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 under section 32. The AR also referred to the judgment of the Hon’ble Gujarat High Court in PCIT v. Zydus Wellness Ltd. [(2017) 87

THE DCIT, (OSD), CIRCLE-8,, AHMEDABAD vs. M/S. V. F. ARVIND BRANDS PRIVATE LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed, and the CO of the assessee is allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No.1904/Ahd/2013 & Cross Objection No. 204/Ahd/2013 (In Ita No.1904/Ahd/2013) िनधा"रण वष"/Assessment Year : 2008-09 D.C.I.T.(Osd), M/S. V. F. Arvind Brands Pvt. Circle-8, Vs. Ltd. Ahmedabad. Arvind Mills Premises, Naroda Road, Ahmedabad-380025. Pan: Aaccv 2727 L (Applicant) (Responent) / Cross Objector

section 32 of the Act. 8.11 The purpose for the depreciation on the intangible assets has been explained in the memorandum of the finance Act to 1998, and there was no such limitation provided for the allowability of the depreciation on technical know-how. Therefore we are not inclined to uphold the finding of the AO that the depreciation

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)

section 115JB, no adjustment on account of prior period expenses is required to be made to the net profits reflected in the profit and loss account of the assessee. Therefore we hold that no adjustment of prior period expenses is to be made by the assessee to arrive at the book profits I.T.A Nos. 3164 & 3124/Ahd/2015. A.Y. 2011-12 Page

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)

section 115JB, no adjustment on account of prior period expenses is required to be made to the net profits reflected in the profit and loss account of the assessee. Therefore we hold that no adjustment of prior period expenses is to be made by the assessee to arrive at the book profits I.T.A Nos. 3164 & 3124/Ahd/2015. A.Y. 2011-12 Page

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:-

87 taxmann.com 82], the CIT(A) held that goodwill qualifies as an intangible asset under Explanation 3(b) to section 32(1) and is eligible for depreciation

BAKERI PROJECTS PRIVATE LIMITED,AHMEDABAD vs. DCIT CIRCLE 1(1)(1), AHMEDABAD, AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2020-21 Bakeri Projects Pvt. Lt. The Dcit, Cir.(1)(1) 1St Floor, Sanskrut Vs. Ahmedabad. Old High Court Road Off: Ashram Road Ahmedabad. Pan : Aagcb 1864 L (Applicant) (Responent)

section 80IBA and set-off of brought forward unabsorbed depreciation. It was contended that the AO, after due examination, disallowed the depreciation of Rs.14,87

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

87,75,944/- for the year under consideration and depreciation was claimed at Rs.3,37,57,114/- which was disallowed by the Ld. AO on very many counts and further confirmed by the First Appellate Authority. Hence, the instant appeal before us. 4. According to the appellant disallowing depreciation by the Revenue authority under Section

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

87,75,944/- for the year under consideration and depreciation was claimed at Rs.3,37,57,114/- which was disallowed by the Ld. AO on very many counts and further confirmed by the First Appellate Authority. Hence, the instant appeal before us. 4. According to the appellant disallowing depreciation by the Revenue authority under Section

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

87,75,944/- for the year under consideration and depreciation was claimed at Rs.3,37,57,114/- which was disallowed by the Ld. AO on very many counts and further confirmed by the First Appellate Authority. Hence, the instant appeal before us. 4. According to the appellant disallowing depreciation by the Revenue authority under Section

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

87 Taxmann.com 82 (Guj). 3.1.9 The Assessee Company claimed depreciation under Section 32(1)(ii) on this amount at 25 percent

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

87. It is also not out of the place to mention that assets used unit No. 1 became the part of the block of assets and lost their individual identity. Accordingly, the assets deployed in unit No. 1 cannot be segregated for the purpose of the depreciation. These assets will remain part of the block of assets and therefore would

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

87. It is also not out of the place to mention that assets used unit No. 1 became the part of the block of assets and lost their individual identity. Accordingly, the assets deployed in unit No. 1 cannot be segregated for the purpose of the depreciation. These assets will remain part of the block of assets and therefore would

DIAMINES AND CHEMICALS LIMITED,,BARODA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BARODA

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

87,051/- thereby determining the total income as Rs. 12,97,62,921/-. 2.1. Ld. PCIT perused the above assessment records and found that the assessee had claimed and allowed depreciation & additional depreciation at the rate of 35% (15 + 20) on several items like Work-in-progress, Pre-Operative expenses which are not eligible for depreciation and additional depreciation which

DIAMINES & CHEMICALS LTD.,,BARODA vs. THE PR. CIT- 1, BARODA

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

87,051/- thereby determining the total income as Rs. 12,97,62,921/-. 2.1. Ld. PCIT perused the above assessment records and found that the assessee had claimed and allowed depreciation & additional depreciation at the rate of 35% (15 + 20) on several items like Work-in-progress, Pre-Operative expenses which are not eligible for depreciation and additional depreciation which

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

Appeal of the assessee is dismissed

87,279 + Rs. 1,65,040) 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

THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. KALPARATRU POWER TRANSMISSION LIMITED,, GANDHINAGAR

Appeal of the assessee is dismissed

87,279 + Rs. 1,65,040) 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

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

Appeal of the assessee is dismissed

87,279 + Rs. 1,65,040) 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

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

depreciation amounting to ₹ 87,24,730.00 against the income computed on presumption basis under section 44BB(1) of the Act in the year

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

depreciation amounting to ₹ 87,24,730.00 against the income computed on presumption basis under section 44BB(1) of the Act in the year