DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

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

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

37(1). 4.2. Without prejudice to the above, the Ld. CIT(A) ought to have allowed additional depreciation under section 32(1)(iia) on such capital expenditure disallowed. 5. Re: Disallowance on account of alleged Bogus Purchases

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

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

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

37(1). 4.2. Without prejudice to the above, the Ld. CIT(A) ought to have allowed additional depreciation under section 32(1)(iia) on such capital expenditure disallowed. 5. Re: Disallowance on account of alleged Bogus Purchases

ALANG STEEL RECYCLING PRIVATE LIMITED,BHAVNAGAR vs. THE PR. CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalalang Steel Recycling The Pr. Cit-1, Private Limited Vs. Ahmedabad – 380 015 Ground Floor, Shop No.G-1 Sukun-1, Bhilwara Circle Bhavnagar – 364 001 [ Pan: Aamca 4837 A ] (Appellant) .. (Respondent) Assessee Represented By : Shri Parimalsinh B. Parmar, Ar Revenue Represented By : Shri R.P. Rastogi, Cit-Dr 08.12.2025 Date Of Hearing Date Of Pronouncement 16.01.2026

1). Alang Steel Recycling Private Limited vs. Pr.CIT A.Y: 2018-19 10.10. In view of the foregoing discussion, we hold that the Assessing Officer, after examining the issue of alleged bogus purchases during the reassessment proceedings, has taken a legally permissible and plausible view by disallowing the entire amount of ₹77,61,745/- under section 37

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

37(1) of the Act, particularly when the genuineness of\nexpenditure was in doubt. It was held that the possibility of a personal or\nnon-business element in such expenditure could not be ruled out.\nConsequently, 10% of the aggregate amount of site and site development\nexpenses, i.e., Rs. 13,47,839/-, was disallowed and added to the total\nincome

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

37(1) of the Act, particularly when the genuineness of\nexpenditure was in doubt. It was held that the possibility of a personal or\nnon-business element in such expenditure could not be ruled out.\nConsequently, 10% of the aggregate amount of site and site development\nexpenses, i.e., Rs.13,47,839/-, was disallowed and added to the total\nincome

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

37(1) of the Act, particularly when the genuineness of\nexpenditure was in doubt. It was held that the possibility of a personal or\nnon-business element in such expenditure could not be ruled out.\nConsequently, 10% of the aggregate amount of site and site development\nexpenses, i.e., Rs.13,47,839/-, was disallowed and added to the total\nincome

DCIT CIRCLE-3(3), AHMEDABAD vs. SHRI ALPESHKUMAR C.PATEL, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Shri T.R. Senthil Kumarआयकर अपील सं./Ita No. 1908/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2011-2012 Alpeshkumar C. Patel, A.C.I.T., 503, Milestone Building, Vs. Circle-3(3), Drive In Road, Ahmedabad. Thaltej, Ahmedabad-380052. Pan: Aeapp9489G

1,10,77,526/- plus 15 lacs. 15.8 It is also important to note that the assessee has purchased the property only in the month of March 2010 and the possession of the same was handed over to the company namely DBS in the month of May/June 2010. This fact has not been disputed by any of the authorities below

THE ITO, WARD-1(4),, AHMEDABAD vs. M/S. DISHMAN INFRASTRUCTURE LTD.,, AHMEDABAD

In the result, appeal of the Revenue and its cross objections are dismissed, whereas the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Amarjit Sinh

1. This very decision has been referred by the ITAT in the case of Zaveri & co. (supra). Thus, first head under which the ld.AO has examined the case of the assessee is not justifiable head for rejecting the claim. 12. In the next line of reasoning, the ld.AO has observed that the assessee has infringed SEZ Act and Rules while

DISHMAN INFRASTRUCTURE LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(4),, AHMEDABAD

In the result, appeal of the Revenue and its cross objections are dismissed, whereas the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav, Vice- & Shri Amarjit Sinh

1. This very decision has been referred by the ITAT in the case of Zaveri & co. (supra). Thus, first head under which the ld.AO has examined the case of the assessee is not justifiable head for rejecting the claim. 12. In the next line of reasoning, the ld.AO has observed that the assessee has infringed SEZ Act and Rules while

THE DCIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LA RENON HEALTHCARE PVT. LTD.,, AHMEDABAD

In the result, all the revenue’s appeals are dismissed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

bogus expenses as correctly been made applicable to the instant case. Reliance were also placed by the Learned CIT(A) on the judgment passed by the Hon’ble Delhi High Court in the matter of CIT-vs-Siddartha Trade Links (Pvt.) Ltd. reported in [2012] 206 Taxman 92 (Delhi). While holding that the assessee had duly established that sufficient services

THE DY. CIT, (OSD)-I, CIRCLE-4,, AHMEDABAD vs. M/S. LA RENON HEALTHCARE PVT. LTD.,, AHMEDABAD

In the result, all the revenue’s appeals are dismissed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

bogus expenses as correctly been made applicable to the instant case. Reliance were also placed by the Learned CIT(A) on the judgment passed by the Hon’ble Delhi High Court in the matter of CIT-vs-Siddartha Trade Links (Pvt.) Ltd. reported in [2012] 206 Taxman 92 (Delhi). While holding that the assessee had duly established that sufficient services

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

37. We have heard the rival contention of both the parties and perused the materials available on record. It is the 2nd round of litigation before us on the issue whether interest income should be excluded while computing the deduction under section 80 IA of the Act after netting of the expenses. Admittedly, the ITAT in the original proceedings under

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

37. We have heard the rival contention of both the parties and perused the materials available on record. It is the 2nd round of litigation before us on the issue whether interest income should be excluded while computing the deduction under section 80 IA of the Act after netting of the expenses. Admittedly, the ITAT in the original proceedings under

THE ACIT, CENTRAL CIRCLE-2(1), AHMEDABAD vs. M/S. DINESHCHANDRA R AGRAWAL INFRACON PVT. LTD., AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 85/Ahd/2021 िनधा"रणवष"/Asstt. Year: 2013-14

37,861/- which consists of the returned income of Rs.33,59,86,450/- (inclusive of surrender of Rs.11,87,02,925/-) and additions of Rs.27,71,51,411/-. Further, in the assessment order, the AO has initiated the penalty proceedings stating issuing the notice u/s. 271(1)(c) of the I.T. Act separately. Further noticed that neither in the assessment

M/S. WORLD TRADE IMPEX LTD.,,BARODA vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, CIRCLE-5,, BARODA

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

bogus. Furthermore, the assessee cannot ITA nos.1580/AHD/2016 & 639/Ahd//2012 A.Y. 2003-04 14 be made subject to the addition if the party does not respond to the notice issued by the revenue. As such the revenue has been given ample power under the statute for collecting the information from the concerned party. In the present case, the AO should have

WORLD TRADE IMPEX LTD.,,BARODA vs. THE ACIT.,CIRCLE-4,, BARODA

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmed

bogus. Furthermore, the assessee cannot ITA nos.1580/AHD/2016 & 639/Ahd//2012 A.Y. 2003-04 14 be made subject to the addition if the party does not respond to the notice issued by the revenue. As such the revenue has been given ample power under the statute for collecting the information from the concerned party. In the present case, the AO should have

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention

HAJIMOHMADSAFI ABDULREHMAN SHAIKH,VADODARA vs. DEPUTY COMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

bogus purchases had been set aside in entirety by the Hon’ble ITAT for fresh adjudication and therefore the earlier relief granted by the CIT(A) stood merged with the order of the Tribunal. It was observed that the Assessing Officer had rightly re-examined the entire issue in accordance with the directions of the ITAT and hence the contention