RECKITT BENCKISER HEALTHCARE INDIA PVT. LTD., ( FORMERLY KNOWN AS RECKITT BENCKISER HEALTHCARE INDIA LTD.,),HARYANA vs. DCIT, CIRCLE-3(1)(2), AHMEDABAD

In the result, appeal of the Revenue is dismissed

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

90,963/- whereas the liability of Treasury Segment were reflected at Rs. Nil. Thus, it appears that the liabilities of Rs. 37,15,82,049/- as on 31/3/2009 were got reduced to Rs. Nil on 31/03/2010. The A.O has correctly observed that there is no corresponding reduction in assets or income generated as per trial balance of the appellant that

AARK INFOSOFT PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2017-18 Vs. Aark Infosoft Private Limited, The Acit, 45, Shetrunjay, 2Nd Floor, Above Circle-1(1)(1), Central Bank Of India, Bhattha Ahmedabad Cross Road, Paldi, Ahmedabad Gujarat-380007 Pan : Aahca 9986 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Divyang Shah, Ar Revenue By : Shri Santosh Kumar, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 08.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 21.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 27.07.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Are As Under:- “1. Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Issuing A Notice U/S 143(2) Of The Act? 2. Whether On The Facts & In Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Making Disallowance Of Employees' Contribution To Pf & Esic Of Rs.5,51,657/- U/S 36(1) (Va) Of The Act?

TDS u/s 40(a)(ii) of the Act? 5. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making disallowance of Rs. 17,790/- for penalty expenses? 6. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making addition

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 under Section 194 of the Act. The four directors of the appellant company namely Mr. Pvaveen T. Kotak, Mr. Jayesh T. Kotak, Mr. Jatin M. Gupta & Mr. Amit M. Gupta are the common and beneficial shareholder in the assessee company as well as subsidiary companies. The case of the Revenue is this that the payment by way of loans

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 under Section 194 of the Act. The four directors of the appellant company namely Mr. Pvaveen T. Kotak, Mr. Jayesh T. Kotak, Mr. Jatin M. Gupta & Mr. Amit M. Gupta are the common and beneficial shareholder in the assessee company as well as subsidiary companies. The case of the Revenue is this that the payment by way of loans

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

90,54,752/- on account of corpus donation holding that the assessee is eligible for exemption u/s.11(1)(d) of the Act as the assessee not covered by proviso to section 2(15) of the Act donation received towards corpus cannot be held as income. 4. Whether on the facts and in circumstances of the Ld. CIT(A), NFAC

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

90. The CIT(A) accepted the assessee’s submission and deleted the disallowance of Rs.8,70,747/- made under section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted

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

90. The CIT(A) accepted the assessee’s submission and deleted the disallowance of Rs.8,70,747/- made under section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

90,334/- 4. Ld. AO / DRP erred in law and on facts in confirming addition of Rs.3,99,455/- of testing charges u/s 195 for non-deduction of TDS by invoking Explanation 2 to Section

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

2. Levy of interest under section 234B of the Act On the facts and circumstances of the case and in law, the Hon'ble CIT(A)/Ld. AO erred in levying interest under section 234B of the Act amounting to INR 55,60,425 on the incremental income offered to tax in I.T.A No. 466/Ahd/2025 A.Y. 2016-17 Page

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

SHREE HARI ENTERPRISE ,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is partly allowed in the\nfollowing terms:\n\ni) Issue No

90,941/-, the A.O. has verified issue of TDS in partial manner,\ntherefore, in view of clause (a) to Explanation 2 of section

OIL & NATURAL GAS CORPORATION LTD.,,AHMEDABAD vs. THE ITO-2 (INTERNATION TAXATION), AHMEDABAD

In the result the appeal filed by the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 1881-1882/Ahd/2019 िनधा"रण वष"/Asstt. Years: N.A Oil & Natural Gas Corporation Income Tax Officer-2, Limited, Vs. (International Taxation), Institute Of Reservoir Studies, Ahmedabad. Chandkheda Campus, Ahmedabad-380005. Pan: Aaaco1598A

TDS under the provisions of section 195 of the Act. It was contended by the assessee that in pursuance to the provisions of section 90(2

OIL & NATURAL GAS CORPORATION LTD.,,AHMEDABAD vs. THE ITO-2 (INTERNATION TAXATION), AHMEDABAD

In the result the appeal filed by the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 1881-1882/Ahd/2019 िनधा"रण वष"/Asstt. Years: N.A Oil & Natural Gas Corporation Income Tax Officer-2, Limited, Vs. (International Taxation), Institute Of Reservoir Studies, Ahmedabad. Chandkheda Campus, Ahmedabad-380005. Pan: Aaaco1598A

TDS under the provisions of section 195 of the Act. It was contended by the assessee that in pursuance to the provisions of section 90(2

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

90,35,110/- and claiming deduction u/s 80IA of Rs. 2,97,41,167/-. The case of the assessee was selected by Revenue for framing scrutiny assessment. The AO issued statutory notices u/s 143(2) and 142(1) of the 1961 Act. The assessee has claimed deduction under section 80IA . The assessee has incurred 3 CO. No.209/Ahd/2011

KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

90,35,110/- and claiming deduction u/s 80IA of Rs. 2,97,41,167/-. The case of the assessee was selected by Revenue for framing scrutiny assessment. The AO issued statutory notices u/s 143(2) and 142(1) of the 1961 Act. The assessee has claimed deduction under section 80IA . The assessee has incurred 3 CO. No.209/Ahd/2011

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

90,35,110/- and claiming deduction u/s 80IA of Rs. 2,97,41,167/-. The case of the assessee was selected by Revenue for framing scrutiny assessment. The AO issued statutory notices u/s 143(2) and 142(1) of the 1961 Act. The assessee has claimed deduction under section 80IA . The assessee has incurred 3 CO. No.209/Ahd/2011

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

90,000/- on India Glycols Ltd. and Rs. 44,550/- on M/s Petron Engineering Construction Ltd. These five invoices represent service charges for actual work done by the assessee to these unrelated parties. The AO has ignored these five invoices and picked up only three invoices of Rs. 24,000/- each for determining the benchmark rate

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

90,000/- on India Glycols Ltd. and Rs. 44,550/- on M/s Petron Engineering Construction Ltd. These five invoices represent service charges for actual work done by the assessee to these unrelated parties. The AO has ignored these five invoices and picked up only three invoices of Rs. 24,000/- each for determining the benchmark rate