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)

132,47,53,370 /- is disallowed under u/s 32(1) r.w.s 43(1) r.ws. 43(6)(e) r.w.s 49(1)(iii)(e) r.w.s. 55(2)(a)ii) of the I.T. Act, 1961. ” 5.1. Thus the AO denied Depreciation on Goodwill as claimed by the assessee and demanded tax thereon. 6. Aggrieved against the assessment order the Assessee filed appeal before

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)

132,47,53,370 /- is disallowed under u/s 32(1) r.w.s 43(1) r.ws. 43(6)(e) r.w.s 49(1)(iii)(e) r.w.s. 55(2)(a)ii) of the I.T. Act, 1961. ” 5.1. Thus the AO denied Depreciation on Goodwill as claimed by the assessee and demanded tax thereon. 6. Aggrieved against the assessment order the Assessee filed appeal before

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

section 92CA(1) of the Act on account of determination of arm's length price of international transaction entered into by the assessee. 19. On appeal, the learned CIT(A) upheld the findings of the AO while relying upon his own decision for the AY 2003-04. 20. The assessee is now in appeal before us against the aforesaid findings

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

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for deduction under section

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

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for deduction under section

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET( DAHEJ) PORT PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 28 of the Act CIT(A) has further noted that the A. O has failed to bring any material evidence on record to support its stand that the loss suffered by the Assessee was speculative loss. We further find that in the case of CIT vs. Woodward Governor the head notes of the decision of Hon'ble Apex Court

DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET (DAHEJ) PORT PVT. LTD, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 28 of the Act CIT(A) has further noted that the A. O has failed to bring any material evidence on record to support its stand that the loss suffered by the Assessee was speculative loss. We further find that in the case of CIT vs. Woodward Governor the head notes of the decision of Hon'ble Apex Court

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET( DAHEJ) PORT PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 28 of the Act CIT(A) has further noted that the A. O has failed to bring any material evidence on record to support its stand that the loss suffered by the Assessee was speculative loss. We further find that in the case of CIT vs. Woodward Governor the head notes of the decision of Hon'ble Apex Court

ADANI PETRONET( DAHEJ) PORT PVT. LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 28 of the Act CIT(A) has further noted that the A. O has failed to bring any material evidence on record to support its stand that the loss suffered by the Assessee was speculative loss. We further find that in the case of CIT vs. Woodward Governor the head notes of the decision of Hon'ble Apex Court

THE DY.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,, AHMEDABAD

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

section 14A were attracted on account of exempt dividend income of Rs. 9,12,638/- earned by the appellant and further holding the disallowance as computer under Rule- 8D It is, therefore, prayed that the additions/disallowances upheld by the CIT(A) may kindly be deleted. A.Y. 2012-13 - Revenue’s Grounds ITA No.1186/Ahd/2016 1. The Ld. CIT(A) has erred

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

section 14A were attracted on account of exempt dividend income of Rs. 9,12,638/- earned by the appellant and further holding the disallowance as computer under Rule- 8D It is, therefore, prayed that the additions/disallowances upheld by the CIT(A) may kindly be deleted. A.Y. 2012-13 - Revenue’s Grounds ITA No.1186/Ahd/2016 1. The Ld. CIT(A) has erred

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

section 14A were attracted on account of exempt dividend income of Rs. 9,12,638/- earned by the appellant and further holding the disallowance as computer under Rule- 8D It is, therefore, prayed that the additions/disallowances upheld by the CIT(A) may kindly be deleted. A.Y. 2012-13 - Revenue’s Grounds ITA No.1186/Ahd/2016 1. The Ld. CIT(A) has erred

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,,AHMEDABAD vs. THE ASST.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD

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

section 14A were attracted on account of exempt dividend income of Rs. 9,12,638/- earned by the appellant and further holding the disallowance as computer under Rule- 8D It is, therefore, prayed that the additions/disallowances upheld by the CIT(A) may kindly be deleted. A.Y. 2012-13 - Revenue’s Grounds ITA No.1186/Ahd/2016 1. The Ld. CIT(A) has erred

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

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

section 14A were attracted on account of exempt dividend income of Rs. 9,12,638/- earned by the appellant and further holding the disallowance as computer under Rule- 8D It is, therefore, prayed that the additions/disallowances upheld by the CIT(A) may kindly be deleted. A.Y. 2012-13 - Revenue’s Grounds ITA No.1186/Ahd/2016 1. The Ld. CIT(A) has erred

SHALIGRAM INFRA PROJECTS LLP ( LTD. LIABILITY PARTNERSHIP),AHMEDABAD vs. THE JCIT (OSD), CENTRAL CIRCLE-2(2), AHMEDABAD

Appeals are partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarit(Ss)A No.167/Ahd/2021 Asstt.Year : 2017-18 & Asst.Year : 2018-19 Shaligram Infra Projects Llp Vs. The Jcit (Osd) 4Th Floor, Office No.401-402 Central Cir.2(2) B/H. Dishman House Ahmedabad. Opp: Sankalp Grace Ii, Ambli Ahmedabad. Pan: Acpfs 7047 A It(Ss)A No.194,195 & 196/Ahd/2021 Asstt.Year : 2015-16, 2016-17 & 2017-18 & Asst.Year : 2018-19 The Jcit (Osd) Vs. Shaligram Infra Projects Llp Central Cir.2(2) 4Th Floor, Office No.401-402 Ahmedabad. B/H. Dishman House Opp: Sankalp Grace Ii, Ambli Ahmedabad.

disallowance calls for no interference. Accordingly, the related grounds raised by the Revenue are dismissed. 15. Now we deal with cross appeals filed by the Revenue and assessee for the A.Y. 2017-18 and A.Y. 2018-19. 15.1 Common facts are such that a search and survey action under sections 132

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE JT. CIT, RANGE-4,, AHMEDABAD

The appeal of the asssessee is partly allowed

section 14 A. The appellant on the other hand, has submitted that no borrowed funds were used for making the investment. The appellant had huge balance in Share capital and Reserves and Surplus and therefore, no disallowance should have been made. The appellant has also claimed that in earlier years the disallowance out of interest has been directed

THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD vs. GUJARAT APOLLO INDUSTRIES LTD.,, AHMEDABAD

The appeal of the asssessee is partly allowed

section 14 A. The appellant on the other hand, has submitted that no borrowed funds were used for making the investment. The appellant had huge balance in Share capital and Reserves and Surplus and therefore, no disallowance should have been made. The appellant has also claimed that in earlier years the disallowance out of interest has been directed

THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD vs. GUJARAT APOLLO INDUSTRIES LTD.,, AHMEDABAD

The appeal of the asssessee is partly allowed

section 14 A. The appellant on the other hand, has submitted that no borrowed funds were used for making the investment. The appellant had huge balance in Share capital and Reserves and Surplus and therefore, no disallowance should have been made. The appellant has also claimed that in earlier years the disallowance out of interest has been directed