HYDCO ENGINEERING PVT. LTD.,,CHHATRAL vs. THE INCOME TAX OFFICER, WARD-2(1)(3),, AHMEDABAD

In the result, the appeal is allowed

TDS u/s 194C(6) as the details of PAN of transporter was Assessment Year : 2012-13 Page 2 of 6 obtained by the assessee company thereby complying the conditions of the law as per section

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS within stipulated time, and under section 272A(2)(g) of the Act of Rs.2,58,000/- for the alleged default of not filing quarterly statement in form no.24Q and 26Q for the financial year 2014-15 within stipulated time. Both the penalties were confirmed by the ld.CIT(A). 6

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS within stipulated time, and under section 272A(2)(g) of the Act of Rs.2,58,000/- for the alleged default of not filing quarterly statement in form no.24Q and 26Q for the financial year 2014-15 within stipulated time. Both the penalties were confirmed by the ld.CIT(A). 6

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS within stipulated time, and under section 272A(2)(g) of the Act of Rs.2,58,000/- for the alleged default of not filing quarterly statement in form no.24Q and 26Q for the financial year 2014-15 within stipulated time. Both the penalties were confirmed by the ld.CIT(A). 6

XCELLON EDUCATION LIMITED,,AHMEDABAD vs. ADDL. CIT, TDS,, AHMEDABAD

The appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

TDS within stipulated time, and under section 272A(2)(g) of the Act of Rs.2,58,000/- for the alleged default of not filing quarterly statement in form no.24Q and 26Q for the financial year 2014-15 within stipulated time. Both the penalties were confirmed by the ld.CIT(A). 6

THE DCIT, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P.INFRASTRUCTURE LTD., AHMEDABAD

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

TDS u/s 194 is not required to be made, unless the loans/advances are given to a share holder as under: "6. We have heard the rival contentions and perused the facts of the case. The arguments made by Shri Rajeev Sogani, learned Authorized Representative, appear to be convincing that section

THE ASSTT. COMMISSIONER OF INCOME TAX, TDS CIRCLE,, AHMEDABAD vs. M/S. J.P. ISCON LTD. (FORMERLY KNOWN AS J.P. INFRASTRUCTURE LTD.),, AHMEDABAD

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

TDS u/s 194 is not required to be made, unless the loans/advances are given to a share holder as under: "6. We have heard the rival contentions and perused the facts of the case. The arguments made by Shri Rajeev Sogani, learned Authorized Representative, appear to be convincing that section

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

6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee had made substantial additions to capital work-in-progress (CWIP

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

6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee had made substantial additions to capital work-in-progress (CWIP

AAKASH PURSHOTTAMBHAI VAGHELA,VADODARA vs. THE ITO, TDS-1, VADODARA

In the result, the appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 201(1)/201(1A) of the Act and total tax liability of Rs.3,19,728/- was worked out as under: - S.No. Name of the Nature of Date of Amount of TDS to be Delay in Interest u/s concern/individual payment/section payment payment deducted months 201(1A) @ involved 1% 1 Vikram P Purchase of property 30.01.2018 4025000 40250 61 24553 Mahurkar

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

6. Your Appellant reserves the right to add, alter, amend and/or withdraw any of the above Grounds of Appeal.” 3. The brief facts of the case are that the assessee is an individual who did not file return of income under Section 139 of the Act for the assessment year under consideration. Thereafter, the case of the assessee was reopened

SHRI SAMIR CHANDRAVADAB BHALAVAT,,BARODA vs. THE INCOME TAX OFFICER, SABARKANTHA WARD-4,, MODASA

In the result the appeal of the assessee is partly allowed

TDS under section 194C (6) of the Act. Accordingly the assessee did not deduct the TDS. Page 4 of 10 Asstt

DCIT, CIRCLE-1(3), , AHMEDABAD vs. EDELWEISS BROKING LTD.(ON BEHALF OF AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

6 is that the Learned CIT (A) erred in upholding the disallowance of Rs. 2,29,932/- representing the payment made to the stock exchange on account of Non-deduction of TDS under Section

M/S. EDELWEISS BROKING LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(3), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

6 is that the Learned CIT (A) erred in upholding the disallowance of Rs. 2,29,932/- representing the payment made to the stock exchange on account of Non-deduction of TDS under Section

THE DCIT, CENTRAL CIRCLE-2(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is allowed

6 Tax relief a Section 90 7a b Section 91 7b c Total (6a+6b) 6c 7 Net tax liability (5-6c) 7 8 Interest Payable a For default in furnishing the return (section 8a 234A) b For default in payment of advance tax 8b (section 234B) c For deferment of advance tax (section 8c 234C) d Total

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

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

Bench: Ms.Annapurna Gupta & T.R. Senthil Kumarasstt.Year : 2014-15 The Dcit, Cir.2(1)(1) Gujarat Apollo Industries Ltd. Ahmedabad. ‘Apollo House’ Rashmi Society Nr.Mithakhali Six Roads Navrangpura Ahmedabad 380 009. Pan : Aaacg 7248 P

TDS as per section 195(6) of the Act relating to various parties. One among this is Mr.Binod Shah, Form

THE DCIT,TDS CIRCLE,, AHMEDABAD vs. NIRMA LIMITED,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedsl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 2216/Ahd/2013 2007-08 Dcit Nirma Limited Tds Circle, Nirma House, Ashram Ahmedabad Road, Ahmedabad-380009 Pan No. Aaacn5350K Revenue By : Shri Dileep Kumar, Sr. Dr. Assessee By : Shri S. N. Soparkar, Sr. Adv. With Shri Himanshu Shah, Ar सुनवाई क" तार"ख/Date Of Hearing : 27.11.2020 घोषणा क" तार"ख /Date Of Pronouncement : 04.01.2021 आदेश/O R D E R Per Waseem Ahmed: The Appeal Has Been Filed By The Revenue For A.Y. 2007-08 Which Is Arising From The Order Of The Cit(A)-Xxi, Ahmedabad Dated 13.06.2013, In The Proceedings Under Section 201(1)/201(1A) Of The Income Tax Act, 1961 For A.Y. 2007-08 (In Short “The Act”).

6 AY: 2007-08 as assessee default on account of non-deduction of TDS under the provisions of section 201(1) of the Act. 6

CRYSTAL QUINONE PVT. LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD

In the result, the assessee’s appeal stands allowed

Bench: Shri Waseem Ahmed & M/S. Madhumita Royआयकर अपील सं./I.T.A. No. 1420/Ahd/2016 ("नधा"रण वष" / Assessment Year : 2011-12) बनाम/ Crystal Quinone Pvt. Ltd. Dcit, Cir-1(1)(2), Opp. Old Excise Chawky, Vs. Ahmedabad S.M. Road, Ahmedabad

TDS do not apply to the assessee. 9. Being aggrieved by the order of Ld. CIT (A), the assessee is in appeal before us. 10. The Ld. AR before us submitted that the assessee had furnished the PAN of all the transport contractors during the assessment proceedings as required under section 194C(6