GMM PFAULDER LTD.,AHMEDABAD vs. THE PR.CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.839/Ahd/2025 िनधा"रण वष" /Assessment Year : 2020-21 Gmm Pfaulder Ltd. The Pr.Cit बनाम/ 3Rd Floor, B-Jadav Chambers Ahmedabad-1 V/S. Navrangpura H.O. Ahmedabad – 380 015 Ashram Road Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aabcg 0563 A (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 09/09/2025 घोषणा की तारीख /Date Of Pronouncement: 28 /10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Of Learned Principal Commissioner Of Income-Tax, Ahmedabad-1 [Hereinafter Referred To As “Ld. Pr. Cit” For Short] Dated 07/03/2025 Passed In Exercise Of His Revisionary Jurisdiction Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short] For Assessment Year (Ay) 2020- 21. 2. The Assessee Has Raised The Following Grounds Of Appeal: Gmm Pfaulder Ltd. Vs. Pcit Asst. Year : 2020-21 2

5. Before us, the learned counsel for the assessee submitted that the very foundation of the impugned revisionary order passed under section 263 of the Act is erroneous inasmuch as all the three issues—namely, depreciation on goodwill, provision for warranty, and deduction under section 80G

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-8,, AHMEDABAD

In the result appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita.No.1285 & 1286/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2009-10 & 2010-11 & Ita No.1396 & 1397/Ahd/2018 Asstt.Year 2011-12 & 2012-13 Torrent Pharmaceuticals Ltd. Acit, Circle-4(1)(2) Torrent House Ahmedabad. Vs. Off.Ashram Road Ahmedabad 380 009. आयकर अपील सं./Ita.No.1327 & 1328/Ahd/2017 िनधा"रण वष"/ Asstt. Year: 2009-10 & 2010-11 & आयकर अपील सं./Ita.No.1414 & 1415/Ahd/2018 िनधा"रण वष"/ Asstt. Year: 2011-12 & 2012-13 Acit, Circle-4(1)(2) Torrent Pharmaceuticals Ltd. Ahmedabad. Torrent House Vs. Off.Ashram Road Ahmedabad 380 009. (Applicant) (Responent) Assessee By : Shri Vartik Choksi, With Shri Biren Shah, Ars. Revenue By : Shri Mohd. Usman, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 23/11/2021 घोषणा क" तारीख /Date Of Pronouncement: 22/02/2022 आदेश/O R D E R Per Bench

section (5) of Section 80-IA. In this case, the question that arose for consideration ITA.Nos.1285/Ahd/2017 & 7 others A.Y.2009-10 38 before this Court related to computation of the profits for the purpose of deduction under section 80-E, as it then existed, after setting off the loss incurred by the assessee in the manufacture of alloy steels. Section

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 DCIT, CIRCLE-1(1),, BARODA vs. M/S. GUJARAT INDUSTRIAL POWER CO.LTD.,, BARODA

In the result, the captioned appeals are

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

depreciation @ 5% as per IT Rules as MD’s house is used mainly for residential purpose. 10. Issue No.5 relates to disallowance of contribution made to various organizations: The assessee claimed payment of Rs.2,00,000/= to SVADES, Rs.95,65,559/= to DEEP and Rs.15,36,500/= to various NGOs. The AO held there was no business obligation in respect

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

In the result, the captioned appeals are

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

depreciation @ 5% as per IT Rules as MD’s house is used mainly for residential purpose. 10. Issue No.5 relates to disallowance of contribution made to various organizations: The assessee claimed payment of Rs.2,00,000/= to SVADES, Rs.95,65,559/= to DEEP and Rs.15,36,500/= to various NGOs. The AO held there was no business obligation in respect

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

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

THE ACIT (EXMPTION) CIRCLE-1, AHMEDABAD vs. GROW MORE FOUNDATION, SABARKANTHA

In the result, appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2016-17

Section 80G(5) of the Act dated 26.05.2008. The assessee trust filed its return of income on 17.10.2016 declaring total income at Rs. Nil. During the assessment proceedings, the Assessing Officer observed that the assessee claimed depreciation

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

DCIT, CENTRAL CIRCLE1(2), AHMEDABAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case of ITA No. 839/Ahd/2019 for the A.Y. 2018-19 has denied the exemption u/s 10(23C)(vi) of the Act to Parul Arogya Seva Mandal Trust

DCIT, CENTRAL CIRCLE-1(2), AHMEDABAD, AAYAKAR BHAWAN, ASHRAM ROAD, AHMEDABAD vs. PARUL AROGYA SEVA MANDAL TRUST, , AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case of ITA No. 839/Ahd/2019 for the A.Y. 2018-19 has denied the exemption u/s 10(23C)(vi) of the Act to Parul Arogya Seva Mandal Trust

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case of ITA No. 839/Ahd/2019 for the A.Y. 2018-19 has denied the exemption u/s 10(23C)(vi) of the Act to Parul Arogya Seva Mandal Trust

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case of ITA No. 839/Ahd/2019 for the A.Y. 2018-19 has denied the exemption u/s 10(23C)(vi) of the Act to Parul Arogya Seva Mandal Trust

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

80G(5) of the act vide approval No. CITE/Ahd/80G(5)/781/PU/2016-17. 2.2. It is also pertinent to note that the co-ordinate bench of ITAT vide its order dated 26-7-2023 in case of ITA No. 839/Ahd/2019 for the A.Y. 2018-19 has denied the exemption u/s 10(23C)(vi) of the Act to Parul Arogya Seva Mandal Trust

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

80G of the Act, and erred in directing the AO to disallow the same. GSP Crop Science Ltd. vs. PCIT Asst.Year –2020-21 - 2– (5) That the learned PCIT has grievously erred in law, and on facts, in directing the AO to verify the claim of set off of brought forward unabsorbed depreciation, without finding any error in appellant

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5 others A.Y.2013-14 43 account of benchmarking of loan to AE. Thus, the ground of the appeal filed by the assessee is hereby allowed. Capital Infusion. 55. The TPO found that the assessee during the year has made payment of share application money to the following AEs: S. Name of AE Amount in Rs. Date of Date of share