THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD vs. TROIKAA PHARMACEUTICLAS LIMITED,, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

35. The assessee during the year under consideration has shown addition in the block of assets of plant and machinery on account of Electrical Installations and claimed depreciation on the same @ 15% amounting to Rs. 13,38,416/- and also claimed additional depreciation of Rs. 3,69,848/- only. However, the AO proposes to restrict the depreciation to the extent

THE DCIT, CIRCLE-4(1)(2), AHMEDABAD vs. TROIKAA PHARMACEUTICALS LTD, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

35. The assessee during the year under consideration has shown addition in the block of assets of plant and machinery on account of Electrical Installations and claimed depreciation on the same @ 15% amounting to Rs. 13,38,416/- and also claimed additional depreciation of Rs. 3,69,848/- only. However, the AO proposes to restrict the depreciation to the extent

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., 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

35(2AB) could not be denied solely on that basis. We have accordingly upheld the assessee’s claim and confirmed the deletion of the disallowance made by the Assessing Officer. 78. In view of our detailed findings already recorded in the preceding part of this order, no separate adjudication is required on these grounds. Accordingly, Ground No. 5 (Original

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

35(2AB) could not be denied solely on that basis. We have accordingly upheld the assessee’s claim and confirmed the deletion of the disallowance made by the Assessing Officer. 78. In view of our detailed findings already recorded in the preceding part of this order, no separate adjudication is required on these grounds. Accordingly, Ground No. 5 (Original

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

TDS on commission payment to non- residents for rendering sale service out of India. 7. Now, Revenue has come before us against the order of the CIT(A). 8. At the outset, learned AR argued that the matter is squarely covered in assessee’s own case by the co-ordinate bench for A.Y. 2010-11, wherein it is observed

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

TDS on commission payment to non- residents for rendering sale service out of India. 7. Now, Revenue has come before us against the order of the CIT(A). 8. At the outset, learned AR argued that the matter is squarely covered in assessee’s own case by the co-ordinate bench for A.Y. 2010-11, wherein it is observed

COSMOS ENGITECH PRIVATE LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(1), VADODARA, CIRCLE 1(1)(1), VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Tr Senthil Kumarcosmos Engitech Private Ltd., The Assistant Vs. Plot No.85/2, Cosmos House, Commissioner Padra Road, Atladara, Of Income Tax, Vadodara-380015. Circle-1(1)(1), Vadodara. [Pan :Aaacc7647 J] (Appellant) .. (Respondent) Appellant By : Shri Tej Shah, Ar Respondent By: Shri Rameshwar P Meena, Sr. Dr Date Of Hearing 11.11.2025 Date Of Pronouncement 27.11.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

Section 35(1)(ii) by providing accommodation entries to donors to enable them to claim false weighted deductions. This is a fresh information received by the Assessing Officer to reopen the assessment; therefore, the reopening of the assessment is good in law. 5. Regarding Ground No. 2, we find that the similar issue involving M/s Arvindo Institute of Applied Scientific

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 36(1)(viii) of the Act. The order passed by the ld.CIT(A) on this issue is therefore set aside and ground raised by the assessee is allowed. 30. Ground No.3 and 4 are raised by the assessee relating to the issue of addition made to the income of the assessee on account of mismatch in the income reported

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 36(1)(viii) of the Act. The order passed by the ld.CIT(A) on this issue is therefore set aside and ground raised by the assessee is allowed. 30. Ground No.3 and 4 are raised by the assessee relating to the issue of addition made to the income of the assessee on account of mismatch in the income reported

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 36(1)(viii) of the Act. The order passed by the ld.CIT(A) on this issue is therefore set aside and ground raised by the assessee is allowed. 30. Ground No.3 and 4 are raised by the assessee relating to the issue of addition made to the income of the assessee on account of mismatch in the income reported

DISHA RESOURCES LTD. (FORMERLY KNOWN AS ARIHANT AVENUES AND CREDIT LIMITED.),AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

Section 35(1)(ii) of Income Tax Act, 1961. 4. On 27/01/2015, the Investigation Wing Kolkata conducted survey and recorded statement of Founder and Secretary Smt. Samadrita Mukherjee Sardar who has signed the donation receipt was recorded in which she accepted that the said institute is engaged in providing bills in guise of Donation and money is routed back

DISHA RESOURCES LTD. (FORMERLY KNOWN AS ARIHANT AVENUES AND CREDIT LIMITED.),AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

Section 35(1)(ii) of Income Tax Act, 1961. 4. On 27/01/2015, the Investigation Wing Kolkata conducted survey and recorded statement of Founder and Secretary Smt. Samadrita Mukherjee Sardar who has signed the donation receipt was recorded in which she accepted that the said institute is engaged in providing bills in guise of Donation and money is routed back

CREST SPECIALITY RESINS PRIVATE LIMITED,KHEDA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), AHMEDABAD (NOW DCIT, CIRCLE 1(1)(1), AHMEDABAD), AHMEDABAD, GUJARAT

In the result, the appeal of the assessee is allowed for both the years under consideration

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

35(2AB), in view of fact that research and development facility had been approved by prescribed authority in proper format i.e. Form 3CM merely because said authority failed to send intimation to Department in Form 3CL, it would not be enough to deprive assessee’s claim of deduction.” 10. Accordingly, in light of the facts of the assessee’s case

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS on expenses incurred in relation to non-residents amounting in all to Rs.67,33,167/-, detailed at page no.26 of his order as under: Payment Amount (In Rs.) Consultancy 17,30,262 Professional Consultancy (Chemical) 15,61,712 ITA No.73 & 76/Ahd/2020, and ITA No.51 & 52/Ahd/2020 DCIT Vs. Cadila Pharmaceuticals Ltd. 3 Legal & Professional Expenses

BRIGHTECH VALVES & CONTROLS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Dr. Brr Kumar & Ms Suchitra Kamblei.Ta. No.52/Ahd/2025 (Assessment Year: 2012-13) Brightech Valves & Controls Vs. Deputy Pvt. Ltd., Commissioner Of Plot No.345, Gidc Kathwada. Income Tax, Kathwada, Circle-1(1)(1), Ahmedabad-382430. Ahmedabad.

TDS of Rs.8,730/-. During the year the Asst.Year –2012-13 - 5– assessee had claimed sales promotion expenses of Rs.61,975/- and sales commission expenses of Rs.9,54,524/-. However, during the assessment proceedings the assessee had not furnished any details despite being specifically asked vide notice u/s 142(1) dated 08.10.2019, 07.11.2019 and 15.06.2019. Subsequently, the Assessing Officer completed

CREST SPECIALITY RESINS PRIVATE LIMITED,KHEDA, GUJARAT vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(2), AHMEDABAD (NOW DCIT, CIRCLE 1(1)(1),AHMEDABAD), AHMEDABAD, GUJARAT

In the result, the appeal of the assessee is allowed for both the years under\nconsideration

1-04-2016 for furnishing of report, we consider that there is nothing\nbefore us on hand differs from the cases cited (supra) so as to take a different view on\nthis issue. Therefore, since the issue on hand being squarely covered following the\nprinciple of consistency, we find merit in the submission of the assessee and allowed\nthe claim