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7 results for “capital gains”+ Permanent Establishmentclear

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Key Topics

Section 80I28Section 54F17Section 14A8Section 143(3)5Deduction5Section 36(1)(va)4Disallowance4Addition to Income4Section 403

KIRI INDUSTRIES LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, appeal of the assessee is partly allowed

ITA 1513/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad19 Dec 2024AY 2018-19

Bench: Dr.Brr Kumarshri Tr Senthil Kumar

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsinh B Parmar, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 14ASection 234ASection 270ASection 36(1)(iii)Section 36(1)(va)Section 40

gain control of the investee company. However, that does not appear to be a relevant factor in determining the issue at hand. Fact remains that such dividend income is non-taxable. In this scenario, if expenditure is incurred on earning the dividend income, that much of the expenditure which is attributable to the dividend income has to be disallowed

Section 234A2
Section 270A2
Penalty2

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

In the result, appeal filed by the Assessee is dismissed

ITA 1443/AHD/2019[2017-18]Status: DisposedITAT Ahmedabad05 Jul 2024AY 2017-18

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

For Appellant: Shri Milin Mehta, A.RFor Respondent: Shri Kamlesh Makwana, CIT/DR
Section 132Section 143(3)Section 2Section 234ASection 234BSection 270ASection 54F

capital gain of Rs. Nil as the assessee has reinvested the consideration in a residential property at Colaba, Mumbai u/s. 54F of the Act of Rs. 14,14,55,783/-. On verification of the claim of the assessing officer held that the assessee already owned two residential properties namely (i) House no. 1028, Bhaili Road, Raipura, Vadodara (“the Raipura House

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

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

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:-

Section 250

Gain earned from transfer of their shares to the assessee company. 13) Whether on the facts and the circumstances of the case and in law, the Id. CIT (A) has erred in deleting addition of Rs. 14,87,29,364/- on account of adjustment for allocation of common expenses while computing deduction/exemption u/s 80IC, 801E and 10AA

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

ITA 712/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

permanency and therefore, capital expenditure is closely akin to the concept of securing a tangible or intangible property or corporeal or incorporeal right, so that they could be of a lasting or enduring benefit to the enterprise in issue. The said principle laid down in I.T.A Nos.712 & 741 /Ahd/2019 A.Y. 2015-16 44 Sun Pharma Labs. Ltd. vs. DCIT Empire

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

ITA 741/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad09 Oct 2024AY 2015-16

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 115JSection 143(3)Section 14ASection 36(1)(va)Section 37(1)Section 80Section 80I

permanency and therefore, capital expenditure is closely akin to the concept of securing a tangible or intangible property or corporeal or incorporeal right, so that they could be of a lasting or enduring benefit to the enterprise in issue. The said principle laid down in I.T.A Nos.712 & 741 /Ahd/2019 A.Y. 2015-16 44 Sun Pharma Labs. Ltd. vs. DCIT Empire

DCIT CC- 1(3), AAYKAR BHAWAN vs. MONTECARLO LIMITED, MONTECARLO HOUSE, SINDHU BHAWA

In the result, the appeal filed by the revenue in ITA

ITA 598/AHD/2023[2018-19]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

Section 143(3)Section 80I

capital expenditure. Thus the disallowance made by the Ld AO is a Revenue neutral following the ratio of Supreme Court Judgment in the case of Excel Industries, as the assessee is a company and assessed to tax at the same rate for all the previous and subsequent assessment years. Therefore the addition of Rs.37,28,56,145/- made

DCIT CC- 1(3), AAYKAR BHAVAN vs. MONTECARLO LIMITED , SINDHU BHAWAN ROAD, BODAKDEV

In the result, the appeal filed by the revenue in ITA

ITA 599/AHD/2023[2020-21]Status: DisposedITAT Ahmedabad27 Sept 2024AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V Mahadeokar (Accountant Member)

Section 143(3)Section 80I

capital expenditure. Thus the disallowance made by the Ld AO is a Revenue neutral following the ratio of Supreme Court Judgment in the case of Excel Industries, as the assessee is a company and assessed to tax at the same rate for all the previous and subsequent assessment years. Therefore the addition of Rs.37,28,56,145/- made