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

143(3) read with section 144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

143(2) of the Act, was issued and served upon the assessee. 4. Specific questionnaires were also issued from time-to-time and duly served upon the assessee alongwith notice under Section 142(1) of the Act, the details whereupon were duly filed by the assessee through electronic media on e-proceeding. The assessee had shown total turnover of Rs.65

GUJARAT STATE ELECTRICITY CORPORATION LTD,VADODARA vs. THE PR. CIT-1, VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.572/Ahd/2020 िनधा"रण वष" /Assessment Year : 2015-16 Gujarat State Electricity The Pr.Cit-1 Corporation Ltd. बनाम/ Vadodara – 390 015 Sardar Patel Vidhyut Bhavan V/S. Race Course Circle Vadodara – 390 007 "थायी लेखा सं./Pan: Aaacg 6864 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Manish J. Shah & Shri Jimi Patel, Ars Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 02/04/2025 घोषणा की तारीख /Date Of Pronouncement: 08/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

depreciation of Rs.1,17,69,30,776/-. The book profit under section 115JB of the Act was declared at Rs.2,51,70,02,648/-. 2.1. The case was selected for scrutiny and a notice under section 143

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

sections 142(1) and 143(2), and after detailed verification of all material facts and supporting evidence. Therefore, it cannot be alleged that the assessment was completed without inquiry or that the AO accepted claims mechanically without application of mind. 8. In relation to Grounds relating to depreciation

BAKERI PROJECTS PRIVATE LIMITED,AHMEDABAD vs. DCIT CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD

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

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2020-21 Bakeri Projects Pvt. Lt. The Dcit, Cir.(1)(1) 1St Floor, Sanskrut Vs. Ahmedabad. Old High Court Road Off: Ashram Road Ahmedabad. Pan : Aagcb 1864 L (Applicant) (Responent)

depreciation loss under normal provisions against gross total income. The case was selected for scrutiny and assessment proceedings were conducted under section 143

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

Section 143(3) r.w.s. 153A vide assessment order dated 21.03.2014. Thus, the finding given in para 12 in the said order of the Tribunal is on presumption. Besides this the observation that the impugned transaction for claiming the deduction on account of the depreciation

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

section 143(3) of the Act for the impugned assessment year i.e. Asst.Year 2018-19, was found to be erroneous causing prejudice to the Revenue on two counts viz; i) Incorrect allowance of claim of depreciation

GUJARAT ENERGY TRANSMISSION CORPORATION LTD.,,VADODARA vs. THE DCIT, , VADODARA

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

Bench: Shri Ramit Kochar & Ms.Madhumita Roy"नधा"रणवष"/Asstt. Year: 2010-11 Gujarat Energy Transmission The Pcit-I Corporation Ltd. Vadodra Sardar Patel Vidyut Bhavan V. Race Course Circle, Baroda. Pan : Aabcg 4029 R "नधा"रणवष"/Asstt. Year: 2010-11 Gujarat Energy Transmission The Deputy Corporation Ltd. Commissioner Of Sardar Patel Vidyut Bhavan V. Income Tax, Circle Race Course Circle, Baroda. 1(1)(1), Vadodra Pan : Aabcg 4029 R Baroda.

143(3), it becomes evident that there is no justifiable ground for the ld.Principal CIT to invoke power under section 263 of the Act. 10. Moreover, it is important to note that there is no revenue implication, and no prejudice has been inflicted upon the Revenue, as the applicable tax rate for the invoice payment in the subsequent year, during

GUJARAT ENERGY TRANSMISSION CORPN.LTD.,,BARODA vs. THE CIT-1, BARODA

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

Bench: Shri Ramit Kochar & Ms.Madhumita Roy"नधा"रणवष"/Asstt. Year: 2010-11 Gujarat Energy Transmission The Pcit-I Corporation Ltd. Vadodra Sardar Patel Vidyut Bhavan V. Race Course Circle, Baroda. Pan : Aabcg 4029 R "नधा"रणवष"/Asstt. Year: 2010-11 Gujarat Energy Transmission The Deputy Corporation Ltd. Commissioner Of Sardar Patel Vidyut Bhavan V. Income Tax, Circle Race Course Circle, Baroda. 1(1)(1), Vadodra Pan : Aabcg 4029 R Baroda.

143(3), it becomes evident that there is no justifiable ground for the ld.Principal CIT to invoke power under section 263 of the Act. 10. Moreover, it is important to note that there is no revenue implication, and no prejudice has been inflicted upon the Revenue, as the applicable tax rate for the invoice payment in the subsequent year, during

THE DCIT, CIRCLE-1(1), NOW CIRCLE-1(1)(1),, BARODA vs. GUJARAT STATE ELECTRICITY CORPORATION LTD.,, BARODA

In the result, the appeal filed by the Assessee in ITA No

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

143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2011-12. Since common issues are involved in both the appeals, the grounds raised by both parties are inter connected the same are disposed of by this consolidated order. 2. The Grounds of appeal raised by the Revenue

GUJARAT STATE ELECTRICITY CORPORATION LTD.,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

In the result, the appeal filed by the Assessee in ITA No

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

143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year 2011-12. Since common issues are involved in both the appeals, the grounds raised by both parties are inter connected the same are disposed of by this consolidated order. 2. The Grounds of appeal raised by the Revenue

TORRENT ENERGY LIMITED (NOW MERGED WITH TORRENT POWER LIMITED),AHMEDABAD vs. THE ACIT CIRCLE 4(1)(1), AHMEDABAD

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2011-12 Torrent Energy Limited The Acit, Cir.4(1)(1) (Now Merged With Torrent Power Ltd) Ahmedabad. Samanvay, 600, Tapovan Ambawadi, Ahmedabad Pan : Aacct 8570 B (Applicant) (Responent) Assessee By : Shri Vartik Chokshi, Ar : Smt.Trupti Patel, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 08/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

section 143(3), the assessee filed a written submission dated 07.11.2011 before the then Assessing Officer claiming depreciation on the leasehold

TECHNODOT ENGINEERS PVT. LTD,GANDHINAGAR vs. THE DCIT, CIRCLE-2(2), AHMEDABAD

Appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokari.T(Ss).A. Nos.147&148/Ahd/2019 (A.Ys.: 2005-06 & 2006-07) Smt. Neelu Sanjay Gupta, Vs. Deputy Commissioner Of L/H. Of Late Shri Sanjay Gupta Income Tax, B-202, Dhananjay Tower, Central Circle-2(2), Anand Nagar Road, Satellite, Ahmedabad Ahmedabad-380015 [Pan No.Adypg0351K] (Appellant) .. (Respondent) I.T(Ss).A. Nos.21 To 23/Ahd/2020 & 15/Ahd/2022 & Ita No. 93/Ahd/2020) (A.Ys.: 2007-08, 2008-09 & 2006-07 & 2010-11 To 2011-12) M/S. Technodot Engineers Ltd., Vs. Deputy Commissioner Of C/O. Cambay Hotel & Resorts, Income Tax, Plot No. 22, 23, 24 Gidc, Central Circle-2(2), Sector-25, Gandhinagar-382010 Ahmedabad [Pan No.Aabct5392A] (Appellant) .. (Respondent)

143(2) and 142(1). The assessee's responses, submitted on November 20, 2012, were deemed insufficient, and a penalty under Section 271(1)(b) was levied on November 27, 2012. The assessee's appeal against the penalty was dismissed by the CIT (A) on May 9, 2013, for failure to comply fully with the notices. The assessee

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

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 708/Ahd/2023 धििाधरणवरध/Asstt. Year: 2014-2015 Chirpal Industries Limited, D.C.I.T, Chirpal House, Vs. Circle-1(1)(2), Shivranjani Cross Road, Ahmedabad. Satellight, Ahmedabad-380015. Pan: Aaacc8513B

depreciation in dispute is eligible for deduction while calculating the income of an undertaking eligible for deduction under section 80 IA of the Act, it is important to note that the disallowance made by the AO for the deduction claimed by the assessee under section 80-IA of the Act in the assessment proceedings carried out under section 143

NIRMA LIMITED,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1) NOW DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

Appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2013-14 Nirma Limited, The Dy. Commissioner Of Vs. Nirma House, Ashram Road, Income-Tax, Ahmedabad-380 009 Circle-3(1)(1), Pan : Aaacn 5350 K Ahmedabad-380009 अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Sanjay Kumar, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 11.07.2024 घोषणा क" तारीख /Date Of Pronouncement: 09.10.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-12, Ahmedabad [Hereinafter Referred To As "Cit(A)" For Short] Dated 10.04.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2013-14. 2. The Effective Ground Raised By The Assessee Is As Follows:-

143(1) processing is Rs.79,14,26,718/- and as per regular assessment is Rs. 78,31,32,108/- calculated by the appellant itself. SAT paid is 1.19% of the tax payable. The contention of the AO is correct. As per proviso to section 244A, no interest on amount of SAT is eligible. Case laws cited predate the amendment

DEPUTY COMMISIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEBABAD vs. RAYON REALTY PRIVATE LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2015-16

143(3) read with Section 263 of the Act on 29.03.2022 at a total income of Rs.7,87,38,346/-. 3. The assessee had filed an appeal with the First Appellate Authority against this assessment order which was decided by the Ld. CIT(A) vide the impugned order and appeal of the assessee was allowed. 4. Now the Revenue

KREATE KONNECT E SOLUTIONS PRIVATE LIMITED,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result the appeal is allowed for statistical purposes

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2020-21 Kcreate Konnect E Solutions Dy. Cit, Cir.1(1)(1) Private Limited Vs. Vadodara. 291M 2Bd Floor, Green Villa-11 B/H. Abs Tower Old Padra Road Vadodara Pan : Aagck 1493 C (Applicant) (Responent) : Shri Jigar Adhyaru, Ar Assessee By : Shri Hargovind Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 24/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 29/07/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) – 5, Chennai [Hereinafter Referred To As “Cit(A)”] Dated 18.09.2024, Pertaining To The Assessment Year 2020– 21, Whereby The Appeal Filed By The Assessee Against The Intimation Issued Under Section 143(1) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”] Dated 18.12.2021 Was Dismissed.

depreciation under section 32(1)(iia), deductions under sections 10AA, 35(1)(ii), etc., thereby complying with the conditions of sub-section (2) of section 115BAA. • In the tax audit report (Form No. 3CD), specifically under Clause 8(a), the auditor disclosed that the assessee has opted to be taxed under section 115BAA. This amounts to third-party statutory attestation

KIFS INTERNATIONAL LLP,AHMEDABAD vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI PRESENTLY WITH ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

depreciation of Goodwill was disallowed by the Ld. AO in the case of KIPL by and under the order dated 30th December, 2018 passed under Section 143

KIFS INTERNATIONAL LLP,AHMEDABAD vs. THE ACIT, CIRCLE-5(2)(1) PRESENTLY WITH ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

depreciation of Goodwill was disallowed by the Ld. AO in the case of KIPL by and under the order dated 30th December, 2018 passed under Section 143