SUN PHARMACEUTICAL INDUSTRIES,MUMBAI vs. JCIT 20(3), MUMBAI

In the result appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

depreciation of plant and machinery used by Sun Pharma Industries & M/s. Sun Pharma Sikkim. III(a) On the facts and circumstances of the case and in law, the Ld. C.I.T.(A) erred in deleting, the disallowance of deduction u/s 80IE(6) r.w.s. 80IA(10) on apportionment of selling and distribution expenses of Rs.182,57,00,000/- incurred by the working

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

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

133A of the Act at the business premises on 15-10-2013 as well as a search action u/s. 132 of the Act at the residential premises of the assessee. Following the search action notice u/s.153A of the Act was issued on 26.08.2014 and the assessee filed his Return of Income for the Asst. Years

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. SHRI UMANG H. THAKKAR, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

u/s 133A of the Act at the site of Neelkanth-II, Ahmedabad. The assessee contended that the contents of the documents impounded pertained to Neelkanth-II Project which was not the project carried out by the assessee, but by one Shri Rajubhai Assessee-Shri Umang Hiralal Thakkar-Cross Appeals AY : 2005-06 Vaghela who was the proprietor of Shree Hari

SHRI UMANG HIRALAL THAKKAR,AHMEDABAD vs. THE DY.CIT.,CENT.CIRCLE-1(1),, AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA No

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 2150/Ahd/2008 िनधा"रण वष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. Dharmadev House, Income-Tax, Shyamal Cross Road, Satellite, Central Circle 1(1), Ahmedabad – 380015 Ahmedabad Pan : Aavpt 8621 R आयकर अपील सं / Ita No. 2548/Ahd/2008 िनधा"रणवष"/Assessment Year: 2005-06 बनाम Shri Umang Hiralal Thakkar, The Dy. Commissioner Of Vs. 305, Sahajanand Plaza, Bhatta Income-Tax, Ch Ar Rasta, Paldi, Ahmedabad Central Circle 1(1), Pan : Aavpt 8621 R Ahmedabad अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" यथ"/ (Respondent) अपीलाथ" अपीलाथ" "" "" यथ" यथ" िनधा"रती की ओर से / Assessee By : Shri Bandish Soparkar, Ar & Shri Parin Shah, Ar ""थ" की ओर से / Revenue By : Shri Akhilendra Pratap Yadav, Cit-Dr तारीख/Date Of Hearing : 09.05.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 30.07.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

u/s 133A of the Act at the site of Neelkanth-II, Ahmedabad. The assessee contended that the contents of the documents impounded pertained to Neelkanth-II Project which was not the project carried out by the assessee, but by one Shri Rajubhai Assessee-Shri Umang Hiralal Thakkar-Cross Appeals AY : 2005-06 Vaghela who was the proprietor of Shree Hari

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic platform

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic platform

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic platform

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic platform

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. APPLITECH SOLUTION LTD.,, AHMEDABAD

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyal

133A of the Act was carried out at the premises of the assessee on 07.03.2003. The findings of the said survey as mentioned in the assessment order for AY 2000-01 were as under:-- “1. No insurance cover was taken for the computers 2. No adequate evidences relating to the real purchase of computer hardware were produced. 3. The main

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

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

133A was conducted in the case of Parul Arogya Seva Mandal Trust and Parul University on 31/01/2017. 2. During the survey, various incrimination documents were found along with data in the form of MS Excel files and impounded which show that the trustees of Parul Group were involved in the practice of receiving back the portion of salary paid

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

133A was conducted in the case of Parul Arogya Seva Mandal Trust and Parul University on 31/01/2017. 2. During the survey, various incrimination documents were found along with data in the form of MS Excel files and impounded which show that the trustees of Parul Group were involved in the practice of receiving back the portion of salary paid