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)

section 14A cannot be applied for computing the book profit u/s. 115JB of the Act and thereby delete the addition made by the AO. Thus the Ground raised by the Revenue is devoid of merits and liable to be dismissed. 10. In the result the appeal filed by the Revenue in ITA No. 302/Ahd/2023 relating to the Asst. year

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)

section 14A cannot be applied for computing the book profit u/s. 115JB of the Act and thereby delete the addition made by the AO. Thus the Ground raised by the Revenue is devoid of merits and liable to be dismissed. 10. In the result the appeal filed by the Revenue in ITA No. 302/Ahd/2023 relating to the Asst. year

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

disallowance under Section 14A applying Rule 8D, the Appellant has not earned any exempt income during the year which is not disputed by AO. The Hon'ble Gujarat High Court in the case of Corrtech Energy Pvt. Limited 45 taxman.com 116

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

disallowance under Section 14A applying Rule 8D, the Appellant has not earned any exempt income during the year which is not disputed by AO. The Hon'ble Gujarat High Court in the case of Corrtech Energy Pvt. Limited 45 taxman.com 116

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

116. The Ld.AR further argued that the AO mistakenly referred to tax Audit Report of A.Y. 2015-16 where the disallowance u/s.14A of the Act, was worked out by the assessee and the assessee has not worked out such disallowance as it has not earned any exempt income during the year. The Ld.AR also placed reliance on the decision

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

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

116. The Ld.AR further argued that the AO mistakenly referred to tax Audit Report of A.Y. 2015-16 where the disallowance u/s.14A of the Act, was worked out by the assessee and the assessee has not worked out such disallowance as it has not earned any exempt income during the year. The Ld.AR also placed reliance on the decision

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

116. The Ld.AR further argued that the AO mistakenly referred to tax Audit Report of A.Y. 2015-16 where the disallowance u/s.14A of the Act, was worked out by the assessee and the assessee has not worked out such disallowance as it has not earned any exempt income during the year. The Ld.AR also placed reliance on the decision

VARUN SATYAPAL SINGHAL,VADODARA vs. THE INCOMETAX OFFICER, WARD-1(2)(3( NOW THE DCIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Us, At The Outset, Ld. Counsel For The Assessee Submitted That He Shall Not Be Pressing For Ground Nos. 3, 4 & 5 Of His

116 taxmann.com 870 (Delhi - Trib.), the ITAT held that where assessee had made payments to related parties, however, there was no material on record to demonstrate that payment made was excessive and unreasonable having regard to fair market rate, impugned disallowance made under section

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

Appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedasstt. Sr.No.

Section 37(1) of the Income-tax Act, 1961, read with sections 198 and 309 of the Companies Act, 1956 - Business expenditure - Allowability of - Assessment year 1979-80 - Whether when vehicles belonging to an assessee-company are used by its directors, for personal or other purposes, it would be wrong to hold that vehicles are personally used by company, because

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) VADODARA, VADODARA vs. M/S. INOX WIND ENERGY LIMITED, VADODARA

In the result, the appeal filed by the Revenue stands dismissed

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.654/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 The Deputy Commissioner M/S. Inox Wind Energy Of Income Tax, बनाम/ Limited, V/S. Circle-1(1)(1), Abs Tower S. No.1837 & Vadodara. 1834, Op Road, Vadodara-390007. (Gujarat) "थायी लेखा सं./Pan: Aafc14628K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Rignesh Das, Cit-Dr Assessee By : Shri Bandish Soparkar, Ar सुनवाई की तारीख/Date Of Hearing : 21/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income-Tax (Appeals)-11, Ahmedabad [Hereinafter Referred To As “The Cit(A)”] Dated 27.01.2025, Arising Out Of The Assessment Order Passed By The Assessing Officer Under Section 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], On 18.12.2017 For The Assessment Year 2015-16. Dcit Vs. Inox Wind Energy Limited Assessment Year 2015-16

disallowance under section 14A. The Hon’ble Gujarat High Court in CIT v. Corrtech Energy (P) Ltd. [2014] 45 taxmann.com 116

N. K. PROTEINS LTD.,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), AHMEDABAD

Bench: Or During The Course Of Hearing Of The Appeal.”

disallowance under section 14A could not be made. In the case of Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116

M/S. CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 35(2AB) of the Act in respect of Research & Development being 200% of expenditure amounting to Rs.2,19,81,593/-. The Assessing Officer made disallowance on Production Registration Expenses of Rs.14,75,75,116

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 35(2AB) of the Act in respect of Research & Development being 200% of expenditure amounting to Rs.2,19,81,593/-. The Assessing Officer made disallowance on Production Registration Expenses of Rs.14,75,75,116

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

disallowance under section 14A could not be made. In the case of Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116

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

disallowance under section 14A could not be made. In the case of Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116

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

disallowance under section 14A could not be made. In the case\nof Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116

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

disallowance under section 14A could not be made. In the case\nof Corrtech Energy (P.) Ltd. [2014] 45 taxmann.com 116

THE DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ASTRAL POLYTECHNIK LTD.,, AHMEDABAD

In the result, we do not find any merit in the appeal of Revenue

116 on identical disallowance under Section 14A when no dividend income is earned by Assessee, has held as under: “"4. Counsel