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

depreciation on goodwill. The facts have been thoroughly verified, the legal position is supported by binding precedents, and the Revenue has failed to demonstrate that the transaction lacks commercial substance or that the claim falls afoul of any specific bar under the Act. All the revised grounds of appeal raised by the Revenue stand rejected. Original Ground

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

depreciation on goodwill. The facts have been thoroughly verified, the legal position is supported by binding precedents, and the Revenue has failed to demonstrate that the transaction lacks commercial substance or that the claim falls afoul of any specific bar under the Act. All the revised grounds of appeal raised by the Revenue stand rejected. Original Ground

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

depreciation on goodwill and granting consequential relief. Accordingly, Ground Nos. 6 to 12 raised by the Revenue are dismissed. Ground No. 13 – Allocation of Common Expenses while Computing Deduction under Sections 80-IC, 80-IE & 10AA 8. This ground relates to deletion of addition made by the Assessing Officer on account of allocation of common/indirect expenses to the eligible units

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

195 nor the disallowance u/s 40(a)(i) is attracted. Regarding genuineness of commission-payment, we observe that the assessee has given sufficient documentary evidences to prove the services of Page 41 of 51 ITA No.2682 & 2683/Ahd/2016 A.Y. 2011-12 and 2012-13 Gujarat Microwax Pvt. Ltd. agents and payment of commission. It is also observed that the assessee

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

195 nor the disallowance u/s 40(a)(i) is attracted. Regarding genuineness of commission-payment, we observe that the assessee has given sufficient documentary evidences to prove the services of Page 41 of 51 ITA No.2682 & 2683/Ahd/2016 A.Y. 2011-12 and 2012-13 Gujarat Microwax Pvt. Ltd. agents and payment of commission. It is also observed that the assessee

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

depreciation considered on year on year basis as against 16 IT(SS)A No. 27 to 30/Ahd/2021 and 14/Ahd/2022 A.Ys. 2006-07 to 2010-11 DCIT vs. M/s Bodal Chemicals Ltd. ITA No. 318/Ahd/2022 IT(SS)A No. 11 to 13/Ahd/2022 A.Ys. 2009-10 to 2012-13 M/s Bodal Chemicals Ltd. vs. DCIT claimed by the respondent by considering

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

depreciation relying upon the\nadditional evidences/documents which were not submitted by the assessee\nbefore the AO dehorse provisions of Rule 46A of I.T. Rules and without calling\nremand report.\n9.\nOn the facts and in the circumstances of the case and in law, the Ld. CIT(A)\nhas erred in deleting the addition of Rs.10,00,000/- made

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

depreciation relying upon the\nadditional evidences/documents which were not submitted by the assessee\nbefore the AO dehorse provisions of Rule 46A of I.T. Rules and without calling\nremand report.\n9. On the facts and in the circumstances of the case and in law, the Ld. CIT(A)\nhas erred in deleting the addition of Rs.10,00,000/- made

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(1)(1), VADODARA, RACE COURSE vs. UNIMED TECHNOLOGIES LIMITED, HALOL

Accordingly dismissed.\n18.9 Based on the findings and conclusions set out hereinabove, the\nappeal filed by the Revenue stands dismissed, whereas the appeal filed by\nthe assessee is partly allowed

195. In\nresponse, the assessee, submitted that out of the total amount of\nRs.2,78,31,758/- claimed as exchange fluctuation loss, an amount of\nRs.20,71,664/- pertained to capital goods, and therefore, to that extent, the\nsaid loss was suo motu offered as capital in nature and not claimed as\nrevenue expenditure. However, upon verification of the assessee

UNIMED TECHNOLOGIES LIMITED,PANCHMAHAL vs. THE ACIT, CIRCLE-2(1)(1), VADODARA

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2016-17 Unimed Technologies Limited Acit, Cir.2(1)(1) Survey No.22 & 22, Vs. Vadodara. Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B Asstt.Year : 2016-17 Acit, Cir.2(1)(1) Unimed Technologies Limited Vadodara. Vs. Survey No.22 & 22, Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 17/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2025 आदेश आदेश/O R D E R आदेश आदेश

195. In response, the assessee, submitted that out of the total amount of Rs.2,78,31,758/- claimed as exchange fluctuation loss, an amount of Rs.20,71,664/- pertained to capital goods, and therefore, to that extent, the said loss was suo motu offered as capital in nature and not claimed as revenue expenditure. However, upon verification of the assessee

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, Revenue’s appeal is allowed in part

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

depreciation thereon. The Ld. CIT(A) deleted the addition following the decision of the ITAT in assessee’s own case in the A.Y. 2011- 12. The Ld. AR submitted that this issue was also involved in the A.Y. 2008-09. 12.2 We find that the Co-ordinate Bench of this Tribunal in the assessee’s own case

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, Revenue’s appeal is allowed in part

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

depreciation thereon. The Ld. CIT(A) deleted the addition following the decision of the ITAT in assessee’s own case in the A.Y. 2011- 12. The Ld. AR submitted that this issue was also involved in the A.Y. 2008-09. 12.2 We find that the Co-ordinate Bench of this Tribunal in the assessee’s own case

INTAS BIOPHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX,CIRCLE-2(1)(1),, AHMEDABAD

In the result, appeal preferred by the assessee is allowed in part

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 865/Ahd/2016 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12) िनधा"रण वष" िनधा"रण वष" Intas The Dy. Commissioner Of बनाम बनाम/ बनाम बनाम Biopharmaceuticals Ltd. Income Tax Vs. Plot 423/P/A, Sarkhej Circle-2(1)(1), Ahmedabad Bavla Highway, Moraiya, Sanand, Ahmedabad, Gujarat, 382213 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabci4722M (Appellant) .. (Respondent) Shri Bandish Soparkar & Shri Parin अपीलाथ" ओर से /Appellant By : Shah, Ars. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr & Shri Ashish Rajesh Revar, Sr. Dr Date Of Hearing 24/07/2024 Date Of Pronouncement 07/08/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-7, Ahmedabad (In Short ‘The Cit(A)’) Dated 20.01.2016 For The Assessment Year 2011-12. Ita No. 865/Ahd/2016 [Intas Biopharmaceuticals Ltd. Vs. Dcit] A.Y. 2011-12 - 2 –

depreciation allowance in respect of the same be eligible to the assessee company commencing from the year of put to use of relevant assets. 4. In law and in the facts and circumstances of the appellant's case. the learned assessing officer has grossly erred and the Ld. CIT A has grossly erred in confirming in making further disallowance

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

depreciation relying upon the\nadditional evidences/documents which were not submitted by the assessee\nbefore the AO dehorse provisions of Rule 46A of I.T. Rules and without calling\nremand report.\n9.\nOn the facts and in the circumstances of the case and in law, the Ld. CIT(A)\nhas erred in deleting the addition of Rs.10,00,000/- made

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

In the result, the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2020-21

195, Vs Ahmedabad Mason Compound, Rajkot Highway, Surendranagar PAN: AABCM2806L (Appellant) (Respondent) Assessee by: Shri Mehul Ranpura, A.R. Revenue by: Shri Alpesh Parmar, CIT-D.R. Date of hearing : 24-09-2025 Date of pronouncement : 12-12-2025 आदेश/ORDER Per Suchitra Kamble, Judicial Member: This is an appeal filed against the order dated 31-03- 2025 passed by PCIT

THE MADHAVPURA MERCANTILE CO. OP. BANK LIMITED (UNDER LIQUIDATION),AHMEDABAD vs. THE ACIT, CIRCLE-1(2), AHMEDABAD

The appeal of the assessee is partly allowed

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

depreciable assets which was adjusted with brought forward business loss. As per provision of section 72(1) of the Act, the brought forward business loss can be set-off only with the business profit. Therefore, the set-off of the current year STCG with brought forward business loss was not in accordance with the provisions of the Act, which

THE MADHAVPURA MERCANTILE CO. OP. BANK LIMITED (UNDER LIQUIDATION),AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is partly allowed

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinha

depreciable assets which was adjusted with brought forward business loss. As per provision of section 72(1) of the Act, the brought forward business loss can be set-off only with the business profit. Therefore, the set-off of the current year STCG with brought forward business loss was not in accordance with the provisions of the Act, which

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-8,, AHMEDABAD

In the result appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita.No.1285 & 1286/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2009-10 & 2010-11 & Ita No.1396 & 1397/Ahd/2018 Asstt.Year 2011-12 & 2012-13 Torrent Pharmaceuticals Ltd. Acit, Circle-4(1)(2) Torrent House Ahmedabad. Vs. Off.Ashram Road Ahmedabad 380 009. आयकर अपील सं./Ita.No.1327 & 1328/Ahd/2017 िनधा"रण वष"/ Asstt. Year: 2009-10 & 2010-11 & आयकर अपील सं./Ita.No.1414 & 1415/Ahd/2018 िनधा"रण वष"/ Asstt. Year: 2011-12 & 2012-13 Acit, Circle-4(1)(2) Torrent Pharmaceuticals Ltd. Ahmedabad. Torrent House Vs. Off.Ashram Road Ahmedabad 380 009. (Applicant) (Responent) Assessee By : Shri Vartik Choksi, With Shri Biren Shah, Ars. Revenue By : Shri Mohd. Usman, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 23/11/2021 घोषणा क" तारीख /Date Of Pronouncement: 22/02/2022 आदेश/O R D E R Per Bench

195 Nil Impairment loss on asset held for 2,556,779 NIL sale Tax Depreciation 340,762,513 164,830,419 32.1. The ld. counsel for the assessee has drawn our attention to statement of income, wherein the assessee has claimed deduction of Rs.183.91 crores under section