SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

13,971/- was disallowed under Section 58(2) r.w.s. 40A(2) of the Act. Accordingly, the disallowance as made by the AO was restricted

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

13,971/- was disallowed under Section 58(2) r.w.s. 40A(2) of the Act. Accordingly, the disallowance as made by the AO was restricted

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

13,280/made by the AO u/s 40A(2)(b) of the Act. We are in complete agreement with the view taken by the learned Tribunal. Under the circumstances, question no. 2(a) is answered against the revenue.” 6. Thus, from the above it is clear that disallowance under Section

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

disallowed exemptions under Sections 11 and 12, treating the income as normal business income due to violations of the trust's objectives. The Ld.CIT(A) partially upheld the AO's additions but allowed the exemptions under Sections 11 and 12, concluding there was no apparent violation of Section 13 of the Act. 7.1. We have also noted that the survey

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

disallowed exemptions under Sections 11 and 12, treating the income as normal business income due to violations of the trust's objectives. The Ld.CIT(A) partially upheld the AO's additions but allowed the exemptions under Sections 11 and 12, concluding there was no apparent violation of Section 13 of the Act. 7.1. We have also noted that the survey

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

disallowed exemptions under Sections 11 and 12, treating the income as normal business income due to violations of the trust's objectives. The Ld.CIT(A) partially upheld the AO's additions but allowed the exemptions under Sections 11 and 12, concluding there was no apparent violation of Section 13 of the Act. 7.1. We have also noted that the survey

PARUL UNIVERSITY,VADODARA vs. THE DY.CIT,EXEMPTION CIRCLE-1, AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

disallowed exemptions under Sections 11 and 12, treating the income as normal business income due to violations of the trust's objectives. The Ld.CIT(A) partially upheld the AO's additions but allowed the exemptions under Sections 11 and 12, concluding there was no apparent violation of Section 13 of the Act. 7.1. We have also noted that the survey

PARUL AROGYA SEVA MANDAL TRUST,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(2), AHMEDABAD

Appeals are allowed

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member

disallowed exemptions under Sections 11 and 12, treating the income as normal business income due to violations of the trust's objectives. The Ld.CIT(A) partially upheld the AO's additions but allowed the exemptions under Sections 11 and 12, concluding there was no apparent violation of Section 13 of the Act. 7.1. We have also noted that the survey

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

13), determining total income at Rs.178,23,60,063/- as against the returned income of Rs.168,29,62,390/-, after making the following additions: i. disallowance of Rs.8,26,43,616/- under section 14A read with Rule 8D(2

JCIT(OSD), CIR-3(1)(2), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE (INDIA) LTD, HARYANA

In the result, appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

2 of the assessee’s appeal are dismissed. 6. Ground No. 3: Disallowance under section 14A of the Act. 6.1 The brief facts relating to this issue are that the assessee has investment of Rs.47,93,23,273/- at the beginning of the year and Rs. 48,17,13

RECKITT BENCKISER HEALTHCARE INDIA PVT. LTD., ( FORMERLY KNOWN AS RECKITT BENCKISER HEALTHCARE INDIA LTD.,),HARYANA vs. DCIT, CIRCLE-3(1)(2), AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

2 of the assessee’s appeal are dismissed. 6. Ground No. 3: Disallowance under section 14A of the Act. 6.1 The brief facts relating to this issue are that the assessee has investment of Rs.47,93,23,273/- at the beginning of the year and Rs. 48,17,13

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

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

Bench: Ms.Annapurna Gupta & T.R. Senthil Kumarasstt.Year : 2014-15 The Dcit, Cir.2(1)(1) Gujarat Apollo Industries Ltd. Ahmedabad. ‘Apollo House’ Rashmi Society Nr.Mithakhali Six Roads Navrangpura Ahmedabad 380 009. Pan : Aaacg 7248 P

2)(iii) of the IT Rule. We order so. 14. So far as second issue i.e. whether amount of disallowance under section 14A is to be added to the income computed as per Section 115JB for MAT purpose or not, is covered in favour of the assessee by the decision of Special Bench in the case of ACIT Vs. Vireet

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

13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary

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

13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary

BARODA DISTRICT COOPERATIVE MILK PRODUCERS UNION LIMITED,VADODARA, GUJARAT vs. ASST. COMMISSIONER OF INCOME TAX OFFICER, CIRCLE 1(1)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeals of the assessee for Asst

2)(iv) of the Act, in accordance with the directions by the\nITAT in the case of assessee in A.Y 12-13 & 13-14.\nterms.\nGround No.2 raised by the assessee is partly allowed in above\n21. Ground No.3 relates to disallowance of expenses by invoking the\nprovisions of section

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

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(EXEMPTION)CIRCL-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