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

41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill 2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

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

41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill 2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR, AHMEDABAD vs. AIA ENGINEERING LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 397/Ahd/2024 िनधा"रण वष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Dcit Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J आयकर अपील सं / Ita No. 532/Ahd/2024 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Acit, Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" िनधा"रती की ओर से / Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar ""थ" की ओर से / Revenue By : Shri Pratik Sharma, Sr Dr & Shri Sudhendu Das, Cit-Dr तारीख/Date Of Hearing : 09.10.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 21.10.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

2.—For the purposes of this [sub-section] "written down value of the block of assets" shall have the same meaning as in clause *(c) of sub-section †(6) of section 43.] [Explanation 3.—For the purposes of this sub-section, the expressions "assets" and "block of assets" shall mean— (a) tangible assets, being buildings, machinery, plant or furniture

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

depreciation on goodwill. 12. The Ld. CIT(A) in this appeal has also held that the assessment order was void ab inito as the assessment was made by the AO in the name of M/s.Unicorn Packaging Pvt.Ltd., whereas, by the time the said company ceased to exist as the same was converted into a limited liability partnership-firm

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)

depreciation on goodwill arising out of amalgamation of Rs.132,47,53,370/- u/s.32 of the Act. 6. The Ld. CIT(A) has erred in law and facts of the case in confirming the action of AO in holding that the goodwill has to be taken at NIL cost in the hands of the appellant. 7. Both the lower authorities have

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)

depreciation on goodwill arising out of amalgamation of Rs.132,47,53,370/- u/s.32 of the Act. 6. The Ld. CIT(A) has erred in law and facts of the case in confirming the action of AO in holding that the goodwill has to be taken at NIL cost in the hands of the appellant. 7. Both the lower authorities have

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)

depreciation on goodwill arising out of amalgamation of Rs.132,47,53,370/- u/s.32 of the Act. 6. The Ld. CIT(A) has erred in law and facts of the case in confirming the action of AO in holding that the goodwill has to be taken at NIL cost in the hands of the appellant. 7. Both the lower authorities have

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)

depreciation on goodwill arising out of amalgamation of Rs.132,47,53,370/- u/s.32 of the Act. 6. The Ld. CIT(A) has erred in law and facts of the case in confirming the action of AO in holding that the goodwill has to be taken at NIL cost in the hands of the appellant. 7. Both the lower authorities have

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. UTTAR GUJARAT VIJ COMPANY LTD.,, MEHSANA

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2010-11

depreciation on related assets to its P&L account. The Ld. CIT(A) erred in deleting the addition to book profits u/s.115JB by merely relying on the decision of the Tribunal in Gujarat State Energy Generation Ltd. (ITA No.1777/Ahd/2009), without examining the facts of the case, and without appreciating the ratio decidendi, and without considering that the facts in this

UTTAR GUJARAT VIJ COMPANY LTD.,,MEHSANA vs. THE INCOME TAX OFFICER, WARD-2(1)(4),, BARODA

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2010-11

depreciation on related assets to its P&L account. The Ld. CIT(A) erred in deleting the addition to book profits u/s.115JB by merely relying on the decision of the Tribunal in Gujarat State Energy Generation Ltd. (ITA No.1777/Ahd/2009), without examining the facts of the case, and without appreciating the ratio decidendi, and without considering that the facts in this

UTTAR GUJARAT VIJ COMPANY LTD.,,MEHSANA vs. THE ACIT, CIRCLE 4, BARODA

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2010-11

depreciation on related assets to its P&L account. The Ld. CIT(A) erred in deleting the addition to book profits u/s.115JB by merely relying on the decision of the Tribunal in Gujarat State Energy Generation Ltd. (ITA No.1777/Ahd/2009), without examining the facts of the case, and without appreciating the ratio decidendi, and without considering that the facts in this

UTTAR GUJARAT VIJ COMPANY LTD.,,MEHSANA vs. THE INCOME TAX OFFICER, WARD-2(1)(4),, BARODA

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2010-11

depreciation on related assets to its P&L account. The Ld. CIT(A) erred in deleting the addition to book profits u/s.115JB by merely relying on the decision of the Tribunal in Gujarat State Energy Generation Ltd. (ITA No.1777/Ahd/2009), without examining the facts of the case, and without appreciating the ratio decidendi, and without considering that the facts in this

UTTAR GUJARAT VIJ COMPANY LTD.,,MEHSANA vs. THE DCIT, CIRCLE-2(1)(1),, BARODA

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2010-11

depreciation on related assets to its P&L account. The Ld. CIT(A) erred in deleting the addition to book profits u/s.115JB by merely relying on the decision of the Tribunal in Gujarat State Energy Generation Ltd. (ITA No.1777/Ahd/2009), without examining the facts of the case, and without appreciating the ratio decidendi, and without considering that the facts in this