(a)(ia) of the Act, 30% of the said amount of Rs.15.09 crores,i.e Rs.4,52,85,292/-, was added to the income of the assessee. The AO initiated penalty proceedings for under-reporting of income in consequence of misreporting ,under section 270A(1) r.w.s 270(A)(9) of the Act. 3

INFOANALYTICA CONSULTING PRIVATE LIMITED,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the penalty u/s

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

section 270A (9) of the Act viz. (a) misrepresentation of suppression of facts and (c) claim of expenditure not substantiated by any evidence. Further, we observe that the AO has disallowed the sum of Rs.68,277/- u/s.143(3) of the Act, on account of non-deduction of TDS

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

In the result, the appeal of the assessee is allowed

3)(1)\nVs.\nAhmedabad.\n(Appellant)\n(Respondent)\nAssessee by\nShri Divyang Shah, AR\nRevenue by\nShri Umesh Kumar Agrawal,\nSr.DR\nसुनवाई की तारीख/Date of Hearing\n: 23/07/2025\nघोषणा की तारीख / Date of Pronouncement: 25/07/2025\nआदेश/ORDER\nPER MAKARAND V.MAHADEOKAR, AM:\nThis appeal has been preferred by the assessee against the order\ndated 20.02.2025 passed by the Commissioner

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 270A Parulben Vijakumar Patel vs. ITO Asst.Year –2017-18 - 3– of the Act for misreporting of income and levied penalty @ 200% of the tax payable on such under reported income. 5. In appeal before Ld. CIT(A), he dismissed the appeal of the assessee with following observations:- “6.1. Carefully considered the submission of the appellant in view

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

TDS where applicable, and that the quantitative tally of consumption and closing stock was fully maintained and verified by statutory auditors. The assessee also submitted comparative GP/NP ratios for past years and argued that the GP rate of 12.5% applied by the AO was wholly arbitrary and unsupported by historical data.\n12. We note that the CIT(A) while giving

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

In the result, all six appeals, three by the Revenue and three\nby the assessee, stand dismissed

TDS where\napplicable, and that the quantitative tally of consumption and\nclosing stock was fully maintained and verified by statutory\nauditors. The assessee also submitted comparative GP/NP ratios\nfor past years and argued that the GP rate of 12.5% applied by\nthe AO was wholly arbitrary and unsupported by historical data.\n12. We note that the CIT(A) while giving

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

In the result, all six appeals, three by the Revenue and three\nby the assessee, stand dismissed

270A of the\nAct.\n9. The appellant craves leave to add, amend, alter, edit, delete, modify or\nchange all or any of the grounds of appeal at the time of or before the\nhearing of the appeal.\n8.\nThough the assessee had taken other grounds of appeal\nalso, however, the sole and common issue raised by both the\nparties

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR, BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

270A of the Act. 9. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal. 8. Though the assessee had taken other grounds of appeal also, however, the sole and common issue raised by both the parties

MADHAV COPPER LTD.,BHAVNAGAR vs. THE INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

270A of the Act. 9. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal. 8. Though the assessee had taken other grounds of appeal also, however, the sole and common issue raised by both the parties

INCOME TAX OFFICER, WARD-1(8), BHAVNAGAR vs. MADHAV COPPER LIMITED, BHAVNAGAR

In the result, all six appeals, three by the Revenue and three by the assessee, stand dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokar

270A of the Act. 9. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any of the grounds of appeal at the time of or before the hearing of the appeal. 8. Though the assessee had taken other grounds of appeal also, however, the sole and common issue raised by both the parties

SURESH RAO,AHMEDABAD vs. INCOME TAX OFFICER, WARD-2(1)(2), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

TDS of Rs 3,75,600/- towards total tax liability and thus there is neither revenue loss to that extent nor question of underreporting of income or misreporting of income to that extent. In view of this, the maximum penalty be levied only on difference amount of Rs 2,62,362/- and not at all on entire tax liability

INEOS STYROLUTION INDIA LTD.,VADODARA vs. THE ADDIT.CIT , DELHI

In the result, appeal of the assessee is allowed

3) of the Act were satisfied before proposing a TP adjustment to the total income of the Appellant. 6. That the learned AO / TPO / DRP has erred in law and on facts in making an adjustment for the part services provided by Group CEO, CFO, Global Financial Controller and Risk Management by concluding that the intra-group services

INEOS STYROLUTION INDIA LIMITED,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

3) of the Act were satisfied before proposing a TP adjustment to the total income of the Appellant. 10. On the facts and circumstances of the case and in law, the learned AO/TPO/ DRP has erred in making an - adjustment for the part services provided by Group CEO, CFO, Global Financial Controller and Risk Management by concluding that the intra

MUKESH CHHOTELAL GUPTA,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is treated as allowed for statistical purposes

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Shri Mukesh Chhotelal Gupta The Dcit, Cir.(1)(1) Gupta Nivas Vs. Ahmedabad. Chandkheda Sabarmati Ahmedabad 380 015. Pan : Ablpg 9729 N (Applicant) (Responent) : Assessee By Shri S.N. Divatia & Shri Samir Vora, Ar : Shri Ashok Kumar Suthar, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 31/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/08/2025 आदेश आदेश/O R D E R आदेश आदेश

3 the assessee, and contended that both interest income and interest expense were consistently recognised on the mercantile basis in accordance with section 145(1) read with Tax Accounting Standard-1 (matching concept). It was further asserted that substantial loans and advances were old and that in an earlier scrutiny for A.Y. 2016-17 a similar claim under section

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)

TDS credit of INR 63,086 I.T.A No. 359/Ahd/2022 A.Y. 2018-19 5 M/s. Altera Digital Health (India) LLP (Formerly known as Allscripts (India) LLP) vs. DCIT 14. On the facts and circumstances of the case and in law, the Ld. AO erred in incorrectly computing the deemed total income under section 115JC

LYSA TRADING LLP,AHMEDABAD,GUJARAT vs. INCOME TAX OFFICER, WARD 1(2)(3), AHMEDABAD, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2022-23 Lysa Trading Llp Ito, Ward-1(2)(3) Corporate House-2, Shilp Vs Ahmedabad. Corporate Park Rajpath Rangoli Road Bodakdev Ahmedabad 380 054. Pan : Aaifl 3030 D (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar Revenue By : Shri Yogesh Mishra, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 08/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 03/07/2025 आदेश आदेश/O R D E R आदेश आदेश

section 270A of the Act. It be so held now. 3. As is evident from the perusal of the grounds raised before us, the solitary issue in the present appeal relates to treating an amount of Rs.17,08,908/-as assessee’s income from house property as opposed to the assessee’s contention that they were merely recovery of common

AMBIS TECHNOLOGIES PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, the appeal is dismissed as infructuous

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2018-19 Ambis Technologies P Ltd The Ito, C/O.Divyang J. Shah Vs Ward-1(1)(1) 201, 2Nd Floor, Devashish Complex Ahmedabad. Nr.Regenta Central Antarim Hotel Off Cg Road, Ahmedabad. Pan : Aalca 0742 K (Applicant) (Responent) : None Assessee By : Ms.Bhavnasingh Gupta, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 01/05/2025 आदेश आदेश/O R D E R आदेश आदेश

270A of the Act. 3. Aggrieved by the said assessment, the assessee filed appeal before the CIT(A). The learned CIT(A), vide order dated 28.11.2024, invoked the provisions of the newly inserted proviso to section 251(1)(a) by the Finance (No. 2) Act, 2024 and set aside the assessment order, restoring the matter to the file

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

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

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

section 92C(2) of the Act. 6. That the learned AO / TPO / DRP has erred in law and on facts in rejecting consistent benchmarking approach followed by the Appellant, rejecting functionally comparable companies and arbitrarily cherry-picking companies for the purpose of benchmarking the transaction of sale of goods to Zydus USA. 7. That the learned AO/TPO/DRP has erred

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

TDS to the extent of INR 12,344 ignoring the\nprovisions of Section 199 of the Act read with Rule 37BA of the Income-tax Rules,\n1962.\n19. The learned AO has erred on the facts and in circumstances of the case on the\nfacts and in law in increasing the tax payable amount by considering