DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

In the result, the appeal of the Revenue is partly allowed

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

Section 5. However, in any such litigation suit SPIL agrees to assist SPGI, without assuming any monetary obligation. 4.3 Legal Compliance. SPIL hereby undertakes to comply with all requirements of law for obtaining various licenses, approvals, permissions and no objection certificates for meeting all legal obligations in respect of any matter ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

DCIT, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD. , BARODA

In the result, the appeal of the Revenue is partly allowed

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

Section 5. However, in any such litigation suit SPIL agrees to assist SPGI, without assuming any monetary obligation. 4.3 Legal Compliance. SPIL hereby undertakes to comply with all requirements of law for obtaining various licenses, approvals, permissions and no objection certificates for meeting all legal obligations in respect of any matter ITA No. 1462, 1463, 1519 & 1520/Ahd/2018 [Sun Pharma Laboratories

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1)(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

THE DCIT, CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

THE DCIT, CIRCLE-1(1), NOW CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

DAKSHIN GUJARAT VIJ CO. LTD.,,VADODARA vs. THE DY.CIT.,CIRCLE-1(1),, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

THE ACIT, CIRCLE-1(1)(1),, VADODARA vs. DAKSHIN GUJARAT VIJ COMPANY LTD.,, VADODARA

Bench: Smt. Annapurna Gupta& Ms. Madhumita Roy

section 43(1) of the Act, the capital grant should be reduced from the cost/WDV of the relevant asset, and thereafter the depreciation is to be calculated. Thus, the capital grant receipt in respect of asset, on which depreciation is allowable at the rate different from 15% should be worked out as per the applicable rate. The DR could

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Section 37(1) of the Act, if they are incurred "wholly and exclusively for the purposes of business or profession." Since the unit was closed and no business activity occurred, the expenses were deemed to lack a nexus with the business operations. 18. The CIT(A) noted that the Packart Press Unit was not entirely closed, as per the assessee

THE ASST. CIT.,CIRCLE-1(1),, BARODA vs. AMBALAL SARABHAI ENTERPRISES LIMITED,, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Section 37(1) of the Act, if they are incurred "wholly and exclusively for the purposes of business or profession." Since the unit was closed and no business activity occurred, the expenses were deemed to lack a nexus with the business operations. 18. The CIT(A) noted that the Packart Press Unit was not entirely closed, as per the assessee

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

In the result, the appeal is allowed for statistical purposes

Section 37(1) of the Act, if they are incurred \"wholly and\nexclusively for the purposes of business or profession.\" Since the unit was closed and\nno business activity occurred, the expenses were deemed to lack a nexus with the\nbusiness operations.\n18.\nThe CIT(A) noted that the Packart Press Unit was not entirely closed, as per\nthe assessee

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

In the result, the appeal is allowed for statistical purposes

Section 37(1) of the Act, if they are incurred \"wholly and\nexclusively for the purposes of business or profession.\" Since the unit was closed and\nno business activity occurred, the expenses were deemed to lack a nexus with the\nbusiness operations.\n18. The CIT(A) noted that the Packart Press Unit was not entirely closed, as per\nthe assessee

DCIT CENTRAL CIRCLE 1(3) ,AHMEDABAD, AAYKAR BHAVAN, ASHRAM ROAD vs. SIDDHESWARI INFRASTRUCTURE, JUDGES BUNGLOW ROAD

The appeals are dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 595 & 596/Ahd/2023 िनधा"रण वष" /Assessment Years: 2016-17 & 2017-18 Respectively The Dcit Siddheswari Infrastructure बनाम/ Circle-1(3) B-101, Shakti Enclave V/S. Ahmedabad Judges Bungalows Road Ahmedabad – 380 054 "थायी लेखा सं./Pan: Abmfs 3587 R (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : -None- Revenue By : Shri Rignesh K. Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/09/2024 घोषणा की तारीख /Date Of Pronouncement: 23/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 147 Date of Reassessment 29.09.2021 29.09.2021 Order Key Additions by AO - Rs.1,38,65,603 - Rs.2,10,62,866 (Unexplained (Unexplained transactions) transactions) ITA Nos.595 & 596/Ahd/2023 The DCIT vs. Siddheswari Infrastructure Asst. Years : 2016-17 & 2017-18 - Rs.3,85,82,434 - Rs.36,50,754 (Excess (Estimated profit @ depreciation on heavy 20% of bogus sales on machinery) Rs.23

DCIT CENTRAL CIRCLE- 1(3), AAYKAR BHAVAN vs. SIDDHESWARI INFRASTRUCTURE, JUDGES BUNGLOW ROAD

The appeals are dismissed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos. 595 & 596/Ahd/2023 िनधा"रण वष" /Assessment Years: 2016-17 & 2017-18 Respectively The Dcit Siddheswari Infrastructure बनाम/ Circle-1(3) B-101, Shakti Enclave V/S. Ahmedabad Judges Bungalows Road Ahmedabad – 380 054 "थायी लेखा सं./Pan: Abmfs 3587 R (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : -None- Revenue By : Shri Rignesh K. Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12/09/2024 घोषणा की तारीख /Date Of Pronouncement: 23/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

Section 147 Date of Reassessment 29.09.2021 29.09.2021 Order Key Additions by AO - Rs.1,38,65,603 - Rs.2,10,62,866 (Unexplained (Unexplained transactions) transactions) ITA Nos.595 & 596/Ahd/2023 The DCIT vs. Siddheswari Infrastructure Asst. Years : 2016-17 & 2017-18 - Rs.3,85,82,434 - Rs.36,50,754 (Excess (Estimated profit @ depreciation on heavy 20% of bogus sales on machinery) Rs.23

PARVINDAR INDAR SINGH,VADODARA vs. THE ACIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

928) to tax. Thus the A.O. made addition of Rs.86,26,454/- after allowing 30% towards expenditure. 3. Aggrieved against the reassessment order, assessee filed an appeal before Ld. CIT(A) which was also dismissed by Ld. CIT(A). 4. Aggrieved against the appellate order, the assessee is in appeal before us raising the following Grounds of Appeal

PARVINDAR INDAR SINGH,VADODARA vs. THE ACIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

928) to tax. Thus the A.O. made addition of Rs.86,26,454/- after allowing 30% towards expenditure. 3. Aggrieved against the reassessment order, assessee filed an appeal before Ld. CIT(A) which was also dismissed by Ld. CIT(A). 4. Aggrieved against the appellate order, the assessee is in appeal before us raising the following Grounds of Appeal

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below