HESTER BIOSCIENCE LIMITED,MEHSANA vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

TDS under section 40(a)(ii) of the Act amounting to ₹1,75,61,505/- and this included the interest amount of Rs. 98,791/-, which is in question. Regarding the deduction under section 80G

HARISHKUMAR KHUSHALRAY BHATT,AHMEDABAD vs. THE ITO, WARD-3(3)(2) NOW WARD-3(3)(1), AHMEDABAD

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Harishkumar Khushalray Bhatt Ito, Ward-3(3)(2) P/1, Chandragupta Apartment Vs. Ahmedabad. Nr. Gordhandas Patel Hospital Vastrapur Ahmedabad. Pan : Abspb 3786 F (Applicant) (Responent) Assessee By : Shri Pritesh L. Shah, Ar : Shri Uday Kishanrao Kakne, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 07/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 15/07/2025 आदेश/O R D E R आदेश आदेश आदेश

80G was deleted on the basis of donation receipt and approval of the donee institution. As regards the addition of Rs.18,10,543/- under section 68, the CIT(A) granted partial relief and sustained the addition only to the extent of Rs.3,24,382/- in respect of three creditors whose creditworthiness remained unsubstantiated. Grounds challenging initiation of penalty proceedings were

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

80G and 80GGB of the Act for the donations made by the undertaking eligible for deduction under section 80-IA of the Act. The deduction under section 80-IA of the Act is allowed to the assessee with respect to the business referred therein is carried on by the assessee. That particular business is known as the undertaking which

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

80G and 80GGB of the Act for the donations made by the undertaking eligible for deduction under section 80-IA of the Act. The deduction under section 80-IA of the Act is allowed to the assessee with respect to the business referred therein is carried on by the assessee. That particular business is known as the undertaking which

SHRI BALASHAH BAVA SANSTHA SARVAJANIK TRUST,ANAND vs. THE CIT (EXEMPTION), AHMEDABAD

In the result, appeal of the assessee/applicant trust is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

TDS) [2023] 153 taxmann.com 496 (Bombay)/[2023] 294 Taxman 766 (Bombay)/[2023] 457 ITR 18 (Bombay)[18-07-2023], the Bombay High ITA Nos. 303&304/Ahd/2025 Shri Balashah Bava Sanstha Sarvajanik Trust vs. CIT(E) Asst. Years –N.A. - 6– Court held that when there is no limitation provided under sub-section (2) of section 279 for submission or consideration

SHRI BALASHAH BAVA SANSTHA SARVAJANIK TRUST,ANAND vs. THE CIT (EXEMPTION), AHMEDABAD

In the result, appeal of the assessee/applicant trust is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

TDS) [2023] 153 taxmann.com 496 (Bombay)/[2023] 294 Taxman 766 (Bombay)/[2023] 457 ITR 18 (Bombay)[18-07-2023], the Bombay High ITA Nos. 303&304/Ahd/2025 Shri Balashah Bava Sanstha Sarvajanik Trust vs. CIT(E) Asst. Years –N.A. - 6– Court held that when there is no limitation provided under sub-section (2) of section 279 for submission or consideration

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

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

TDS on delayed payment charges (viii) Disallowance on upgradation of software expenses (ix) Charging of interest under section 234B on book Profits u/s. 115JB (x) Loss due to foreign exchange difference rate 7. As the first five issues are being covered in assessee’s own case in ITA No. 3003/Ahd/2010 & ors. relating to A.Ys. 2003- 04 & ors., dated

GUJARAT INDUSTRIES POWER CO.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

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

TDS on delayed payment charges (viii) Disallowance on upgradation of software expenses (ix) Charging of interest under section 234B on book Profits u/s. 115JB (x) Loss due to foreign exchange difference rate 7. As the first five issues are being covered in assessee’s own case in ITA No. 3003/Ahd/2010 & ors. relating to A.Ys. 2003- 04 & ors., dated

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

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

TDS on delayed payment charges (viii) Disallowance on upgradation of software expenses (ix) Charging of interest under section 234B on book Profits u/s. 115JB (x) Loss due to foreign exchange difference rate 7. As the first five issues are being covered in assessee’s own case in ITA No. 3003/Ahd/2010 & ors. relating to A.Ys. 2003- 04 & ors., dated

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 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 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 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

ACIT, EXEMPTIONS, CIRCLE-1, AHMEDABAD, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

TDS was deducted on certain payments, the assessee can’t be said to be a profit-making organization, when the pre-activity was entirely charitable in nature. The facts being identical in this year as well, we do not find any reason to deviate from the stand as taken above by the Co-ordinate Bench in the assessee