DCIT CIRCLE-2(1)(1), AHMEDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

DCIE CIRCLE-2(1)(1), AHEMDABAD, VEJALPUR vs. ERIS LIFESCIENCES LIMITED SHIVARTH AMBIT, BODAKDEV AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION - THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DELHI (PRESENT JURISDICTION- THE DY. CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

ERIS LIFESCIENCES LIMITED,AHMEDABAD vs. NFAC, DEHI (PRESENT JURISDICTION- THE DY.CIT, CIRCLE-2(1)(1)), AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

DCIT, CIRCLE-2(1)(1) AHMEDABAD, AHMEDABAD vs. ERIS LIFESCIENCE LIMITED SHIVARTH AMBIT, AHMEDABAD

In the result, for assessment year 2022-23, the appeal of the Department is partly allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation and other common expenses in the ratio of Guwahati sales to total sales, assessee adopted a different method division only for employee benefit expenses, resulting in lower allocation to the eligible unit and thereby inflating profits of the 80-IE unit. The AO rejected the assessee’s methodology as inconsistent, and being insufficiently supported and based on unverifiable division

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, CIRCLE-1(1)(2), AHMEDABAD

Appeal are dismissed as not pressed

depreciation on Hummer car. The assessee gets the relief accordingly. 108. Ground no. 8 is thus allowed.” 35. In our view, since the issue is directly covered in favour of the assessee in his own case for assessment years 2009-10 and 2010-11 and assessment years 2012-13 and 2013-14, respectfully following the orders passed on 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)

234/- from eligible R&D expense. The ld. A.R. explained that the assessee had made additional claim of Rs.60,36,617/- being 50% of weighed deduction in respect of return towards CRO realization, which was suo moto disallowed by the assessee on a conservative basis. He explained that the assessee had earned certain income from contract research carried for other

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)

234/- from eligible R&D expense. The ld. A.R. explained that the assessee had made additional claim of Rs.60,36,617/- being 50% of weighed deduction in respect of return towards CRO realization, which was suo moto disallowed by the assessee on a conservative basis. He explained that the assessee had earned certain income from contract research carried for other

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

section (5) of Section 80-IA. In this case, the question that arose for consideration ITA.Nos.1285/Ahd/2017 & 7 others A.Y.2009-10 38 before this Court related to computation of the profits for the purpose of deduction under section 80-E, as it then existed, after setting off the loss incurred by the assessee in the manufacture of alloy steels. Section

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

In the result, the appeal is allowed for statistical purposes

depreciation against\nincome from short-term capital gains\n11. Before us, the counsel for the assessee submitted that this ground is\nrelevant only if ground number 14A and ground related to brokerage charges\nare allowed in favour of the Revenue, in the appeal filed by the Department.\nITA No. 954/Ahd/2016, 1315/Ahd/2016,\n1807/Ahd/2017 & 2033/Ahd/2017\nAmbalal Sarabhai Enterprises Ltd. vs. DCIT

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation against income from short-term capital gains 11. Before us, the counsel for the assessee submitted that this ground is relevant only if ground number 14A and ground related to brokerage charges are allowed in favour of the Revenue, in the appeal filed by the Department. ITA No. 954/Ahd/2016, 1315/Ahd/2016, 1807/Ahd/2017 & 2033/Ahd/2017 Ambalal Sarabhai Enterprises Ltd. vs. DCIT & DCIT/ACIT

THE ASST. CIT.,CIRCLE-1(1),, BARODA vs. AMBALAL SARABHAI ENTERPRISES LIMITED,, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

depreciation against income from short-term capital gains 11. Before us, the counsel for the assessee submitted that this ground is relevant only if ground number 14A and ground related to brokerage charges are allowed in favour of the Revenue, in the appeal filed by the Department. ITA No. 954/Ahd/2016, 1315/Ahd/2016, 1807/Ahd/2017 & 2033/Ahd/2017 Ambalal Sarabhai Enterprises Ltd. vs. DCIT & DCIT/ACIT

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

In the result, the appeal is allowed for statistical purposes

depreciation against\nincome from short-term capital gains\n11.\nBefore us, the counsel for the assessee submitted that this ground is\nrelevant only if ground number 14A and ground related to brokerage charges\nare allowed in favour of the Revenue, in the appeal filed by the Department.\nITA No. 954/Ahd/2016, 1315/Ahd/2016,\n1807/Ahd/2017 & 2033/Ahd/2017\nAmbalal Sarabhai Enterprises Ltd. vs. DCIT

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

depreciation of Rs. 8.347/- 13. The learned CIT(A) erred in fact and law in confirming the action of the Id. AO in making a disallowance of deductions of Rs. 77,958/- claimed by the Appellant under Chapter VI-A of the Act. 14. The learned CIT(A) erred in fact and law in confirming the action

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

depreciation of Rs. 8.347/- 13. The learned CIT(A) erred in fact and law in confirming the action of the Id. AO in making a disallowance of deductions of Rs. 77,958/- claimed by the Appellant under Chapter VI-A of the Act. 14. The learned CIT(A) erred in fact and law in confirming the action

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

depreciation of Rs. 8.347/- 13. The learned CIT(A) erred in fact and law in confirming the action of the Id. AO in making a disallowance of deductions of Rs. 77,958/- claimed by the Appellant under Chapter VI-A of the Act. 14. The learned CIT(A) erred in fact and law in confirming the action

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

depreciation of Rs. 8.347/- 13. The learned CIT(A) erred in fact and law in confirming the action of the Id. AO in making a disallowance of deductions of Rs. 77,958/- claimed by the Appellant under Chapter VI-A of the Act. 14. The learned CIT(A) erred in fact and law in confirming the action

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

depreciation of Rs. 8.347/- 13. The learned CIT(A) erred in fact and law in confirming the action of the Id. AO in making a disallowance of deductions of Rs. 77,958/- claimed by the Appellant under Chapter VI-A of the Act. 14. The learned CIT(A) erred in fact and law in confirming the action