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. The facts have been thoroughly verified, the legal position is supported by binding precedents, and the Revenue has failed to demonstrate that the transaction lacks commercial substance or that the claim falls afoul of any specific bar under the Act. All the revised grounds of appeal raised by the Revenue stand rejected. Original Ground

THE DCIT, CIRCLE-1(3), AHMEDABAD vs. EDELWEISS BROKING LTD., AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

73 of the I. T. Act, 1961. (8) That the ld. CIT(A) has erred in law and on the facts in directing to re- compute the Capital Gain by ignoring the fact that the AO has rightly computed the Capital Gain as per provision of Section 48 of the I. T. Act, 1961 for indexing the cost from

M/S. EDELWEISS BROKING LTD. ( AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.),AHMEDABAD vs. THE JT. CIT, RANGE-3,, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

73 of the I. T. Act, 1961. (8) That the ld. CIT(A) has erred in law and on the facts in directing to re- compute the Capital Gain by ignoring the fact that the AO has rightly computed the Capital Gain as per provision of Section 48 of the I. T. Act, 1961 for indexing the cost from

THE DCIT, CIRCLE-1(3), AHMEDABAD vs. EDELWEISS FINANCIAL ADVISORS LTD., ( FORMERLY KNOWN ANAGRAM STOCK BROKING LTD.,), AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

73 of the I. T. Act, 1961. (8) That the ld. CIT(A) has erred in law and on the facts in directing to re- compute the Capital Gain by ignoring the fact that the AO has rightly computed the Capital Gain as per provision of Section 48 of the I. T. Act, 1961 for indexing the cost from

M/S. SABARMATI GAS LTD.,GANDHINAGAR vs. THE PR. CIT-3, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2018-19 Sabarmati Gas Ltd. The Ld.Pr.Cit Plot No.907, Sector 21 Vs Ahmedabad-3. Gandhinagar 382 021 Pan : Aakcs 0110 N

section 73, the allowance or the part of the allowance to which effect has not been given, as the case may be, shall be added to the amount of the allowance for depreciation

M/S. EDELWEISS BROKING LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(3), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

depreciation of Rs. 13,55,778/-, interest expenses of Rs. 55,585/- and insurance of Rs. ITA No.2021/Ahd/2017 & 1939/A/17 [M/s. Edelweiss Broking Ltd. vs. DCIT] A.Y. 2013-14 - 3 - 16,875/- and made aggregated disallowance of Rs. 14,28,238/-. In appeal before the Ld. CIT(A) thereafter assessee preferred First Statutory Appeal before the Ld. CIT(A), granted relief

DCIT, CIRCLE-1(3), , AHMEDABAD vs. EDELWEISS BROKING LTD.(ON BEHALF OF AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.), AHMEDABAD

Appeal of the Revenue is dismissed whereas the ground of appeal of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Wassem Ahmedआयकर अपील सं./I.T.A. No. 2021/Ahd/2017 ("नधा"रण वष" / Assessment Year: 2013-14) M/S. Edelweiss Broking Ltd. Dcit बनाम/ (On Behalf Of Amalgamating Cricle-1(3), Vs. 1St Floor, B-109, Company, Edelweiss Financial Advisors Ltd.) Pratyaksh Kar Bhavan, Nr. 801-804, 8Th Floor, Abhishree Panjrapole, Ambawadi, Avenue, Opp. Hanumanji Ahmedabad-380015 Temple, Nehrunagar, Ambawadi, Ahmedabad- 380015 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabce9421H .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

depreciation of Rs. 13,55,778/-, interest expenses of Rs. 55,585/- and insurance of Rs. ITA No.2021/Ahd/2017 & 1939/A/17 [M/s. Edelweiss Broking Ltd. vs. DCIT] A.Y. 2013-14 - 3 - 16,875/- and made aggregated disallowance of Rs. 14,28,238/-. In appeal before the Ld. CIT(A) thereafter assessee preferred First Statutory Appeal before the Ld. CIT(A), granted relief

THE DCIT, CIRCLE-1(1), NOW CIRCLE-1(1)(1),, BARODA vs. GUJARAT STATE ELECTRICITY CORPORATION LTD.,, BARODA

In the result, the appeal filed by the Assessee in ITA No

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

73,000/- to the Book Profit under Section 115JB of the Act on account of prior period expenses is also added back to the book profit of the assessee. 16.2. Before the First Appellate Authority the assessee submitted that in assessee’s own case for A.Y. 2012-13 the Ld. CIT(A) has deleted the addition. In that view

GUJARAT STATE ELECTRICITY CORPORATION LTD.,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

In the result, the appeal filed by the Assessee in ITA No

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

73,000/- to the Book Profit under Section 115JB of the Act on account of prior period expenses is also added back to the book profit of the assessee. 16.2. Before the First Appellate Authority the assessee submitted that in assessee’s own case for A.Y. 2012-13 the Ld. CIT(A) has deleted the addition. In that view

CHIRAYU EXIM PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3),, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr आयकर अपील सं./I.T.A. No. 2819/Ahd/2016 ("नधा"रण वष" / Assessment Year : 2013-14)

depreciation or capital expenditure on scientific research, the provisions of sub-section (2) of section 72 shall apply in relation to speculation business as they apply in relation to any other business. (4) No loss shall be carried forward under this section for more than four assessment years immediately succeeding the assessment year for which the loss was first computed

MAGIC SHARE TRADERS LTD.,AHMEDABAD vs. THE ITO, WARD-2(1)(4), AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasadआयकर अपील सं./I.T.A. No. 635/Ahd/2018 ("नधा"रण वष" / Assessment Year: 2014-15) Magic Share Traders Ltd. बनाम/ Ito 101, Akashganga Building, Ward- 2(1)(4) Vs. Nr. Gujarat College Road, Ahmedabad Ellis Bridge, Ahmedabad- 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aae Cm9 542 L .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

section. 5.3 Sec. 73 deals with losses incurred by an assessee in his speculation business. Losses computed in respect of speculation business is not allowed to be set off against income other than speculation income. From the plain reading of the Explanation to sec. 73, it can be seen that the Explanation has introduced a deemed ITA No.635/Ahd/2018 [Magic Share

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 on goodwill and granting consequential relief. Accordingly, Ground Nos. 6 to 12 raised by the Revenue are dismissed. Ground No. 13 – Allocation of Common Expenses while Computing Deduction under Sections 80-IC, 80-IE & 10AA 8. This ground relates to deletion of addition made by the Assessing Officer on account of allocation of common/indirect expenses to the eligible units

ACIT ANAND CIRCLE, ANAND, ANAND vs. ELECON ENGINEERING COMPANY LTD, VALLABH VIDYANAGAR

In the result, appeal filed by the Revenue is dismissed

Bench: Us.

section 73, the allowance or the part of the allowance to which effect has not been given, as the case may be, shall be added to the amount of the allowance for depreciation

KIFS INTERNATIONAL LLP,AHMEDABAD vs. THE ACIT, CIRCLE-5(2)(1) PRESENTLY WITH ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

73,84,36,872/- as per section 32 of the Act. However, considering that KIPL was in existence only till 14 March 2016, on the basis of the provisions of sixth proviso to section 32(1)(ii) of the Act, KIPL claimed depreciation

KIFS INTERNATIONAL LLP,AHMEDABAD vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI PRESENTLY WITH ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

73,84,36,872/- as per section 32 of the Act. However, considering that KIPL was in existence only till 14 March 2016, on the basis of the provisions of sixth proviso to section 32(1)(ii) of the Act, KIPL claimed depreciation

KIFS INTERNATIONAL LLP,AHMEDABAD vs. THE ACIT, CIRCLE-5(2)(1) PRESENTLY WITH ACIT, CENTRAL CIRCLE-1(4), AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 682, 683 & 684/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2016-17 To 2018-19) Kifs International Llp Acit बनाम/ B-81, Pariseema Complex, Circle-5(2)(1), Vs. C. G. Road, Ellisbridge, Narayan Chambers Ahmedabad 380006 Building, Ashram Road, Ahmedabad [Presently With Acit, Central Circle 1(4), 3Rd Floor, Aaykar Bhavan, Ashrma Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaqfk2892L (Appellant) .. (Respondent) Shri Tushar Hemani, Sr. Advocate & Assessee By : Shri Parimalsinh B. Parmar, A.Rs. Revenue By : Shri Ritesh Parmar, Cit. Dr & Shri Rajdeep Singh, Sr.Dr (On 08.11.2023) & Shri Kamlesh Makwana, Cit.Dr (On 30.01.2024) सुनवाई क" तार"ख / Date Of 08/11/2023 & 30.01.2024 Hearing घोषणा क" तार"ख /Date Of 08/02/2024 Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Bunch Of Three Appeals Filed By The Assessee Are Directed Against The Common Order Dated 14.08.2023 Passed By Ld. Commissioner Of Income Tax (Appeals)-11, Ahmedabad (In Short ‘Cit(A)’) Arising Out Of The Orders Dated

73,84,36,872/- as per section 32 of the Act. However, considering that KIPL was in existence only till 14 March 2016, on the basis of the provisions of sixth proviso to section 32(1)(ii) of the Act, KIPL claimed depreciation

ATUL LIMITED,,AHMEDABAD vs. THE DY.CIT (OSD), RANGE-1,, AHMEDABAD

The appeal are dismissed

Bench: Us, Ld. Counsel For The Assessee Took Us Through The Chronology Of Events Leading To The Rectification Order Passed U/S. 154 Of The Act ,Which Was Carried In Appeal Before The Ld. Cit(A) Who Dismissed The Same & Against Which The Assessee Has Come Up In Appeal Before Us. Ld. Counsel For The

section 73, the allowance or the part of the allowance to which effect has not been given, as the case may be, shall be added to the amount of the allowance for depreciation

THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. N K PROTEINS PRIVATE LIMITED, AHMEDABAD

In the result, no question of law arises

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

Depreciation on Akola Plant 1,27,09,375 Excess Remuneration paid 7,64,000 Loss on F&O 4,20,57,547 Disallowance u/s 36(1)(va) 71,060 Interest Capitalization of WIP 4,88,000 Prior Period Income 1,05,89,848 Interest free advances 4,24,000 Interest free advances to Shri Nilesh Keshavlal Patel

N K PROTEINS PVT. LIMITED,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE- 3(1)(1), AHMEDABAD

In the result, no question of law arises

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

Depreciation on Akola Plant 1,27,09,375 Excess Remuneration paid 7,64,000 Loss on F&O 4,20,57,547 Disallowance u/s 36(1)(va) 71,060 Interest Capitalization of WIP 4,88,000 Prior Period Income 1,05,89,848 Interest free advances 4,24,000 Interest free advances to Shri Nilesh Keshavlal Patel