TTEC INDIA CUSTOMER SOLUTIONS PVT. LTD.,AHMEDABAD vs. THE PR.CIT-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21 Ttec India Customer Solutions Pr.Commissioner Of Private Limited, Ttec Ahmedabad Vs. Income Tax-3 Opp: L.J.College Vejalpur Off: Sg Road, Makarba Ahmedabad. Fatewadi Bo, Fatewadi Ahmedabad. Pan : Aaccm 1005A (Applicant) (Responent) : Shri Vishal Kabra, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 04/07/2025 आदेश आदेश/O R D E R आदेश आदेश

80G for donations forming part of CSR expenditure. 11. The learned PCIT, while invoking section 263, alleged that the Assessing Officer failed to verify whether the foreign tax credit (FTC) of Rs.8,02,50,535/- claimed by the assessee was allowable under section 90 read with Article 24 of the India–Philippines DTAA. It was further alleged that

GSP CROP SCIENCE LIMITED,AHMEDABAD vs. THE PR.CIT-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

depreciation claim of Rs. 1,80,783/-, which the Pr. CIT held as irregular and prejudicial to the interest of the Revenue. Accordingly, this issue was also set aside to the A.O. for recomputation as per law. Third, the assessee had claimed deduction under section 80G

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

80G of Rs. 9,92,000/- and deduction u/s. 80IA of Rs. 6,26,51,076/-, the total eligible deduction thus amounting to Rs. 6,36,43,076/- which was restricted to the extent of gross total income, resulting in Nil income assessed. Computation of the assessed income at Para 10 of the order was pointed

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

80G and 80GGB of the Act for the donations made by the undertaking eligible for deduction under section 80-IA of the Act. The deduction under section 80-IA of the Act is allowed to the assessee with respect to the business referred therein is carried on by the assessee. That particular business is known as the undertaking which

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

80G and 80GGB of the Act for the donations made by the undertaking eligible for deduction under section 80-IA of the Act. The deduction under section 80-IA of the Act is allowed to the assessee with respect to the business referred therein is carried on by the assessee. That particular business is known as the undertaking which

THE ACIT, CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

depreciation. Thus, this ground of revenue is dismissed.” As the facts are identical to the facts of the case as discussed above, therefore respectfully following the same, we do not find a reason to interfere in the order of the ld. CIT-A. Hence, the ground of appeal raised by Revenue is dismissed. The fourth issue raised by the Revenue

THE TORRENT PHARMACEUTICALS,AHMEDABAD vs. THE ADDITIONAL CIT, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

depreciation. Thus, this ground of revenue is dismissed.” As the facts are identical to the facts of the case as discussed above, therefore respectfully following the same, we do not find a reason to interfere in the order of the ld. CIT-A. Hence, the ground of appeal raised by Revenue is dismissed. The fourth issue raised by the Revenue

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

depreciation. Thus, this ground of revenue is dismissed.” As the facts are identical to the facts of the case as discussed above, therefore respectfully following the same, we do not find a reason to interfere in the order of the ld. CIT-A. Hence, the ground of appeal raised by Revenue is dismissed. The fourth issue raised by the Revenue

THE TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

depreciation. Thus, this ground of revenue is dismissed.” As the facts are identical to the facts of the case as discussed above, therefore respectfully following the same, we do not find a reason to interfere in the order of the ld. CIT-A. Hence, the ground of appeal raised by Revenue is dismissed. The fourth issue raised by the Revenue

THE ITO, (EXEMPTIONS), WARD-2,, AHMEDABAD vs. PLATINUM FOUNDATION,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.2885/Ahd/2016 "नधा"रण वष"/Asstt. Year: 2013-14

depreciation. 3. Brief facts of the case are that assessee is a trust running educational institutions and imparting engineering and management courses. Trust has registered under section 12AA and also granted ITA No.2885 /Ahd/2016 2 certificate under section 80G

BHANDARI CHARITABLE TRUST,,AHMEDABAD vs. THE DIT(EXEMP.), AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2935 /Ahd/2014 & Asstt.Year : 2014-15 Bhandari Charitable Trust Dit(Exemption) A-1, Sky Lark Apartments Vs Ahmedabad. Satellite Road, Satellite Ahmedabad 380 015. Pan : Aaatb 3672 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Prakash D. Shah, Ar & Shri S.N.Devatia, Ar Revenue By : Shri Vinod Tanwani, Cit-Dr

80G(5) of the Act, then the AO has observed that such registration was granted after looking into the objects of the trust. The AO observed that the assessee failed to submit any evidence showing that it is actually imparting education by conducting classes. The ld.AO failed to note that the stand of the assessee was always to the effect

BHANDARI CHARITABLE TRUST,,AHMEDABAD vs. THE ITO (EXEMPTIONS), WARD-1,, AHMEDABAD

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2935 /Ahd/2014 & Asstt.Year : 2014-15 Bhandari Charitable Trust Dit(Exemption) A-1, Sky Lark Apartments Vs Ahmedabad. Satellite Road, Satellite Ahmedabad 380 015. Pan : Aaatb 3672 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Prakash D. Shah, Ar & Shri S.N.Devatia, Ar Revenue By : Shri Vinod Tanwani, Cit-Dr

80G(5) of the Act, then the AO has observed that such registration was granted after looking into the objects of the trust. The AO observed that the assessee failed to submit any evidence showing that it is actually imparting education by conducting classes. The ld.AO failed to note that the stand of the assessee was always to the effect

BHANDARI CHARITABLE TRUST,,AHMEDABAD vs. THE ITO (EXEMPTIONS), WARD-1,, AHMEDABAD

In the result, the appeal preferred by the assessee is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

80G(5) of the Act, then the AO has observed that such registration was granted after looking into the objects of the trust. The AO observed that the assessee failed to submit any evidence showing that it is actually imparting education by conducting classes. The ld.AO failed to note that the stand of the assessee was always to the effect

SABARMATI GAS LIMITED,GANDHINAGAR vs. PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2020-21

depreciation of Rs. 2,08,08,398/-. Thus, the invocation of the provisions of section 263 of the Act by Pr. CIT is merely a change of opinion and is beyond the scope of provisions of section 263 of the Act. The ld. A.R. further submitted that the verification in respect of CSR expenses claimed u/s. 80G

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income