ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, BHAVNAGAR, BHAVNAGAR vs. RUDRA GLOBAL INFRA PRODUCTS LIMITED, BHAVNAGAR

In the result, the appeal of the Revenue as well as the Cross-Objection filed by the assessee, both are dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

disallowance was made mainly on the ground of non-response or partial response to notices issued under section 133(6

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

disallowed 10% of the total trade payables due to inadequate documentation and ITA Nos.661/Ahd/2023 (By Assessee), 732 & 807/Ahd/2023 (By Revenue) Oriental Enterprise Pvt.Ltd. vs. ACIT Asst. Years : 2016-17 & 2018-19 failure to provide proof of the genuineness of transactions. The lack of response from third parties to section 133(6

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

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

disallowed 10% of the total trade payables due to inadequate documentation and ITA Nos.661/Ahd/2023 (By Assessee), 732 & 807/Ahd/2023 (By Revenue) Oriental Enterprise Pvt.Ltd. vs. ACIT Asst. Years : 2016-17 & 2018-19 failure to provide proof of the genuineness of transactions. The lack of response from third parties to section 133(6

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

disallowed 10% of the total trade payables due to inadequate documentation and ITA Nos.661/Ahd/2023 (By Assessee), 732 & 807/Ahd/2023 (By Revenue) Oriental Enterprise Pvt.Ltd. vs. ACIT Asst. Years : 2016-17 & 2018-19 failure to provide proof of the genuineness of transactions. The lack of response from third parties to section 133(6

AANYA DEVELOPERS,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Rifaur Rahman

section 68 of the Act. He further observed that the assessee has alleged payment of interest on these loans which were termed as bogus, therefore, the expenses claimed in the shape of interest deserves to be disallowed. He disallowed such interest expenditure and made addition of Rs.3,01,277/-. 5. Dissatisfied with the additions, the assessee carried the matter

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

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

HARSHADKUMAR HARGOVANDAS PATEL,KALOL vs. THE ITO, WARD-4, MEHSANA

In the result, the appeal of the assessee is allowed for statistical\npurposes

133(6) or summons under section 131 to\nverify the genuineness of the transactions, summarily disallowed the entire\nclaim merely

SUN PHARMACEUTICAL INDUSTRIES,MUMBAI vs. JCIT 20(3), MUMBAI

In the result appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

6) r.w.s. 80IA(10) of the Act 7. The issue raise by the Revenue vide ground Nos. I(a) and II(a) to II(d) are that the learned CIT(A) erred in holding that the assessee is eligible for deduction under section 80IE of the Act. 7.1 The assessee during the year under consideration claimed deduction

PARIKH AMITKUMAR MAHENDRABHAI,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes with the above directions

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2015-16 Parikh Amitkumar Mahendrabhai The Dcit 6, Alaknanda Society Circle 1(1)(1) Sama, Vadodara 390 008. Vadodara. Pan : Acppp 2527 G (Applicant) (Responent) Assessee By : Shri Mehul K. Pate, Advocate Revenue By : Shri Yogesh Mishra, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 07/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 09/10/2025 आदेश/O R D E R आदेश आदेश आदेश

133(6) from Arcadia Developers that no such agreement 4 existed and that Arcadia Developers had not carried out any construction on behalf of the assessee, the assessee was required to show cause why the deduction under section 54 should not be disallowed

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

6. Ground no.-2 pertains to deduction under Section 80G of the Act. During the year the assessee had contributed Rs.3,57,42,548/- to Mukhyamantri Shree Swachchta Nidhi Gujarat as part of its CSR initiative. This amount was disallowed by the assessee under Section 37 of the Act and added to the income. However, as contribution to Mukhyamantri Shree

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

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

133(6), such notice was duly served upon both the lenders. Both the lenders filed their respective reply. AO recorded that complete details as desired by him was not furnished. AO by referring the modus operandi alleged entry provider treated the loan transaction as accommodation entry and also disallowed the interest expenses. We find that before

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

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

133(6), such notice was duly served upon both the lenders. Both the lenders filed their respective reply. AO recorded that complete details as desired by him was not furnished. AO by referring the modus operandi alleged entry provider treated the loan transaction as accommodation entry and also disallowed the interest expenses. We find that before

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

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

133(6), such notice was duly served upon both the lenders. Both the lenders filed their respective reply. AO recorded that complete details as desired by him was not furnished. AO by referring the modus operandi alleged entry provider treated the loan transaction as accommodation entry and also disallowed the interest expenses. We find that before

M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,,AHMEDABAD vs. THE DCIT, (OSD) CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 1582/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2012-2013 M/S. Venus Infrastructure & D.C.I.T.,(Osd) Developers (P) Ltd., Vs. Central Circle-8, 801-802, Broadway Business Ahmedabad. Centre, Opp. Mayor’S Bungalow, Law Garden Ellisbridge, Ahmedabad. Pan: Aahcs6254J

section 133(6) of the Act and made disallowances of claim of the assessee. 27.10 In this regard we find

THE DCIT, CIRCLE-4(1)(1),, AHMEDABAD vs. SHREE SARAS SPICES & FOOD PRIVATE LTD.,, AHMEDABAD

In the result, the appeal filed by the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 478/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2012-2013 M/S. Shree Saras Spices & Foods Pvt. I.T.O., Ltd., Vs. Ward-4(1)(3), A/3, 4Th Floor, Ahmedabad. Casela Tower,, Opp. Iscon Mandir, S.G. Highway, Ahmedabad-380015

133(6) and some of the parties have submitted required detail. In the given facts and circumstances, the assessee duly discharged the primary onus cast under section 68 of the Act. It was the duty of the AO to make independent enquiries based on primary document to bring contrary materials. But the AO failed to make enquiries and bring

SHREE SARAS SPICES & FOODS P. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1)(3),, AHMEDABAD

In the result, the appeal filed by the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No. 478/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2012-2013 M/S. Shree Saras Spices & Foods Pvt. I.T.O., Ltd., Vs. Ward-4(1)(3), A/3, 4Th Floor, Ahmedabad. Casela Tower,, Opp. Iscon Mandir, S.G. Highway, Ahmedabad-380015

133(6) and some of the parties have submitted required detail. In the given facts and circumstances, the assessee duly discharged the primary onus cast under section 68 of the Act. It was the duty of the AO to make independent enquiries based on primary document to bring contrary materials. But the AO failed to make enquiries and bring