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(3) r.w.s. 144B

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

section 143(3) r.w.s. 144C and 144B of the Act holding the same to be erroneous and prejudicial to the interest of Revenue and directing the assessing officer to pass a fresh assessment order after re-computing claim allowable related to general depreciation

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

Section 147 r.w.s. 143(3) & 143(3) r.w.s. 144B of the Income Tax Act, 1961, (hereinafter referred to as ‘the Act’) for Assessment Year 2016-17 to 2018-19. 2. Since all these appeals are relating to identical issues that too in respect of the same appellant, these are heard analogously and are being disposed of by this common order

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

Section 147 r.w.s. 143(3) & 143(3) r.w.s. 144B of the Income Tax Act, 1961, (hereinafter referred to as ‘the Act’) for Assessment Year 2016-17 to 2018-19. 2. Since all these appeals are relating to identical issues that too in respect of the same appellant, these are heard analogously and are being disposed of by this common order

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

Section 147 r.w.s. 143(3) & 143(3) r.w.s. 144B of the Income Tax Act, 1961, (hereinafter referred to as ‘the Act’) for Assessment Year 2016-17 to 2018-19. 2. Since all these appeals are relating to identical issues that too in respect of the same appellant, these are heard analogously and are being disposed of by this common order

MAKSON PHARMACEUTICALS(INDIA) PRIVATE LIMITED,SURENDRANAGAR vs. PR. CIT, AHMEDABAD-3, AHMEDABAD, AHMEDABAD

In the result, appeal filed by the assessee is allowed

144B was passed on 29/05/2021 hence present proceedings deserves to be dropped. However, during the present hearing, assessee has failed to demonstrate that ITA No. 1017/Ahd/2024 [Makson Pharmaceuticals (India) Private Limited vs. PCIT] A.Y. 2018-19 - 14 – AO has applied his mind while passing the assessment order or assessee has submitted specific details regarding non applicability of provisions of Section

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

depreciation was rejected on the basis of the ITAT’s decision in the group concern Torrent Power Ltd. in ITA Nos. 3133 & 3331/Ahd/2008 for A.Y. 2005–06. 4. Revenue preferred an appeal before this Co-ordinate Bench. The Coordinate Bench, in its order dated 19.03.2019 in ITA No. 1562/AHD/2015, after noting the judgment of the Hon’ble Gujarat High Court

GMM PFAULDER LTD.,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.839/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Gmm Pfaulder Ltd. The Pr.Cit बनाम/ 3Rd Floor, B-Jadav Chambers Ahmedabad-1 V/S. Navrangpura H.O. Ahmedabad – 380 015 Ashram Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabcg 0563 A (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 09/09/2025 घोषणा की तारीख /Date Of Pronouncement: 28 /10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Learned Principal Commissioner Of Income-Tax, Ahmedabad-1 [Hereinafter Referred To As “Ld. Pr. Cit” For Short] Dated 07/03/2025 Passed In Exercise Of His Revisionary Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2020- 21. 2. The Assessee Has Raised The Following Grounds Of Appeal: Gmm Pfaulder Ltd. Vs. Pcit Asst. Year : 2020-21 2

section 144B of the Income-tax Act, 1961 (“Act”) on 16.09.2022, accepting the income as declared in the return. On examination of records, the Principal Commissioner of Income Tax (Pr. CIT) observed that the Assessing Officer had not made requisite verifications on three specific issues — firstly, the allowability of depreciation

AARVEE DENIMS & EXPORTS LTD.,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.396/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 Aarvee Denims & Exports Ltd. The Pr.Cit बनाम/ 191, Shahwadi Ahmedabad-1 V/S. Narol–Sarkhej Highway Ahmedabad – 382 405 (Gujarat) "थायी लेखा सं./Pan: Aabca 6019 P (अपीलाथ&/ Appellant) ('( यथ&/ Respondent) Assessee By : Shri Divyakant Parikh, Ar Revenue By : Shri Prithviraj Meena, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 19/09/2024 घोषणा की तारीख /Date Of Pronouncement: 27/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

144B of the Act, making additions of Rs.42,06,604/- as per order under section 143(1) of the Act and Rs. 3,15,44,000/- under section 40(a)(i) of the Act on account of non-deduction of TDS on foreign commission. The gross total income was computed at Rs.12,04,36,098/-, against which the assessee claimed

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2 1 1 AHMEDABAD, AHMEDABAD vs. KHYATI CHEMICALS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby allowed

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

depreciation in accordance with provisions of section 32(1)(ii) r.w.s. Rule 5(1) and Appendix 1 and section 32(1)(iia) at the time of giving appeal effect.” 4. Aggrieved against the appellate order, the Revenue is in appeal before us raising the following Grounds of Appeal: 1. Whether on facts and circumstances of the case

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

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

Section 147 of the Act ITEM NO.: II Disallowance u/s. 14A r.w.r. 8D of Rs. 25,40,345/- (Rs. 6,02,80,885/- as per Assessment order u/s. 147 r.w.s. 144B of the Act Less: Rs. 5,77,40,540/- already disallowed as per Assessment order u/s. 143(3) of the Act). 2.1 The learned CIT(A) has grossly erred

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

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

Section 147 of the Act ITEM NO.: II Disallowance u/s. 14A r.w.r. 8D of Rs. 25,40,345/- (Rs. 6,02,80,885/- as per Assessment order u/s. 147 r.w.s. 144B of the Act Less: Rs. 5,77,40,540/- already disallowed as per Assessment order u/s. 143(3) of the Act). 2.1 The learned CIT(A) has grossly erred

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

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

Section 147 of the Act ITEM NO.: II Disallowance u/s. 14A r.w.r. 8D of Rs. 25,40,345/- (Rs. 6,02,80,885/- as per Assessment order u/s. 147 r.w.s. 144B of the Act Less: Rs. 5,77,40,540/- already disallowed as per Assessment order u/s. 143(3) of the Act). 2.1 The learned CIT(A) has grossly erred

GUJARAT STATE PETROLEUM CORPORATION LIMITED,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR, GANDHINAGAR

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

Section 147 of the Act ITEM NO.: II Disallowance u/s. 14A r.w.r. 8D of Rs. 25,40,345/- (Rs. 6,02,80,885/- as per Assessment order u/s. 147 r.w.s. 144B of the Act Less: Rs. 5,77,40,540/- already disallowed as per Assessment order u/s. 143(3) of the Act). 2.1 The learned CIT(A) has grossly erred

SCHNEIDER ELECTRIC INFRASTRUCTURE LTD,VADODARA vs. THE ADD./JT. DCIT/ITO NATONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalassessment Year : 2017-18 Schneider Electric Infrastructure D.C.I.T, Limited, Vs Circle-2(1)(1), Milestone 87, Vadodara Halol Vadodara. Highway, Village Kotambi, Po Jaroad, Vadodara-391510 Pan : Aapcs 6078 Q

144B of the Act is bad in law and liable to be quashed to the extent it confirms the additions / disallowances made in the assessment order. 2. That the Learned Dispute Resolution Panel ("Ld. DRP") ignored the judicial pronouncements and erred in dismissing the grounds of objections raised by the Schneider Electric Infrastructure Ltd Vs. DCIT

M/S. GUJARAT AMBUJA EXPORTS LTD.,,AHMEDABAD vs. THE PR. CIT-1, AHMEDABAD

In the result the order of the Ld

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

144B of the Income Tax on 29-05-2021 is neither erroneous nor prejudicial to the interest of the revenue and none of the conditions as envisaged under Section 263 are fulfilled. 2. Ground No. 2 Issue of claim of deduction under Section 32AC of the Act is neither erroneous nor prejudicial to the interest of revenue: The Ld. PCIT

GSP CROP SCIENCE LIMITED,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

144B of the Income-tax Act, 1961 (Act) was completed on 29/09/2022, assessing the income at Rs. 11,84,45,480/- after making an addition of Rs. 28,55,071/- under section 40(a)(ia) of the Act. Upon examination of the assessment records, the Principal Commissioner of Income Tax (Pr. CIT) noted several issues that were either not properly

TOURISM CORPORATION OF GUJARAT LIMITED,GANDHINAGAR vs. PCIT AHMEDABAD - 3, AHMEDABAD

Accordingly, the appeal filed by the assessee is dismissed

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

section 144B of the Act was completed on 16.09.2022 accepting the returned income. However, on examination of case records, Ld. Pr. CIT noted that the assessee received Government grants during the relevant period which were credited to a deferred Government account instead of being reduced from the cost or written down value of the relevant block of assets; only

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)

144B of the Income Tax Act, 1961 (hereinafter referred as to ‘the Act’) for Assessment Year 2016-17. 2. The maintainability of the very proceeding is under challenge before us to this effect that the Transfer Pricing Officer / Dispute Resolution Panel (‘DRP’) has erred in exceeding the jurisdiction by passing the transfer pricing order under Section 92CA