M/S. CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

144C(3) read with Section 143(3) of the Act. The Assessing Officer observed that in respect of Transfer Pricing addition, the TPO passed an order under Section 92CA(3) of the Act on 31.12.2015 thereby quantifying an upward adjustment of Rs.60,83,440/- on International Transaction of the assessee. The Assessing Officer further made disallowance under Section 36(1

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

144C(3) read with Section 143(3) of the Act. The Assessing Officer observed that in respect of Transfer Pricing addition, the TPO passed an order under Section 92CA(3) of the Act on 31.12.2015 thereby quantifying an upward adjustment of Rs.60,83,440/- on International Transaction of the assessee. The Assessing Officer further made disallowance under Section 36(1

HAZIRA PORT PRIVATE LIMITED,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CICLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed on the above terms

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1 percent on account of forex risk without providing any reasons for such action (Without prejudice) 8.8 Not appreciating that no international transaction of obtaining loan from AEs was undertaken during the AY 2017-18 however only repayment of existing loans was undertaken 8.9 Not following the principle of consistency as laid down in several judicial precedents. 9. That

ROHIT JAYANTILAL SONI,DAHOD vs. THE ACIT, CIRCLE INTL. TAXATION, VADODARA

In the result, the appeal filed by the assessee is allowed

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Capital gain'. Therefore, the impugned action of the Ld. AO in making the impugned addition at Rs 22,01,977/- is CONFIRMED. Accordingly, the Ground No.2 raised in appeal is DISMISSED.” 5. Aggrieved against the appellate order, the assessee is in appeal before us raising the following Grounds of Appeal: 1. The Ld. CIT(Appela-13) erred

PRALAY PRADYOTKANTI GHOSH,AHMEDABAD vs. INCOME -TAX OFFICER, WARD-1, INTERNATIONAL TAXATION, AHMEDABAD

In the result, the appeal of Assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.298/Ahd/2022 "नधा"रण वष" /Assessment Year : 2018-19 Pralay Pradyotkanti Ghosh The Ito बनाम/ 22, Konark Society Ward-1 Nr. Railway Colony International Taxation V/S. Jawahar Chowk, Sabarmati Ahmedabad Ahmedabad – 380 019 "थायी लेखा सं./Pan: Abypg 6172 C (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Assessee As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-13, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 01/06/2022, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) R.W.S.144C(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As "The Act") Dated 22/10/2021 Relevant To The Assessment Year (Ay) 2018-19. Pralay Pradyotkanti Ghosh Vs. Ito (Intl.Taxation) Asst. Year : 2018-19

capital gains. The assessee also received salary income from his employer (Oceaneering International GMBH) to the tune of Rs.61,74,262/- on which TDS of Rs.18,35,210/- u/s.192 of the Act was deducted, however, the same was shown as “exempt income” in the return of income filed by the assessee. 2.1. The assessee was requested to provide details

SUZUKI MOTOR GUJARAT PVT LTD,AHMEDABAD, GUJARAT vs. PRINCIPLE COMMISSONER OF INCOME TAX, AHMEDANAD-3, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

144C(3) and 144B of the Act on the ground that the same was erroneous in so far as prejudicial to the interests of the Revenue, inasmuch as the Suzuki Motor Gujarat Pvt Ltd Vs. PCIT Asst. Year : 2018-19 - 4– Assessing Officer has failed to examine the claim of depreciation made by the assessee as a consequence of claiming

AXIS BANK LIMITED,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is partly allowed for statistical purposes

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2018-19 Axis Bank Limited, Vs. Assistant Commissioner Of “Trishul”, 3Rd Floor, Opp. Income-Tax, Samartheshwar Temple, Nr. Law Circle 1(1)(1), Garden, Ellisbridge, Ahmedabad Ahmedabad-380006 Pan : Aaacu 2414 K अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.11.2023/03.04.2024 घोषणा क" तारीख /Date Of Pronouncement: 10.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: By Way Of This Appeal, The Assessee-Appellant Has Challenged Correctness Of The Order Dated 28Th July, 2022 Passed By The Assessing Officer Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act” For Short], For The Assessment Year (Ay) 2018-19. 2. Ground No.1 Raised By The Assessee Reads As Under:- “1. Disallowance In Respect Of Annual Technical Fees (Tax Effect - Rs. 16,84,276) 1.1 The Learned Drp Has Erred In Upholding Addition Made By Ao In Respect Of Treating Annual Technical Services (Ats) Fees Paid To Infosys Limited To The Extent Of Rs. 48.66 Lacs As Prior Period Expense. 1.2. It Is Submitted That The Expenditure Relates To Amount Payable To Infosys & No Part Of The Amount Was Claimed As Expenditure At Any Time In The 2 Axis Bank Limited Vs. Acit Ay : 2018-19

144C(5) The DRP procedure can only be initiated by an assessee objecting to the draft assessment order. This would enable correction in the proposed order (draft assessment order) before a final assessment order is passed. Therefore, we are of the view that in the present facts this issue could be agitated before and rectified

PRABODH MOHANLAL SHAH,VADODARA vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE INTL. TAXATION, VADODARA

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

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

section 144C(1) of the Income Tax Act, 1961 relating to the Asst. Year 2018-19. I.T.A No. 331/Ahd/2022 A.Y. 2018-19 Page No 2 Prabodh Mohanlal Shah vs. ACIT 2. Brief facts of the case is that the assessee is a Non Resident Indian residing in United States of America has shown Long Term Capital Gain

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ARVIND LIMITED, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

Section 250 of the Income- tax Act, 1961 [hereinafter referred to as "the Act" for short] dated 23.01.2024 for Assessment Year (AY) 2018-19. Since the issues are common and appeals are inter-connected, the same are being disposed of by this common order for the sake of convenience. ITA No. 349 & 466/Ahd/2024 Assessee : Arvind Limited Asst. Year

ARVIND LIMITED,AHMEDABAD vs. NFAC, DELHI PRESENT JURISDICTION THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

Section 250 of the Income- tax Act, 1961 [hereinafter referred to as "the Act" for short] dated 23.01.2024 for Assessment Year (AY) 2018-19. Since the issues are common and appeals are inter-connected, the same are being disposed of by this common order for the sake of convenience. ITA No. 349 & 466/Ahd/2024 Assessee : Arvind Limited Asst. Year

THE ACIT, ANAND CIRCLE,, ANAND vs. M/S. CHHOTABHAI JETHABHAI PATEL & CO.,, KHEDA

In the result, the appeal of the revenue is dismissed

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

144C(1) r.w.s. 92CA(3) vide order dated 05/03/2021 passed for the assessment year 2014-15. I.T.A No. 201/Ahd/2021 A.Y. 2014-15 Page No. 2 ACIT vs. M/s. Chhotabhai Jethabhai Patel & Co. 2. The grounds of appeal are as under:- “1. Whether on the facts and in the circumstances of the case

AHMED MAHOMED PANDOR,BHARUCH vs. ACIT, CIRCLE INT.TXN., VADODARA, BARODA

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1.आयकर अपील सं /Ita No.1667/Ahd/2025 – By Revenue 2.आयकर अपील सं /Ita No.1602/Ahd/2025 – By Assessee (िनधा"रण वष" /Assessment Year : 2016-17) 1. The Acit 1. Ahmed Mahomed बनाम (Internation Taxation) Pandor / Vadodara – 390 007 Moti Masjid Falia V/S. Jitali Ankleshwar Bharuch – 393 001 2. Ahmed Mahomed 2. The Acit Circle Pandor Int. Txn, Ankleshwar Vadodara – 390 007 Bharuch – 393 001 "थायी लेखा सं./Pan: Cwupp 2469 N (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Rasesh Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Are Cross-Appeals One By The Revenue & The Other By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/06/2025 Passed U/S.250 Of The Income Tax

gains (LTCG) earned by the assessee on sale of land. 3. Being aggrieved by the said order of the Ld. CIT(A), the Revenue has come in appeal agitating the action of the Ld. CIT(A) ibn deleting the impugned addition made by the AO, whereas, the assessee has filed the appeal raising legal grounds relating to the validity

ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATION TAXATION) VADODARA, VADODARA vs. AHMED MAHOMED PANDOR, BHARUCH

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha1.आयकर अपील सं /Ita No.1667/Ahd/2025 – By Revenue 2.आयकर अपील सं /Ita No.1602/Ahd/2025 – By Assessee (िनधा"रण वष" /Assessment Year : 2016-17) 1. The Acit 1. Ahmed Mahomed बनाम (Internation Taxation) Pandor / Vadodara – 390 007 Moti Masjid Falia V/S. Jitali Ankleshwar Bharuch – 393 001 2. Ahmed Mahomed 2. The Acit Circle Pandor Int. Txn, Ankleshwar Vadodara – 390 007 Bharuch – 393 001 "थायी लेखा सं./Pan: Cwupp 2469 N (अपीलाथ(/ Appellant) (") यथ(/ Respondent) Assessee By : Shri Rasesh Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/12/2025 घोषणा की तारीख /Date Of Pronouncement: 09/03/2026 आदेश/O R D E R Per Sanjay Garg: The Present Are Cross-Appeals One By The Revenue & The Other By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/06/2025 Passed U/S.250 Of The Income Tax

gains (LTCG) earned by the assessee on sale of land. 3. Being aggrieved by the said order of the Ld. CIT(A), the Revenue has come in appeal agitating the action of the Ld. CIT(A) ibn deleting the impugned addition made by the AO, whereas, the assessee has filed the appeal raising legal grounds relating to the validity

MINAL PRASHANT VAKIL LEGAL HEIR OF LATE. PRASHANT RASIKLAL VAKIL,AHMEDABAD vs. INCOME TAX OFFICERWARD 1, INTERNATIONAL TAX AHMEDABAD , AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T.R. Senthil Kumar (Judicial Member)

section 143(3) r.w.s. 144C of the Income Tax Act, I.T.A No. 1546/Ahd/2024 A.Y. 2015-16 Page No 2 Minal Prashant Vakil Legal Heir of Late Prashant Rasiklal Vakil vs. ITO, Int.Tax 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2015-16. 2. The brief facts of the case is that the assessee is an individual