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

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 that all the four investee companies were dormant, and no expenditure could be said to have been incurred

CHIRAG MAHENDRABHAI SHAH,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(2)(1),, AHMEDABAD

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

7. Under sub-section (1) of Section 200 any person deducting tax at source would pay within the prescribed time the said sum to the credit of the Central Government under sub-section (3) of Section 200 such person would file periodic statements of tax deducted at source. Sub-section (1) of Section 203 requires every person deducting

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

7– (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply.” 13. The term “under-reporting” is defined in sub-Section (2) which provides seven situations wherein a person is considered to have under-reported his income. Sub-Section (8) provides

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

7 to section 43(1), sixth proviso to section 32(1), section 49(1)(iii)(e), and Explanation 2 to section 43(6), asserting that the cost or WDV in the hands of the amalgamating company should be taken as nil. We find that these provisions apply to tangible assets transferred in amalgamation, not to newly recognised intangible assets like

MIRANT NAVINBHAI PARIKH,VADODARA vs. THE DCIT ,CIRCLE INT.TAXA., VADODARA

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta, Accountnat Member & Shri T.R.Senthil Kumar

7. Under sub-section (1) of Section 200 any person deducting tax at source would pay within the prescribed time the said sum to the credit of the Central Government under sub-section (3) of Section 200 such person would file periodic statements of tax deducted at source. Sub-section (1) of Section 203 requires every person deducting

KIRI INDUSTRIES LTD.,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

94,666/- under Section 36(1)(va), a disallowance of Rs. 57,74,100/- concerning commission paid to non-residents and a sum of Rs. 35,18,785/- under Section 36(1)(iii) of the Act. 4. Subsequently, upon reviewing the records, Principal CIT noted that the Auditors of Kiri Industries i.e. the assessee had certified that an interest amount

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 274 r.w.s 271(l)(c) of the Act against the Appellant. The Appellant reserves the right to add, amend, alter or vary all or any of the above grounds of appeal as they or their representative may think fit.” 79. We observe that all the issues covered in the grounds of appeal for Assessment Year 2013-14, barring

THE DY.CIT (INT.-TAXA.)-1, , AHMEDABAD vs. ZYDUS LIFSCIENCE LTD. (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.), AHMEDABAD

In the result, the appeal of the revenue is hereby dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmed

TDS provisions under section 195 of the Act. In holding so, we draw support and guidance from the judgment of Hon’ble Delhi High Court in the case of DIT Vs. Nokia Networks OY reported in 358 ITR 77 wherein it was observed that the transaction of software purchase on principal-to-principal basis cannot be considered as royalty payment

OFFICE OF THE GEOLOGIST,SABARKANTHA vs. THE ITO (TDS), GANDHINAGAR

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

Bench: Shri P.M. Jagtap, Vice- & Ms. Madhumita Royassessment Year : 2011-12

TDS), B-Block, Third Floor, Vs 401, Udyog Bhawan, Bahumali Bhavan, Hajipura, Sector-11, Gandhinagar Himatnagar, Sabarkantha-383001 PAN : AAALO 0111 G अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri S.N. Divatia, AR Revenue by : Shri Mukesh Thakwani, Sr. DR सुनवाई क" तार"ख/Date of Hearing : 14/07/2022 घोषणा क" तार"ख /Date of Pronouncement: 22/07/2022 आदेश

SUZLON GUJARAT WIND PARK LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed in the above\nterms

7 represent a common ground and is accordingly\nbeing disposed of.\n10.\nWe have heard the rival contentions and perused the material on\nrecord. It would be useful to reproduce section 244 of the Act for ready\nreference:\nInterest on refunds.\n244A. (1) [Where refund of any amount becomes due to the assessee 94 under this Act],\nhe shall, subject