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

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 14A r.w.s. Rule 8D 8,70,747 5 Disallowance of Weighted Deduction under 65

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

depreciation. In the present case, the goodwill represents the expected future economic benefits arising from business consolidation, synergy, and operational continuity — all recognized aspects of goodwill under law. Revised Ground No. 7: 65. The Department seeks to apply Explanation 7 to section

SPORTS AUTHORITY OF GUJARAT,GANDHINAGAR vs. THE DCIT (EXEMPRTION) (HQ), AHMEDABAD

In the result, Ground Number 3 of the assessee’s appeal is dismissed

65,042/-, the ld. CIT(A) held that the claim of depreciation was not routed through the profit and loss account but was separately claimed in the statement of total income. Since the interest income itself has been held to “income from other sources”, the claim of depreciation which is governed by the provisions of section

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE DY.CIT.,CRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 41(1) of the Act. 65. The AO during the assessment proceedings found that there was the outstanding amount payable by the assessee for Rs.80,000/- against the purchase of old car which was due since the long-time. Furthermore, the assessee has claimed depreciation

SHREE RAMA MULTI-TECH LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 41(1) of the Act. 65. The AO during the assessment proceedings found that there was the outstanding amount payable by the assessee for Rs.80,000/- against the purchase of old car which was due since the long-time. Furthermore, the assessee has claimed depreciation

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE INDIA PRIVATE LIMITED , HARYANA

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

65,61,88,427/- 2022–23 — Rs.1,26,54,00,107/- 5.3 We now take up the Revenue’s ground challenging the deletion of disallowance of depreciation on goodwill. 5.4 During the course of assessment proceedings, the AO noted that the assessee had claimed depreciation of Rs.6,61,91,21,210/- on goodwill. This goodwill was stated to have arisen

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE INDIA PRIVATE LIMITED , HARYANA

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

65,61,88,427/- 2022–23 — Rs.1,26,54,00,107/- 5.3 We now take up the Revenue’s ground challenging the deletion of disallowance of depreciation on goodwill. 5.4 During the course of assessment proceedings, the AO noted that the assessee had claimed depreciation of Rs.6,61,91,21,210/- on goodwill. This goodwill was stated to have arisen

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE INDIA PRIVATE LIMITED, GURGAON

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

65,61,88,427/- 2022–23 — Rs.1,26,54,00,107/- 5.3 We now take up the Revenue’s ground challenging the deletion of disallowance of depreciation on goodwill. 5.4 During the course of assessment proceedings, the AO noted that the assessee had claimed depreciation of Rs.6,61,91,21,210/- on goodwill. This goodwill was stated to have arisen

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE INDIA PRIVATE LIMITED , HARYANA

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

65,61,88,427/- 2022–23 — Rs.1,26,54,00,107/- 5.3 We now take up the Revenue’s ground challenging the deletion of disallowance of depreciation on goodwill. 5.4 During the course of assessment proceedings, the AO noted that the assessee had claimed depreciation of Rs.6,61,91,21,210/- on goodwill. This goodwill was stated to have arisen

MAXXIS RUBBER INDIA PVT. LTD.,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

65,82,83,901 - 3,02,59,885 half rate to be allowed (7 - 8) 10 Depreciation on 6 at full rate 2,33,03,59,584 - 10,47,47,906 11 Depreciation on 9 at half rate 49,93,71,293 - 60,51,977 12 Additional depreciation, if any, on 25,60,45,955 - - 4 13 Additional depreciation

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

65,054/- after rectification order u/s 154 dt. 06.02.2020) on electrical fittings u/s 32 of the Act?" 3. The appellant craves leave to amend or alter any ground or add a new ground, which may be necessary. It is, therefore, prayed that the order of Ld. CIT(A) may be set aside and that of the Assessing Officer be restored

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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 :

section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Income-tax Act." 3) "The Revenue craves leave to add/alter/armed and/or substitute any or all of the grounds of appeal." 3. The brief facts of the case, as culled out from the assessment order

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

Appeal of the assessee is dismissed

65,040) respectively for the two loans. The proposed adjustment was made by the A.O. in his order passed u/s. 143(3) of the Act. 7. The matter was carried before the Ld. CIT(A) who upheld the adjustment relying on the decision of the ITAT Ahmedabad Bench in the case of Soma Textile Industries vs. Addl.CIT

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

Appeal of the assessee is dismissed

65,040) respectively for the two loans. The proposed adjustment was made by the A.O. in his order passed u/s. 143(3) of the Act. 7. The matter was carried before the Ld. CIT(A) who upheld the adjustment relying on the decision of the ITAT Ahmedabad Bench in the case of Soma Textile Industries vs. Addl.CIT