M/S. NIRMA LIMITED,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

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

gains would be determined in the prescribed manner. Rule 8AC has been prescribed for this purpose.  Section 55: Meaning of 'Cost of Acquisition' in case of Goodwill of Business or Profession has been amended to provide that • in case it is acquired from a previous owner, the cost would be the amount of purchase price paid. • in case

THE DCIT, CIR-3(1)(1), AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

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

gains would be determined in the prescribed manner. Rule 8AC has been prescribed for this purpose.  Section 55: Meaning of 'Cost of Acquisition' in case of Goodwill of Business or Profession has been amended to provide that • in case it is acquired from a previous owner, the cost would be the amount of purchase price paid. • in case

NIRMA LIMITED,,AHMEDABAD vs. DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

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

gains would be determined in the prescribed manner. Rule 8AC has been prescribed for this purpose.  Section 55: Meaning of 'Cost of Acquisition' in case of Goodwill of Business or Profession has been amended to provide that • in case it is acquired from a previous owner, the cost would be the amount of purchase price paid. • in case

JT. CTI (OSD), CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

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

gains would be determined in the prescribed manner. Rule 8AC has been prescribed for this purpose.  Section 55: Meaning of 'Cost of Acquisition' in case of Goodwill of Business or Profession has been amended to provide that • in case it is acquired from a previous owner, the cost would be the amount of purchase price paid. • in case

HANSABEN GIRISHBHAI SHAH,AHMEDABAD vs. THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee stands allowed on this legal ground

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1279/Ahd/2024 िनधा"रण वष" /Assessment Year : 2017-18 Hansaben Girishbhai Shah The Dy.Cit बनाम/ 139, V.R. Shah Smruti Circle-2(1)(1) V/S. Shikshan Mandir Ahmedabad – 380 015 Opp. Yogeshwar Nagar Society Nr. Dharnidhar Derasar Vasna Ahmedabad – 380 007 "थायी लेखा सं./Pan: Aajpd 7188 H (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Jaimin Shah, Ar Revenue By : Shri Abhijit Sr.Dr सुनवाई की तारीख/Date Of Hearing : 20/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred 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 27/03/2024 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. Hansaben Girishbhai Shah Vs. Dy.Cit, Cir-2(1)(1) Asst.Yeaar 2017-18

Capital Gain/Loss, unsecured loans, share premium, bogus gains, contrived losses, etc. The said information was a general and vague information. The only information available to the AO was that the assessee had engaged into some transaction with Kaushal Group and nothing else. Under those circumstances, the AO was supposed to co-relate to the said information with the assessment records

INDIAN CHRONICLE LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER,WARD-4(3),, AHMEDABAD

In the result, the appeal ofthe assessee is allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 1275/Ahd/2012 ("नधा"रण वष" / Assessment Year : 2007-08) Indian Chronicle Ltd. बनाम/ Ito Gujarat Samacharbhavan, Ward4(3), Ahmedabad Vs. Khanpur,Ahmedabad - 380001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaaci0793H (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & अपीलाथ" ओर से/Appellant By : Shri Parimalsinh B. Parmar, A.R. Shri Rignesh Das, Sr. Dr ""यथ" क" ओर से/Respondentby: Date Of Hearing 28/11/2024 Date Of Pronouncement 18/12/2024

capital gain in Book Profits was by way of amendment in law applicable from the impugned year onwards and therefore missed out for its consideration. We agree with the Ld.Counsel for the assessee that there was a mistake apparent on record in the order of the ITAT finding the assessee to have acted malafidely by only considering the fact that

M/S. NIRMA LIMITED,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-\n13 & 2013-14 filed by the assessee are partly allowed, while the appeal of the assessee\nfor AY 2014-15 is allowed

gains would be determined in the\nprescribed manner. Rule 8AC has been prescribed for this purpose.\nSection 55: Meaning of 'Cost of Acquisition' in case of Goodwill of Business or\nProfession has been amended to provide that\nin case it is acquired from a previous owner, the cost would be the\namount of purchase price paid.\nin case

INCOME TAX OFFICER WARD-3(3)(2), AHMEDABAD, AHMEDABAD vs. KAPIL ARUN AGRAWAL, AHMEDABAD

In the result, appeal of the Revenue stands dismissed

Bench: Shri Sanjay Garg & Smt. Annapurna Guptaआयकर अपील सं /Ita No.672/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Income Tax Officer Kapil Arun Agrawal बनाम/ Ward-3(3)(2) B-130 Pushp Industrial Park V/S. Ahmedabad Near Shital Cinema, Gomtipur Rakhial Ahmeabad – 390 021 "थायी लेखा सं./Pan: Agupa 1914 H (अपीलाथ)/ Appellant) (*+ यथ)/ Respondent) Assessee By : Ms. Urvashi Sodhan, Ar Revenue By : Shri Ravindra, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 28/08/2025 घोषणा की तारीख /Date Of Pronouncement: 04/09/2025 आदेश/O R D E R Per Sanjay Garg:

gain, rather the Short Term Capital Loss (STCL) of Rs.92,040/- only. It was also explained that the shares of the said company, M/s.Oasis Tradelink Ptd. were received by the assessee by IPO/initial allotment which were sold for Rs.69,87,960/- thereby making a loss of Rs.92,040/-. That the assessee had not taken any accommodation entry as alleged

NIRMA LIMITED,,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1),, AHMEDABAD

193/- as on 31.03.2016. The assessee contended that\ngoodwill had arisen as a balancing figure on account of the\ndifference between net assets taken over and the liabilities\nassumed under the approved scheme of amalgamation and being\nan intangible asset within the meaning of section 32(1)(ii) of the\nAct, depreciation thereon was allowable.\n47. The Assessing Officer, however

THE ACTI , CIRCLE-3(1)(1),, AHMEDABAD vs. NIRMA LIMITED,, AHMEDABAD

193/- as on 31.03.2016. The assessee contended that\ngoodwill had arisen as a balancing figure on account of the\ndifference between net assets taken over and the liabilities\nassumed under the approved scheme of amalgamation and being\nan intangible asset within the meaning of section 32(1)(ii) of the\nAct, depreciation thereon was allowable.\nITA Nos.1412-1413/Ahd/2019 with others\nNirma

NIRMA LIMITED,,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1),, AHMEDABAD

193/- as on 31.03.2016. The assessee contended that\ngoodwill had arisen as a balancing figure on account of the\ndifference between net assets taken over and the liabilities\nassumed under the approved scheme of amalgamation and being\nan intangible asset within the meaning of section 32(1)(ii) of the\nAct, depreciation thereon was allowable.\nITA Nos.1412-1413/Ahd/2019 with others\nNirma

THE ACTI , CIRCLE-3(1)(1),, AHMEDABAD vs. NIRMA LIMITED,, AHMEDABAD

193/- as on 31.03.2016. The assessee contended that\ngoodwill had arisen as a balancing figure on account of the\ndifference between net assets taken over and the liabilities\nassumed under the approved scheme of amalgamation and being\nan intangible asset within the meaning of Section 32(1)(ii) of the\nAct, depreciation thereon was allowable.\n27\nITA Nos.1412-1413/Ahd/2019 with others

SHAILESHBHAI BHA vs. ANGBHAI CHAVDA,BHAVNAGARVS.THE INCOME TAX OFFICER WARD 1(4) BHAVNAGAR, BHAVNAGAR

In the result, the appeal of the assessee in ITA No

Bench: Shri Ramit Kochar (Accountant Member)

193, Mokhandaka, v. Ward-1(4), Paleetana, Aayakar Bhawan, Bhavnagar 364270, Bhavnagar- Gujarat, India 364002 ,Gujarat PAN: AIWPC1539L (Appellant) (Respondent) Assessee by: Shri Jignesh Parikh, A.R. Revenue by: Smt. Trupti Patel, Sr. D.R. Date of hearing : 03-07-2024 Date of pronouncement : 03-07-2024 आदेश/ORDER This appeal in ITA No. 248/Ahd/2024 for assessment year 2012-13 filed

SHREE MALLIKARJUN TRAD INVEST PRIVATE LIMITED,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1)(3), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Ms. Suchitra Kambleassessment Year: 2014-15

Gain (LTCG) and Short Term Capital Loss (STCL)/business loss etc. The assessee was asked to explain as to why the loss of Rs.6,58,200/- shown could not be treated as not genuine and disallowed. In response to the same, the assessee furnished its submission before the Assessing Officer. After taking cognisance of the said explanation of the assessee

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Capital Infusion. 55. The TPO found that the assessee during the year has made payment of share application money to the following AEs: S. Name of AE Amount in Rs. Date of Date of share No. payment allotted 1 Zao Torrent Pharma 20,51,66,850/- 08-08-2012 28-03-2013 2 Zao Torrent Pharma

KALPANABEN VADILAL SHAH,AHMEDABAD vs. THE ITO, WARD-5(3)(1), AHMEDABAD

In the result, appeal filed by the assessee is allowed in above\nterms

Capital Gain/Loss, unsecured loans, share\npremium, bogus gains, contrived losses, etc. The said information was a general\nand vague information. The only information available to the AO was that the\nassessee had engaged into some transaction with Kaushal Group and nothing else.\nUnder those circumstances, the AO was supposed to co-relate to the said\ninformation with the assessment records

ACIT, ANAND CIRCLE, ANAND, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

capital,\nsuch limitation would become inapplicable (rather than the whole section\nbecoming inapplicable). It is submitted that it be so held now.\n3. The NFAC has erred on facts and in law in confirming the ad-hoc\ndisallowance capped at Rs.10,00,000/- under Section 14A of the Act\nfollowing the Hon'ble Income Tax Appellate Tribunal ('ITAT') order

ACIT, ANAND CIRCLE, ANAND, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

capital,\nsuch limitation would become inapplicable (rather than the whole section\nbecoming inapplicable). It is submitted that it be so held now.\n3. The NFAC has erred on facts and in law in confirming the ad-hoc\ndisallowance capped at Rs.10,00,000/- under Section 14A of the Act\nfollowing the Hon'ble Income Tax Appellate Tribunal ('ITAT') order

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

capital, such limitation would become inapplicable (rather than the whole section becoming inapplicable). It is submitted that it be so held now.\n\n3. The NFAC has erred on facts and in law in confirming the ad-hoc disallowance capped at Rs.10,00,000/- under Section 14A of the Act following the Hon'ble Income Tax Appellate Tribunal ('ITAT') order