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

depreciation in Rule 5 of the Income Tax Rules, 1962, are different from the rates specified in Schedule XIV of 1956 Act. In fact, by the Companies (Amendment) Act, 1988, the linkage between the two has been expressly de-linked. Hence, what is incorporated in Section 115J is only Schedule VI and not Section 205 or Section 350 or Section

KALPATARU POWER TRANSMISSION LTD.,,GANDHINAGAR vs. THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the assessee is dismissed

253 (Ahmedabad) 10. At this juncture, Ld. Counsel for the assessee was asked at bar to demonstrate with evidence as to how the loan given in the present case would qualify as quasi capital and or given for commercial expediency of the assessee as were the facts in the case of Micro Inks Ltd. (supra) referred

KALPATARU POWER TRANSMISSION LTD.,,GANDHINAGAR vs. THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the assessee is dismissed

253 (Ahmedabad) 10. At this juncture, Ld. Counsel for the assessee was asked at bar to demonstrate with evidence as to how the loan given in the present case would qualify as quasi capital and or given for commercial expediency of the assessee as were the facts in the case of Micro Inks Ltd. (supra) referred

THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. KALPARATRU POWER TRANSMISSION LIMITED,, GANDHINAGAR

Appeal of the assessee is dismissed

253 (Ahmedabad) 10. At this juncture, Ld. Counsel for the assessee was asked at bar to demonstrate with evidence as to how the loan given in the present case would qualify as quasi capital and or given for commercial expediency of the assessee as were the facts in the case of Micro Inks Ltd. (supra) referred

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. The assessment order dated 05.12.2017 refers to and deals with the revised return and proceeds to make various additions under normal and MAT provisions. 4.2. At this stage, it is necessary to emphasize that the present appeal arises from an order passed under section 263 of the Act. We, in exercise of its appellate jurisdiction under section 253

THE DCIT, CIRCLE-4,, VADODARA vs. M/S. MUNJAL AUTO INDUSTRIES LTD.,, VADODARA

Appeal is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

253 (SC). 3. During the course of hearing the Departmental Representative (DR) made a detailed submission before us, focusing on the applicability of Explanation 10 to Section 43(1) of the Income-tax Act, 1961, and the correct computation of book profits under Section 115JB of the Act. 3.1. On this background, we now first deal with Revenue’s Grounds

THE DCIT, CIRCLE-4,, VADODARA vs. M/S. MUNJAL AUTO INDUSTRIES LTD.,, VADODARA

Appeal is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

253 (SC). 3. During the course of hearing the Departmental Representative (DR) made a detailed submission before us, focusing on the applicability of Explanation 10 to Section 43(1) of the Income-tax Act, 1961, and the correct computation of book profits under Section 115JB of the Act. 3.1. On this background, we now first deal with Revenue’s Grounds

M/S. MUNJAL AUTO INDUSTRIES LTD.,,BARODA vs. THE INCOME TAX OFFICER,WARD-4(1),, BARODA

Appeal is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

253 (SC). 3. During the course of hearing the Departmental Representative (DR) made a detailed submission before us, focusing on the applicability of Explanation 10 to Section 43(1) of the Income-tax Act, 1961, and the correct computation of book profits under Section 115JB of the Act. 3.1. On this background, we now first deal with Revenue’s Grounds

THE DCIT, CIRCLE-4,, VADODARA vs. MUNJAL AUTO INDUSTRIES LTD.,, VADODARA

Appeal is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

253 (SC). 3. During the course of hearing the Departmental Representative (DR) made a detailed submission before us, focusing on the applicability of Explanation 10 to Section 43(1) of the Income-tax Act, 1961, and the correct computation of book profits under Section 115JB of the Act. 3.1. On this background, we now first deal with Revenue’s Grounds

THE DCIT, CIRCLE-4(1),, VADODARA vs. MUNJAL AUTO INDUSTRIES LTD.,, VADODARA

Bench: SHRI T.R. SENTHIL KUMAR, JUDICIAL MEMBER &\nSHRI MAKARAND V. MAHADEOKAR (Accountant Member)

253 (SC).\nDuring the course of hearing the Departmental Representative (DR)\nmade a detailed submission before us, focusing on the applicability of\nExplanation 10 to Section 43(1) of the Income-tax Act, 1961, and the correct\ncomputation of book profits under Section 115JB of the Act.\n3. 1. On this background, we now first deal with Revenue's Grounds

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5 others A.Y.2013-14 43 account of benchmarking of loan to AE. Thus, the ground of the appeal filed by the assessee is hereby allowed. Capital Infusion. 55. The TPO found that the assessee during the year has made payment of share application money to the following AEs: S. Name of AE Amount in Rs. Date of Date of share

GUJARAT STATE ELECTRICITY CORPN. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Dr Brr Kumarshri Siddhartha Nautiyalआयकर अपील सं /Ita No. 1596/Ahd/2024 िनधा"रण वष" /Assessment Year : 2006-07

depreciation. 4. The appellant craves leave to add, amend or alter the grounds of appeal at the time of hearing, if need arise. 3. The Revenue has raised the following grounds of appeal: i) “Whether on the facts and circumstances of case and in law, the Ld.CIT(A) is justified in deleting the Addition on account of Extraordinary items amounting

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1), VADODARA, VADODARA vs. GUJARAT STATE ELECTRICITY CORPORATION LIMITED, VADODARA

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

Bench: Dr Brr Kumarshri Siddhartha Nautiyalआयकर अपील सं /Ita No. 1596/Ahd/2024 िनधा"रण वष" /Assessment Year : 2006-07

depreciation. 4. The appellant craves leave to add, amend or alter the grounds of appeal at the time of hearing, if need arise. 3. The Revenue has raised the following grounds of appeal: i) “Whether on the facts and circumstances of case and in law, the Ld.CIT(A) is justified in deleting the Addition on account of Extraordinary items amounting

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

Appeals are partly allowed for\nstatistical reasons

5)\nand Rs.7,88,200/- made out of soil filling expenses (Ground No. 6) on the\nground of lack of documentation. The Revenue, on the other hand, has\nchallenged the CIT(A)'s action of restricting the disallowance of site\ndevelopment expenses to Rs.7,88,200/- as against Rs.78,82,000/- made by\nthe AO, contending that such expenses

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

253 ITR 749) for the proposition that for the purpose\nof section 32, registration in the assessee's own name is not mandatory if\nbeneficial ownership and business use are established.\n80. On this issue, the learned AR placed reliance on the findings of the\nlearned CIT(A), whereas the learned DR supported the order of the\nAssessing Officer

ADANI ENTERPRISES LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD

Appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedasstt. Sr.No.

253 ITR 749 wherein it is held as under: "Section 37(1) of the Income-tax Act, 1961, read with sections 198 and 309 of the Companies Act, 1956 - Business expenditure - Allowability of - Assessment year 1979-80 - Whether when vehicles belonging to an assessee-company are used by its directors, for personal or other purposes, it would be wrong

CERA SANITARYWARE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

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

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

Depreciation 19.433 Cost + Dep)] 95,514.40 Other overheads [25% of (Emp. Total 4,77,572 Employees cost Total Cost Total time Amount involved (%) (Rs.) 1,31,39,648 1% 1,31,396 Rajesh B. Shah, CFO and COO (Fin. & Comm.) Vinit Jain, Asst. Manager 36,38,445 2% 72,769 Rini Bhiwaniwala 15,84,597 1,58,460 10% Total

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

Appeals are partly allowed for\nstatistical reasons

5)\nand Rs.7,88,200/- made out of soil filling expenses (Ground No. 6) on the\nground of lack of documentation. The Revenue, on the other hand, has\nchallenged the CIT(A)'s action of restricting the disallowance of site\ndevelopment expenses to Rs.7,88,200/- as against Rs.78,82,000/- made by\nthe AO, contending that such expenses