JCIT(OSD), CIR-3(1)(2), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE (INDIA) LTD, HARYANA

In the result, appeal of the Revenue is dismissed

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

gains tax on the Appellant, it is a condition precedent that the consideration on transfer of alleged capital assets must have been received by the Appellant from the resulting company, which condition is not satisfied in the present case. ITA Nos. 1184/Ahd/2018 & 1225/Ahd/2018 Assessee : Reckitt Benckiser Healthcare (I) Ltd Asst. Year : 2011-12 - 5– 1.8 Without prejudice to above

SHRI NAVINCHANDRA N. PATEL,VADODARA vs. THE ACIT, CIRCLE-1(2), VADODARA

In the result, the appeal of the assessee is allowed

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

deemed to be the full value of the consideration received or accruing as a result of the transfer of the capital asset. The fair market value of the above non agriculture land on the date of (Conversion i.e. 03.02.2010 and 20.02.2010 relevant to asst, year 2010-11, was taken as at jantri rate, for that land which stands

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

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

dividend, which were claimed on the sale of shares as discussed above, and finally claimed as exempt. Further, it is also noticed that maximum fund was accumulated by the assessee in the shape of FDRs etc. It was also noted that these funds are still with the assessee trust and in the control of trustee, and has not been utilised

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

dividend, which were claimed on the sale of shares as discussed\nabove, and finally claimed as exempt. Further, it is also noticed that\nmaximum fund was accumulated by the assessee in the shape of FDRs\netc. It was also noted that these funds are still with the assessee trust\nand in the control of trustee, and has not been utilised

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

dividend, which were claimed on the sale of shares as discussed\nabove, and finally claimed as exempt. Further, it is also noticed that\nmaximum fund was accumulated by the assessee in the shape of FDRs\netc. It was also noted that these funds are still with the assessee trust\nand in the control of trustee, and has not been utilised

SHAMA AJAY PATEL,AHMEDABAD vs. THE CIT(IT & TP), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2017-18 Shama Ajay Patel, Vs. 2, Chandroday Society, The Cit(It & Tp), Opp. Golden Triangle, Sp Ahmedabad Stadium Road, Navjivan Post, Ahmedabad-380014 Pan : Alxpp 5273 E अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Sunil Talati, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 01.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 26.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income-Tax (It & Tp), Ahmedabad [Hereinafter Referred To As Ld. "Cit(It & Tp)" For Short] Dated 08.02.2023, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Challenging The Impugned Order Of The Ld. Cit (It & Tp) Reads As Under:- “1. The Ld. Cit Has Erred In Passing Order U/S 263 Without Jurisdiction & Appropriate Powers Available Under The Act. It Is Submitted That The Order Passed U/S. 263 Is Bad In Law As A.O. Has Neither Committed Any Error Nor It Is Prejudicial To The Interest Of Revenue. It Be Held Now.

deemed to be erroneous in so far as it is prejudiced to the interests of the revenue, if the order is passed without making inquiries or verification which should have been made or if the order is passed allowing any relief without inquiring into the claim. The AO while passing the order did not consider the provisions

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

dividend income, holding that such quantum of exempt income could not have been earned without some administrative effort. Accordingly, the CIT(A) upheld the disallowance but directed that it be allocated between Guwahati and the taxable unit in the ratio of their sales. ITA Nos. 847to850/Ahd/2025 & 912to915/Ahd/2025 DCIT vs. Eris Lifesciences Ltd. Eris Lifesciences Ltd. vs. DCIT Asst. Years

DCIT CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT , BODAKDEV AHMEDABAD

Appeal are dismissed

dividend income, holding that such quantum of exempt\nincome could not have been earned without some administrative effort.\nAccordingly, the CIT(A) upheld the disallowance but directed that it be\nallocated between Guwahati and the taxable unit in the ratio of their sales.\nHowever, with respect to MAT computation, the CIT(A) relied on Gujarat\nHigh Court in Gujarat Fluorochemicals

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

Appeal are dismissed

dividend income, holding that such quantum of exempt\nincome could not have been earned without some administrative effort.\nAccordingly, the CIT(A) upheld the disallowance but directed that it be\nallocated between Guwahati and the taxable unit in the ratio of their sales.\nHowever, with respect to MAT computation, the CIT(A) relied on Gujarat\nHigh Court in Gujarat Fluorochemicals

M/S. SHRI RANG INFRASTRUCTURE PVT. LTD.,,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

capital gain and made the addition. The Assessing Officer also observed that the assessee has given loan of Rs.1,04,78,866/- to Ms. Tapasvi A. Patel who is one of the Directors having voting power exceeding 10% of the total shares and Rs.41,64,532/- to Shri Arvindbhai T. Patel who is a shareholder having voting power exceeding

ANANG KUNJVIHARIBHAI SHAH,AHMEDABAD vs. THE ITO, WARD-7(2)(1) (PREVIOUSLY DCIT, CIRCLE-1(1)(2)), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalincome-Tax Officer, Anang Kunjviharibhai Shah, Vs. Ward 7(2)(1), 1, Friends Colony, Sm Road, Vejalpur, Ahmedabad Ambawadi, Ahmedabad-380015 [Pan: Acups 2559 J] (Previously Dcit, Cir. 1(1)(2)) (Appellant) .. (Respondent) Appellant By: Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr. Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026

deemed dividend u/s. 2(22)(e) of the Act.” 2 Anang Kunjviharibhai Shah Vs. ITO A.Y : 2015-16 3. The brief facts of the case are that the assessee is an individual who filed his return of income for A.Y. 2015-16 on 31.10.2015 declaring a total income of Rs. 2,63,18,720/-. The assessee derives income from salary

ATUL GOVINDJI SHROFF,VADODARA vs. THE DCIT, CENTRAL CIRCLE-3, VADODARA

In the result, appeal filed by the Assessee is dismissed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

capital gain, income from other sources, special rate income (dividend income u/s 115BBDA and also exempt interest from PPF) but there appears to be no mention of any agricultural income or any income from sale of milk or other dairy products. Thus the claim of the appellant that there is sale of milk and vegetables in the farm

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

dividend income / income from mutual funds which does not form part of the total income as contemplated under Section 14A. The Assessing Officer can adopt a reasonable basis for effecting the apportionment. While making that determination, the Assessing Officer shall provide a reasonable opportunity to the assessee of producing its accounts and relevant or germane material having a bearing

ARVINDKUMAR AMULKH TANNA,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-2 (3), AHMEADABAD

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

Capital Gain (LTCG) may kindly be deleted and the direction given by the Ld. CIT (A) to the AO be quashed. 3. Such and further relief as the nature and circumstances of the case may justify.” (b) In ITA No.577/Ahd/2020 for AY 2015-16 “The Ld. CIT (A) has grossly erred in law and on facts in partly allowing