PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

13 is found, the trust is eligible to get exemption under section 11& 12 of the Act in presence of registration granted u/s 12A of the Act. Similar view also given by Hon'ble Madras High court in case of Commissioner of Income-tax, Central- Ill, Chennai V. Balaji Educational & Charitable Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

13 is found, the trust is eligible to get exemption under section 11& 12 of the Act in presence of registration granted u/s 12A of the Act. Similar view also given by Hon'ble Madras High court in case of Commissioner of Income-tax, Central- Ill, Chennai V. Balaji Educational & Charitable Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed

DCIT, CENTRAL CIRCLE1(2), AHMEDABAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

13 is found, the trust is eligible to get exemption under section 11& 12 of the Act in presence of registration granted u/s 12A of the Act. Similar view also given by Hon'ble Madras High court in case of Commissioner of Income-tax, Central- Ill, Chennai V. Balaji Educational & Charitable Public Trust [2015] 56 taxmann.com 182. 5.9 As discussed

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

8 CO. No.209/Ahd/2011 AYs:2007-08 CO. No.210/Ahd/2011 & Khurana Engineering Ltd. The income on which deduction u/s. 801A has been claimed was related to the contract works executed by the assessee and was not on BOT, BOOT, or BOLT basis. Thus works carried out by the company were not as developer but as a contractor and by virtue of agreements

KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

8 CO. No.209/Ahd/2011 AYs:2007-08 CO. No.210/Ahd/2011 & Khurana Engineering Ltd. The income on which deduction u/s. 801A has been claimed was related to the contract works executed by the assessee and was not on BOT, BOOT, or BOLT basis. Thus works carried out by the company were not as developer but as a contractor and by virtue of agreements

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

8 CO. No.209/Ahd/2011 AYs:2007-08 CO. No.210/Ahd/2011 & Khurana Engineering Ltd. The income on which deduction u/s. 801A has been claimed was related to the contract works executed by the assessee and was not on BOT, BOOT, or BOLT basis. Thus works carried out by the company were not as developer but as a contractor and by virtue of agreements

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. KANSARA POPATLAL TRIBHOVANDAS METAL PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed while the Cross

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

8 deeming fiction. Hence, we need to read Section 115J(1A) of the Act in the strict sense. If we so read, it is clear that, by legislative incorporation, only Parts II and III of Schedule VI to 1956 Act have been incorporated legislatively into Section 115J of the Act. Therefore, the question of applicability of Parts

OLYMPIC DECOR LLP,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, the Appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2018-19 Olympic Décor Llp Pr.Commissioner Of 6, Patel Avenue, Nr.Gurudwara Vs Income Tax-3 Sg Highway, Bodakdev Ambawadi Ahmedabad. Ahmedabad. Pan : Adafs 2113 H (Applicant) (Responent) : Assessee By Shri Tushar Hemani, Sr.Advocate & Parimalsinh B. Parmar, Ars : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 23/05/2025 आदेश आदेश/O R D E R आदेश आदेश

8 conduct de novo assessment without any finding on incorrect allowance or loss of revenue. The revisionary jurisdiction under section 263, it was submitted, cannot be invoked merely for directing roving inquiries or for improvement of reasoning. It was stressed that where the AO has taken a plausible view after inquiry, the jurisdiction under section 263 is barred. 13

M/S. SABARMATI GAS LTD.,GANDHINAGAR vs. THE PR. CIT-3, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2018-19 Sabarmati Gas Ltd. The Ld.Pr.Cit Plot No.907, Sector 21 Vs Ahmedabad-3. Gandhinagar 382 021 Pan : Aakcs 0110 N

8 Machinery. The assessee also had recalculated the WDV of this new block of asset by applying the higher rate of depreciation applicable from the beginning, i.e since the acquisition of the ROU/ ROW. And the difference between the WDV derived from Plant and Machinery and the actual WDV so worked out of the intangible asset was claimed as prior

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure

THE ACIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. AJAY ENGG. INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

depreciation in respect of such machinery or plant has been allowed or is allowable under the provisions of this Act in computing the total income of any person for any period prior to the date of the installation of machinery or plant by the assessee. AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure

THE ACIT (EXEMPTIONS), CIRCLE-1,, AHMEDABAD vs. ELECTRONICS & QUALITY DEVELOPMENT CENTRE,, GANDHINAGAR

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.1757/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2015-2016 A.C.I.T.(Exemptions), Electronics & Quality Development Circle-1, Vs. Centre, Ahmedabad. B-177/178, Gidc, Electronic Centre Sector-25, Gandhinagar-382024. Pan: Aaate0718R

8,06,71,844/- as application of income. Though the activities of the assessee are not charitable in nature by virtue of 1 proviso to section 2(15) of the Act. A.Y. 2015-16 6 12. As the activities of the assessee were falling under 1 and 2 proviso of section

MAXXIS RUBBER INDIA PVT. LTD.,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

section - - 50(5+ 8-3a-3b -4 -7-19) 21 Written down value on the last day 16,89,99,13,280 - 18,13,29,768 of previous year (6+ 9-15) 7.2 For the year under consideration, the assessee claimed aggregate depreciation