THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year) : Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

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

1)(iii)(e), explanation 2 to section 43(6) and section 55(2). 8. Whether the CIT(A) has erred in law and on facts in not appreciating that the Goodwill arose was allocated to Dehradun and Sikkim Units, which are part and parcel of the transferor company and after amalgamation depreciation claimed on goodwill is at higher valuation

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

1)(iii)(e), explanation 2 to section 43(6) and section 55(2). 8. Whether the CIT(A) has erred in law and on facts in not appreciating that the Goodwill arose was allocated to Dehradun and Sikkim Units, which are part and parcel of the transferor company and after amalgamation depreciation claimed on goodwill is at higher valuation

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD vs. TROIKAA PHARMACEUTICLAS LIMITED,, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

36, (c) the expenditure must not be in the nature of capital expenditure or personal expenditure of the assessee, and (d) expenditure must be laid out or expended wholly and exclusively for the purpose of business or profession. The expression “wholly” employed in section 37 refers to quantification of expenditure while expression “exclusively” refers to the motive, objective and purpose

THE DCIT, CIRCLE-4(1)(2), AHMEDABAD vs. TROIKAA PHARMACEUTICALS LTD, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

36, (c) the expenditure must not be in the nature of capital expenditure or personal expenditure of the assessee, and (d) expenditure must be laid out or expended wholly and exclusively for the purpose of business or profession. The expression “wholly” employed in section 37 refers to quantification of expenditure while expression “exclusively” refers to the motive, objective and purpose

NATIONAL DAIRY DEVELOPMENT BOARD,,ANAND vs. THE ASSTT. COMMISSIONER OF INCOME TAX, ANAND CIRCLE,, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

36,90,077/- under section 14A following the appellate order for AY 2010-11. In the facts and circumstances of the case it is submitted that no disallowance under section 14A is required to be made. It is submitted that it be so held now. 3.1 The Hon’ble CIT(A) has erred in not appreciating that section

THE DY.COMMISSIONER OF INCOME TAX.,ANAND CIRCLE,, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

36,90,077/- under section 14A following the appellate order for AY 2010-11. In the facts and circumstances of the case it is submitted that no disallowance under section 14A is required to be made. It is submitted that it be so held now. 3.1 The Hon’ble CIT(A) has erred in not appreciating that section

THE ACIT,ANAND CIRCLE,, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

36,90,077/- under section 14A following the appellate order for AY 2010-11. In the facts and circumstances of the case it is submitted that no disallowance under section 14A is required to be made. It is submitted that it be so held now. 3.1 The Hon’ble CIT(A) has erred in not appreciating that section

NATIONAL DAIRY DEVELOPMENT BOARD,,ANAND vs. THE ACIT.,ANAND CIRCLE,, ANAND

In the result, Ground No. 7 of the assessee’s appeal is allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

36,90,077/- under section 14A following the appellate order for AY 2010-11. In the facts and circumstances of the case it is submitted that no disallowance under section 14A is required to be made. It is submitted that it be so held now. 3.1 The Hon’ble CIT(A) has erred in not appreciating that section

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

36(1)(iii)", "68", "37(1)", "80GGB", "32", "143(3)", "139(1)", "142(1)", "271(1)(c)", "274"], "issues": "The appeals concern disallowances under Section 14A read with Rule 8D, notional interest on advances, cost of land, site development expenses, deduction under section 80GGB, depreciation

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

ACIT, ANAND CIRCLE, ANAND, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

ACIT, ANAND CIRCLE, ANAND, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

NATIONAL DAIRY DEVELOPMENT BOARD,ANAND vs. THE DY.CIT, ANAND CIRCLE, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A

ACIT,ANAND CIRCLE, ANAND, ANAND vs. NATIONAL DAIRY DEVELOPMENT BOARD, ANAND

In the result, the appeals filed by the Revenue in ITA Nos

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

depreciation on building  Disallowance of deduction of interest paid to North Kerala Project Development Fund  Disallowance of contribution to Employee’s Recreation (BOHO Club)  Disallowance of payment of monthly benefit to employees under VRS scheme after retirement – Section 35DDA, Section 37(1)  Applicability of MAT u/s 115JB  Adjustment of withdrawal from reserves and provisions to book profit u/s 115JB I.T.A