RAVINDRABHAI SHANKARBHAI PATEL,VADODARA vs. THE ITO, WARD-1(2)(5) NOW ITO, WARD-1(2)(2), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalthe Ito Ravindrabhai Shankarbhai Vs. Ward-1(2)(5). Patel Now Ito, Ward-1(2)(2) 86,Kanha Residency Vadodara – 390 007 Kalali Road, Kalali Ahmedabad – 390 012 [Pan : Aigpp 8415 M] (Appellant) (Respondent) .. Assessee Represented By : Ms. Urvashi Shodhan, Ar Revenue Represented By : Shri Abhijit, Sr.Dr Date Of Hearing 27/11/2025 Date Of Pronouncement 29/01/2026

capital gains have to be construed liberally. 8.1. With regard to the disallowance relating to investments in agricultural land, the learned counsel explained that the Assessing Officer disallowed payments relating to the Anklav land and the Chansad land on the sole ground that the payments were made after 31.07.2015. It was submitted that the law does not mandate that

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

x B C A = Amount of interest, other than the amount of interest which is directly attributable to the exempt income stated in (a) above. B = The average of value of investment, income from which does not or shall not form part of the total income, as appearing in the balance sheet of the assessee, on the first

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

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

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

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

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

2 per cent. We observe that in the instant facts, the assessee has computed the ALP at LIBOR plus 2.5%. The Ld. CIT(Appeals) has upheld the order of the Ld. Assessing Officer on the Ground that the assessee has not given the comparable basis for arriving at the aforesaid rate. However, in our view, the Ld. CIT(Appeals

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

x) of the Act relating to the late payment of PF/ESIC payment. The Assessing Officer assessed the income at Rs.61,61,15,800/-. The Assessing Officer also calculated MAT under Section 115JB of the Act thereby making addition of Rs.6,66,11,675/-. Disallowance under Section 14A of the Act and ITA Nos.345 & 383/Ahd/2020 Assessment Years: 2012-13 Page

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

x) of the Act relating to the late payment of PF/ESIC payment. The Assessing Officer assessed the income at Rs.61,61,15,800/-. The Assessing Officer also calculated MAT under Section 115JB of the Act thereby making addition of Rs.6,66,11,675/-. Disallowance under Section 14A of the Act and ITA Nos.345 & 383/Ahd/2020 Assessment Years: 2012-13 Page

ITO, WD. 1(2)(2), RACE COURSE CIRCLE, VADODARA vs. NEETABEN SNEHALKUMAR PATEL, RACE COURSE CIRCLE, VADODARA

In the result, the appeal preferred by the Revenue is allowed

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 247/Ahd/2024 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15) िनधा"रण वष"

section 68 of the Act? 2. Whether on the facts and circumstances and in law, the Ld. Commissioner of Income-tax(Appeals) was justified in deleting the addition made u/s 68 of the Act, without appreciating the findings of the AO and also ignoring the larger scam of organized tax evasion by way of bogus capital gain generated in penny

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

x) of the l.T. Act, 1961. (v) In the instant case, the assessee held the amount of Rs.2,47,943/- and Rs.19,36,095/- pertaining to A.Yrs. 1992-93 and 1993-94 respectively illegally for number of years and instead of refunding the ill-gotten amount to Govt. account, the assessee chose to invest the money further as mentioned supra

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

x) of the l.T. Act, 1961. (v) In the instant case, the assessee held the amount of Rs.2,47,943/- and Rs.19,36,095/- pertaining to A.Yrs. 1992-93 and 1993-94 respectively illegally for number of years and instead of refunding the ill-gotten amount to Govt. account, the assessee chose to invest the money further as mentioned supra

SHRI JIGNESH RAMJIBHAI PATEL,BHAVNAGAR vs. ITO, WARD-1(2),, BHAVNAGAR

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

56,940/- and Long term capital gain(LTCG) amounting to Rs.2,23,95,400/-. The said return was processed u/s.143(1) of the Act. The case of the assessee was selected for scrutiny and notice u/s.143(2) of the Act was issued on 24.09.2015 and duly served upon the assessee. Subsequently, notice u/s.142(1) of the Act was issued

SMT. SHITAL SANJAYBHAI PATEL,BHAVNAGAR vs. ITO, WARD-1(5),, BHAVNAGAR

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

56,940/- and Long term capital gain(LTCG) amounting to Rs.2,23,95,400/-. The said return was processed u/s.143(1) of the Act. The case of the assessee was selected for scrutiny and notice u/s.143(2) of the Act was issued on 24.09.2015 and duly served upon the assessee. Subsequently, notice u/s.142(1) of the Act was issued

SHRI SANJAYBHAI RAMJIBHAI PATEL,,BHAVNAGAR vs. ITO, WARD-1(5),, BHAVNAGAR

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 452/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-2015

56,940/- and Long term capital gain(LTCG) amounting to Rs.2,23,95,400/-. The said return was processed u/s.143(1) of the Act. The case of the assessee was selected for scrutiny and notice u/s.143(2) of the Act was issued on 24.09.2015 and duly served upon the assessee. Subsequently, notice u/s.142(1) of the Act was issued

VAISHALI BABUBHAI PATEL,AHMEDABAD vs. THE PR. CIT-3, AHMEDABAD

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./ Ita No. 380/Ahd/2020 धििाधरणवरध/Asstt. Year: 2015-2016 Vaishali Babubhai Patel, The Principal Commissioner B-201, Vs. Of Income Tax-3, Gala Gardenia Apartments, Ahmedabad. Nr. Safal Parisar, South Bopal, Ahmedabad-380058. Pan: Abdpp0233G

section 263 of the Act erred in holding the assessment framed u/s 143(3) of the Act, as erroneous in so far prejudicial to the interest of the revenue. 4. The assessee in the year under consideration has sold a property along with the Co-owner. The share of the assessee in the property was 17.60% and sale consideration relating

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

x) r.w.s.36(l)(va) of the I.T.\nAct.\n3)\nIn law and in facts and circumstances of the Appellant's case, the learned\nCIT(A) has grossly erred in confirming disallowance of depreciation on goodwill\nfor Rs.17,27,50,337/-\n4) In law and in facts and circumstances of the Appellant's case, the learned\nCIT (A) has grossly erred

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

In the result, appeal of the assessee is partly allowed

Bench: Dr.Brr Kumarshri Tr Senthil Kumar

x) of the Act shall be deleted on account of contributions made within the grace period. 4. The Ld. CIT(A) has erred in law and on facts of the case in confirming the disallowance of foreign commission of Rs. 57,74,100/- u/s. 40(a)(ia) of the Act. 5. Alternatively and without prejudice. the disallowance of foreign commission