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

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

depreciation thereon under the provisions of the Act. 11.3 Without prejudice to the above, hedging charges amounting to Rs. 10,00,30,513/- incurred towards investment made by the Company in overseas subsidiary companies should be adjusted to the cost of acquisition of such investment. 12. Re: Double taxation of Income from Capital gains and other sources.: 12.1 The Assessing