GUJARAT FLUOROCHEMEICALS LTD,,BARODA vs. THE DY.CIT.,CIRCLE-1(1)(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT FLUROCHEMICALS LTD.,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

THA ADDL. CIT, RANGE-1,, BARODA vs. M/S. GUJARAT FLUROCHEMICALS LIMITED.,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

GUJARAT FLUROCHEMICALS LIMITED,,BARODA vs. THE ADDL. CIT, RANGE-1,, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

THE ADDL.CIT, RANGE-1, BARODA vs. GUJARAT FLUOROCHEMEICALS LTD, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

GUJARAT FLUROCHEMICALS LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

GUJARAT FLUROCHEMICALS LIMITED,,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

Appeals of the Revenue are dismissed, whereas appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediasr. No.

15. Next common issue involved in all appeals of the Revenue as well as of the assessee is, whether purchase and sale of shares is to be treated as trading activity or an investment activity. The assessee has treated its activity of sale and purchase of shares as an investment activity and on sale of shares/mutual fund

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

15. Next fold of dispute relates to working out of administrative expenses relatable to earning of exempt income. 16. As pointed out by the ld.cousnel for the assessee that Hon’ble Gujarat High Court (in Corrotech) and Hon’ble Delhi High Court in (Chemvest) have concurred with each other that if there is no dividend income or tax free income

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

15. Next fold of dispute relates to working out of administrative expenses relatable to earning of exempt income. 16. As pointed out by the ld.cousnel for the assessee that Hon’ble Gujarat High Court (in Corrotech) and Hon’ble Delhi High Court in (Chemvest) have concurred with each other that if there is no dividend income or tax free income

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

15, 2021 in violation of the provisions of the Act. Common Grounds 3. That on the facts and circumstances of the case and in law, the orders passed by the Ld. AO / TPO / DRP in respect of transfer pricing adjustment are not in accordance with law and contrary to the facts and circumstances of the present case

INOX RENEWABLES LIMITED,VADODARA vs. ACIT, CIRCLE1(1)(2), , VADODARA

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadavआयकर अपील सं./ Ita No.1731/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 Inox Renewables Ltd. Vs. Acit, Cir.1(1)(2) Vadodara. Abs Towers 2Nd Floor Old Padra Road Vadodara 390 007 Pan : Aacci 4628 K

section 143(2) was issued and served upon the assessee. The assessee-company was incorporated on 11.11.2010 and 99.98% of equity capital was held by holding company viz. M/s.Gujarat Fluorochemicals Ltd.(GFL). According to the assessee, it has acquired wind energy division of GFL during the accounting year relevant to this assessment year. It claimed depreciation. However, its claim

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

144C(10) and holding that in view of the long term I.T.A No. 702 & 729/Ahd/2016 A.Y. 2011-12 Page No 5 Sun Pharmaceutical Industries Ltd. Vs. ACIT/Dy. CIT vs. Sun Pharmaceutical Industries Ltd capital gains claimed as exempt u/s. 10(38), disallowance u/s. 14A could be made. The Assessing Officer failed to appreciate that ii was not open

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

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

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

THE JOINT COMMISSIONER OF INCOME TAX(OSD),, GANDHINAGAR vs. KALPATARU POWER TRANSMISSION LTD.,, GANDHINAGAR

In the result, Revenue’s appeal in ITA No

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad1. आयकर अपील सं./I.T.A. No.1462/Ahd/2016 2.आयकर अपील सं./I.T.A. No.1463/Ahd/2016 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Respectively)

15. What does a person get by buying these carbon credits or CERs. For each carbon credit that a person in the developed world buys, he gets right to emit one more ton of CO2 (carbon dioxide) or CO2e (carbon dioxide equivalent gases). Nobody would normally buy these credits as a token of appreciation of the work done

THE JOINT COMMISSIONER OF INCOME TAX(OSD),, GANDHINAGAR vs. KALPATARU POWER TRANSMISSION LTD.,, GANDHINAGAR

In the result, Revenue’s appeal in ITA No

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad1. आयकर अपील सं./I.T.A. No.1462/Ahd/2016 2.आयकर अपील सं./I.T.A. No.1463/Ahd/2016 ("नधा"रण वष" / Assessment Years: 2010-11 & 2011-12 Respectively)

15. What does a person get by buying these carbon credits or CERs. For each carbon credit that a person in the developed world buys, he gets right to emit one more ton of CO2 (carbon dioxide) or CO2e (carbon dioxide equivalent gases). Nobody would normally buy these credits as a token of appreciation of the work done

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

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