VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption u/s. 11 & 12 of the Act and the assessed the income of the assessee at Rs.40,51,98,900/- by making the following disallowances: (a) Revenue Expenditure Rs. 3,85,16,135/ (b) VUDA

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption u/s. 11 & 12 of the Act and the assessed the income of the assessee at Rs.40,51,98,900/- by making the following disallowances: (a) Revenue Expenditure Rs. 3,85,16,135/ (b) VUDA

JT.CIT(E), CIRCLE-2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption u/s. 11 & 12 of the Act and the assessed the income of the assessee at Rs.40,51,98,900/- by making the following disallowances: (a) Revenue Expenditure Rs. 3,85,16,135/ (b) VUDA

JT.CIT(E),CIRCLE -2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption u/s. 11 & 12 of the Act and the assessed the income of the assessee at Rs.40,51,98,900/- by making the following disallowances: (a) Revenue Expenditure Rs. 3,85,16,135/ (b) VUDA

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption u/s. 11 & 12 of the Act and the assessed the income of the assessee at Rs.40,51,98,900/- by making the following disallowances: (a) Revenue Expenditure Rs. 3,85,16,135/ (b) VUDA

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

disallow Rs.26,25,000/- under Section 36(1)(iii) of the Act. 13. Before us, the Ld.AR stated that the Ld.CIT(A) relied on the decision of Hon’ble Rajasthan High Court in case of Indian Savings Products Ltd. (265 ITR 250), where it was not a question of law and in fact the assessee company has interest free funds

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

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

disallow Rs.26,25,000/- under Section 36(1)(iii) of the Act. 13. Before us, the Ld.AR stated that the Ld.CIT(A) relied on the decision of Hon’ble Rajasthan High Court in case of Indian Savings Products Ltd. (265 ITR 250), where it was not a question of law and in fact the assessee company has interest free funds

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

disallow Rs.26,25,000/- under Section 36(1)(iii) of the Act. 13. Before us, the Ld.AR stated that the Ld.CIT(A) relied on the decision of Hon’ble Rajasthan High Court in case of Indian Savings Products Ltd. (265 ITR 250), where it was not a question of law and in fact the assessee company has interest free funds

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

10 (other than provisions contained in clause 38 thereof) or section 11 or section 12 apply. In this regard, we draw support from the coordinate bench’s decision in assessee’s own case for A.Y. 2010–11, where in paragraphs 46 to 51, the Bench categorically noted that the provisions of section 115JB are self-contained and that disallowance made

GUJARAT STATE FINANCIAL SERVICES LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed in part

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Section 80G of the Act in respect of donation made to Mukhyamantri Shree Swachchta Nidhi Gujarat, as donation to this fund in respect of CSR activities was not specifically debarred under the provisions of the Act. Accordingly, the ground taken by the assessee is allowed. Disallowance u/s 14A 10. The next ground pertains to disallowance of Rs.14,31

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

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

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

10. Ground Nos. 2, 3 & 4 of the assessee’s appeal are general in nature and does not require any specific adjudication. ITA No. 414/Ahd/2020 for A.Y. 2016-17 11. The Revenue has raised the following grounds of appeal:- “(a)(i) Whether on the facts and in circumstances of the case, the learned CIT(A) has erred

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 of the Revenue’s appeal are dismissed. Ground No. 6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee

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 of the Revenue’s appeal are dismissed. Ground No. 6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee

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 squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

RAI UNIVERSITY,AHMEDABAD vs. ACIT,(E) CIRCLE-1, AHMEDABAD

In the result, the appeal of the Revenue is dismissed; whereas the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Years : 2014-15 Rai University, Asst. Commissioner Of 398-400-401-403, Vs Income-Tax (E), Village : Saroda, Taluka : Dholka, Circle-1, Ahmedabad – 382260 Ahmedabad Pan : Aabar 4376 A Assessment Years : 2014-15 Asst. Commissioner Of Rai University, Income-Tax (E), Vs Village : Saroda, Circle-1, Taluka : Dholka, Ahmedabad Ahmedabad – 382260 Pan : Aabar 4376 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Smt. Arti Shah, Ar Revenue By : Shri C.S. Sharma, Sr. Dr & Shri Anshu Prakas, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 14/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 22/02/2022 आदेश / O R D E R Per P.M. Jagtap, Vice-: These Two Appeals, One Filed By The Assessee Being Ita No.386/Ahd/2019 & Other Filed By The Revenue Being

31. Babita Pandita Gold Corporate Ms. K Venkata MahaShani 1 7,861 /- Card No. Travelling from Delhi- 3769-453730- Hydrabad-Delhi 82009 32. Babita Pandita Gold Corporate Ms. Sankara Reddy Travelling to 19,733/- Card No. 3769- Delhi to Hyradabad and 453730-82009 Hydrabad to Delhi 21,39,354/- 5. As noted by the learned Assessing Officer, all the events

THE ACIT,(E) CIRCLE-1, AHMEDABAD vs. RAI UNIVERSITY, AHMEDABAD

In the result, the appeal of the Revenue is dismissed; whereas the appeal of the assessee is treated as allowed for statistical purposes

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Years : 2014-15 Rai University, Asst. Commissioner Of 398-400-401-403, Vs Income-Tax (E), Village : Saroda, Taluka : Dholka, Circle-1, Ahmedabad – 382260 Ahmedabad Pan : Aabar 4376 A Assessment Years : 2014-15 Asst. Commissioner Of Rai University, Income-Tax (E), Vs Village : Saroda, Circle-1, Taluka : Dholka, Ahmedabad Ahmedabad – 382260 Pan : Aabar 4376 A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Smt. Arti Shah, Ar Revenue By : Shri C.S. Sharma, Sr. Dr & Shri Anshu Prakas, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 14/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 22/02/2022 आदेश / O R D E R Per P.M. Jagtap, Vice-: These Two Appeals, One Filed By The Assessee Being Ita No.386/Ahd/2019 & Other Filed By The Revenue Being

31. Babita Pandita Gold Corporate Ms. K Venkata MahaShani 1 7,861 /- Card No. Travelling from Delhi- 3769-453730- Hydrabad-Delhi 82009 32. Babita Pandita Gold Corporate Ms. Sankara Reddy Travelling to 19,733/- Card No. 3769- Delhi to Hyradabad and 453730-82009 Hydrabad to Delhi 21,39,354/- 5. As noted by the learned Assessing Officer, all the events