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

10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section 14A r.w.s. Rule 8D 8,70,747 5 Disallowance of Weighted Deduction under 65,09,81,251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section 36(1

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), 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

10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section 14A r.w.s. Rule 8D 8,70,747 5 Disallowance of Weighted Deduction under 65,09,81,251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section 36(1

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), VADODARA, VADODARA vs. ORIENTAL ENTERPRISES PRIVATE LIMITED, PCC NOTIFIED AREA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

10,487=Rs.21,80,985/−. • Administrative/Other Expenses Disallowance: o The AO computed this as 0.5% of the average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section

ORIENTAL ENTERPRISE PRIVATE LIMITED,VADODARA vs. THE ACIT, CIRCLE-2(1)(2), VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

10,487=Rs.21,80,985/−. • Administrative/Other Expenses Disallowance: o The AO computed this as 0.5% of the average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 2(1)(1), VADODARA, VADODARA vs. ORIENTAL ENTERPRISES PRIVATE LIMITED,, PCC NOTIFIED AREA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

10,487=Rs.21,80,985/−. • Administrative/Other Expenses Disallowance: o The AO computed this as 0.5% of the average value of investments generating exempt income: o Disallowance: (B) * 0.5% = 0.5%×1,29,22,8268=Rs.30,26,552/− Total Disallowance under Section

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

disallowance under section 14A to the book profit computed under section 115JB, we find such adjustment to be legally untenable. Clause (f) of Explanation 1 to section 115JB(2) provides for addition of the amount of expenditure relatable to any income to which section 10

JAI PRAKASH CHOUDHARY,VADODARA vs. THE ADIT CPC, BENGLURU

In the result, the appeal filed by the Assessee is hereby dismissed

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

disallowance, which is well within the provisions of law. 8.1. Further the Co-ordinate Bench of the Delhi Tribunal in the case of Savleen Kaur vs. ITO in ITA No. 2249/DEL/2022 dated 09- 01-2023 considered the Checkmate Services (P.) Ltd. Supreme Court Judgment and the provisions of Section 143(1)(a) held as follows: “…. 12. A perusal

JAIPRAKASH CHOUDHARY,VADODARA vs. THE DCIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal filed by the Assessee is hereby dismissed

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

disallowance, which is well within the provisions of law. 8.1. Further the Co-ordinate Bench of the Delhi Tribunal in the case of Savleen Kaur vs. ITO in ITA No. 2249/DEL/2022 dated 09- 01-2023 considered the Checkmate Services (P.) Ltd. Supreme Court Judgment and the provisions of Section 143(1)(a) held as follows: “…. 12. A perusal

JAI PRAKASH CHOUDHARY,VADODARA vs. THE ADIT CPC, BENGLURU

In the result, the appeal filed by the Assessee is hereby dismissed

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

disallowance, which is well within the provisions of law. 8.1. Further the Co-ordinate Bench of the Delhi Tribunal in the case of Savleen Kaur vs. ITO in ITA No. 2249/DEL/2022 dated 09- 01-2023 considered the Checkmate Services (P.) Ltd. Supreme Court Judgment and the provisions of Section 143(1)(a) held as follows: “…. 12. A perusal

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

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

disallowance made by the Assessing Officer towards export commission paid by the assessee to the non-resident was rightly deleted.' 16. When the transaction does not atract the provisions of Section 9 of the Act, then there is no question of applying Explanation 4 to Section 9 of the Act. Therefore, the Revenue has no case and the Tax Case

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

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

disallowance made by the Assessing Officer towards export commission paid by the assessee to the non-resident was rightly deleted.' 16. When the transaction does not atract the provisions of Section 9 of the Act, then there is no question of applying Explanation 4 to Section 9 of the Act. Therefore, the Revenue has no case and the Tax Case

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under Section 14A was required to be made? Learned counsel for the respondents assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2) clause (f). The Assessing Officer

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under Section 14A was required to be made? Learned counsel for the respondents assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2) clause (f). The Assessing Officer

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under Section 14A was required to be made? Learned counsel for the respondents assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2) clause (f). The Assessing Officer

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under Section 14A was required to be made? Learned counsel for the respondents assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2) clause (f). The Assessing Officer

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

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

10 expenses 621,578,070 11 Disallowances of deduction u/s 10B 504 12 Disallowances of repair expenses 1,017,500 13 Disallowances of leave encashment 3,998,673 14 Disallowances under section

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

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

10 expenses 621,578,070 11 Disallowances of deduction u/s 10B 504 12 Disallowances of repair expenses 1,017,500 13 Disallowances of leave encashment 3,998,673 14 Disallowances under section

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

section 37(1) of the Act, particularly when the genuineness of\nexpenditure was in doubt. It was held that the possibility of a personal or\nnon-business element in such expenditure could not be ruled out.\nConsequently, 10% of the aggregate amount of site and site development\nexpenses, i.e., Rs. 13,47,839/-, was disallowed