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 claimed on goodwill amounting to Rs.227,92,50,000/- had been rightly allowed by the CIT(A) in accordance with law and settled judicial precedents. The AR submitted that the goodwill had arisen pursuant to a scheme of amalgamation between the assessee and its wholly owned subsidiary (ILPL), which was duly sanctioned by the Hon’ble Gujarat High Court

THE ARVIND LTD,AHMEDABAD vs. THE ACIT.,CIRCLE-1,, AHMEDABAD

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 862/Ahd/2012 िनधा"रण वष"/Asstt. Year: 2007-2008 Arvind Ltd.(Earlier Known As Arvind A.C.I.T., Mills Ltd.), Vs. Circle-1, Naroda Road, Ahmedabad. Naroda, Ahmedabad.

depreciation can be carried forward from the de-merged company to the resulting company. ii. Neither the companies nor the shareholders are subject to capital gains tax. iii. Expenses incurred wholly for the purpose of de-merger are allowed as a deduction in five annual instalments being 20 per cent in each year. 11.4 The above benefits, however, will

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

Appeal of the assessee is dismissed

391/- made on short term advance to its overseas subsidiaries is held justified and is hereby confirmed. Relevant ground of appeal is rejected. 8. Before us, the Ld. Counsel for the assessee reiterated the contentions made before the lower authorities that the impugned advances were in the nature of quasi equity capital since they were given to the subsidiaries which

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

Appeal of the assessee is dismissed

391/- made on short term advance to its overseas subsidiaries is held justified and is hereby confirmed. Relevant ground of appeal is rejected. 8. Before us, the Ld. Counsel for the assessee reiterated the contentions made before the lower authorities that the impugned advances were in the nature of quasi equity capital since they were given to the subsidiaries which

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

Appeal of the assessee is dismissed

391/- made on short term advance to its overseas subsidiaries is held justified and is hereby confirmed. Relevant ground of appeal is rejected. 8. Before us, the Ld. Counsel for the assessee reiterated the contentions made before the lower authorities that the impugned advances were in the nature of quasi equity capital since they were given to the subsidiaries which

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)

391 760\n(Assessee)\nPAN: AAACG8588 L\nThe DCIT\nCircle-4(1), Baroda\nThe Income Tax\nOfficer\nWard-4(1)\nBaroda\n(Revenue)\n2.\n2007/Ahd/2007\n2004-05\n-do-Revenue\nBy Assessee\n3.\n1619/Ahd/2008\n2005-06\nBy Assessee\n4.\n1382/Ahd/2009\n2003-04\n-do-Revenue\nBy Assessee\n5.\n1383/Ahd/2009\n2006-07\n-do-Revenue\nBy Assessee\nAssessee by: Ms. Amrin

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 :

391 760 (Assessee) (Revenue) PAN: AAACG8588 L 2007/Ahd/2007 2. 2004-05 The DCIT By Assessee Circle-4(1),Baroda 1619/Ahd/2008 3. 2005-06 -do-Revenue By Assessee 4. 1382/Ahd/2009 2003-04 -do-Revenue By Assessee 1383/Ahd/2009 5. 2006-07 -do-Revenue By Assessee Assessee by : Ms. Amrin Pathan, AR Revenue by : Shri Waghe Prasadrao, Sr.DR सुनवाई की तारीख/Date

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 :

391 760 (Assessee) (Revenue) PAN: AAACG8588 L 2007/Ahd/2007 2. 2004-05 The DCIT By Assessee Circle-4(1),Baroda 1619/Ahd/2008 3. 2005-06 -do-Revenue By Assessee 4. 1382/Ahd/2009 2003-04 -do-Revenue By Assessee 1383/Ahd/2009 5. 2006-07 -do-Revenue By Assessee Assessee by : Ms. Amrin Pathan, AR Revenue by : Shri Waghe Prasadrao, Sr.DR सुनवाई की तारीख/Date

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 :

391 760 (Assessee) (Revenue) PAN: AAACG8588 L 2007/Ahd/2007 2. 2004-05 The DCIT By Assessee Circle-4(1),Baroda 1619/Ahd/2008 3. 2005-06 -do-Revenue By Assessee 4. 1382/Ahd/2009 2003-04 -do-Revenue By Assessee 1383/Ahd/2009 5. 2006-07 -do-Revenue By Assessee Assessee by : Ms. Amrin Pathan, AR Revenue by : Shri Waghe Prasadrao, Sr.DR सुनवाई की तारीख/Date

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 :

391 760 (Assessee) (Revenue) PAN: AAACG8588 L 2007/Ahd/2007 2. 2004-05 The DCIT By Assessee Circle-4(1),Baroda 1619/Ahd/2008 3. 2005-06 -do-Revenue By Assessee 4. 1382/Ahd/2009 2003-04 -do-Revenue By Assessee 1383/Ahd/2009 5. 2006-07 -do-Revenue By Assessee Assessee by : Ms. Amrin Pathan, AR Revenue by : Shri Waghe Prasadrao, Sr.DR सुनवाई की तारीख/Date

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

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

391 to 394 of Companies Act, 1956 vide order dated 03.05.2013 in Company claim Petition No. 283 of 2013 and also by the Hon'ble Gujrat High Court vide order dated 03.05.2013 [pages 679 to 682 of the Paper Book] in Company Petition No. 31 of 2013 connected with the Company Application No. 373 of 2012. The assets received

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

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

391 to 394 of Companies Act, 1956 vide order dated 03.05.2013 in Company claim Petition No. 283 of 2013 and also by the Hon'ble Gujrat High Court vide order dated 03.05.2013 [pages 679 to 682 of the Paper Book] in Company Petition No. 31 of 2013 connected with the Company Application No. 373 of 2012. The assets received

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

391 (Guj)] by the High Court of Gujarat, in our view, correctly, to mean as income “arising or accruing in India”. The amendment to the section by way of an Explanation in 1983 effected a change in the scope of that judicial definition so as to include with effect from 1979, “income payable for service rendered in India”. 19. When

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

391 (Guj)] by the High Court of Gujarat, in our view, correctly, to mean as income “arising or accruing in India”. The amendment to the section by way of an Explanation in 1983 effected a change in the scope of that judicial definition so as to include with effect from 1979, “income payable for service rendered in India”. 19. When

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

391 (Guj)] by the High Court of Gujarat, in our view, correctly, to mean as income “arising or accruing in India”. The amendment to the section by way of an Explanation in 1983 effected a change in the scope of that judicial definition so as to include with effect from 1979, “income payable for service rendered in India”. 19. When

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

391 (Guj)] by the High Court of Gujarat, in our view, correctly, to mean as income “arising or accruing in India”. The amendment to the section by way of an Explanation in 1983 effected a change in the scope of that judicial definition so as to include with effect from 1979, “income payable for service rendered in India”. 19. When