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, read with rule 8D of the Income-tax Rules, 1962.” 9.4. Further jurisdictional High Court in the case of PCIT -Vs.- Gujarat Fluro Chemicals Ltd [2023] 155 taxmann.com 135 [Guj] had considered the entire issue in detail and judgements rendered by different High Courts, Special Bench of ITAT and held as follows: 14 I.T.A No. 198 & 199/Ahd/2023

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, read with rule 8D of the Income-tax Rules, 1962.” 9.4. Further jurisdictional High Court in the case of PCIT -Vs.- Gujarat Fluro Chemicals Ltd [2023] 155 taxmann.com 135 [Guj] had considered the entire issue in detail and judgements rendered by different High Courts, Special Bench of ITAT and held as follows: 14 I.T.A No. 198 & 199/Ahd/2023

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

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

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

135/-. The assessee preferred an appeal before Ld.CIT(A), who partly allowed the appeal of the assessee. The summary of additions and decision of the Ld.CIT(A) is tabulated as follows: Sr Particulars of Amount of Relief granted by Who is in disallowance / addition/ CIT(A) appeal addition by disallowance by before us AO AO against CIT(A)’s 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

135/-. The assessee preferred an appeal before Ld.CIT(A), who partly allowed the appeal of the assessee. The summary of additions and decision of the Ld.CIT(A) is tabulated as follows: Sr Particulars of Amount of Relief granted by Who is in disallowance / addition/ CIT(A) appeal addition by disallowance by before us AO AO against CIT(A)’s 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

135/-. The assessee preferred an appeal before Ld.CIT(A), who partly allowed the appeal of the assessee. The summary of additions and decision of the Ld.CIT(A) is tabulated as follows: Sr Particulars of Amount of Relief granted by Who is in disallowance / addition/ CIT(A) appeal addition by disallowance by before us AO AO against CIT(A)’s decision

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

TML INDUSTRIES LTD.,VADODARA vs. THE INCOME TAX OFFICER, WARD-2(1)(4), NOW THE DCIT, CIRCLE-2(1)(1), VADODARA

In the result, appeal of the assessee is partly allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2014-15

disallowance is called for under Section 14A of the Act read with Rule 8D of the Income Tax Rules. 7. In response, the Ld. DR placed reliance on the observations made by the Assessing Officer and the Ld. CIT(A) in their respective orders. 8. We have heard the rival contentions and perused the material on record. We observe that

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

disallowed by the assessee under Section 37 of the Act. However, as the contribution to Mukhyamantri Shree Swachchta Nidhi Gujarat for sanitation work was eligible for deduction under Section 80G of the Act, the assessee had rightly claimed the deduction. The Ld. AR has drawn our attention to the provisions of Section 80G(2)(a)(iiihk) and (iiihl

DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ADANI PORT & SPECIAL ECONOMIC ZONE LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

disallowance of Rs.19,79,54,135/- made by the Assessing Officer while computing Profits and Gains eligible for deduction u/s.80-IAB of the I.T. Act, thereby holding that Interest Income derived by the appellant from business advances cannot be considered to be inextricably linked to the carrying on of the business eligible u/s.80-IAB of the I.T. Act. This resulted into confirmation

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ADANI PORT & SPECIAL ECONOMIC ZONE LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

disallowance of Rs.19,79,54,135/- made by the Assessing Officer while computing Profits and Gains eligible for deduction u/s.80-IAB of the I.T. Act, thereby holding that Interest Income derived by the appellant from business advances cannot be considered to be inextricably linked to the carrying on of the business eligible u/s.80-IAB of the I.T. Act. This resulted into confirmation

THE JT.CIT, (OSD)CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LTD., VADODARA

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

135/-. The assessee shown book profit u/s. 115JB of Rs.165,54,21,963/-. The return was taken up for scrutiny assessment and various disallowances made by the Assessing Officer namely: (i) Disallowance u/s. 14A of Rs. 154,61,81,000/- (ii) Interest capitalization of CWIP of Rs.6,97,664/- I.T.A Nos. 166/Ahd/22 & 231/Ahd/24 and Ors. A.Ys

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

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

135/-. The assessee shown book profit u/s. 115JB of Rs.165,54,21,963/-. The return was taken up for scrutiny assessment and various disallowances made by the Assessing Officer namely: (i) Disallowance u/s. 14A of Rs. 154,61,81,000/- (ii) Interest capitalization of CWIP of Rs.6,97,664/- I.T.A Nos. 166/Ahd/22 & 231/Ahd/24 and Ors. A.Ys

GUJARAT URJA VIKAS NIGAM LTD.,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

135/-. The assessee shown book profit u/s. 115JB of Rs.165,54,21,963/-. The return was taken up for scrutiny assessment and various disallowances made by the Assessing Officer namely: (i) Disallowance u/s. 14A of Rs. 154,61,81,000/- (ii) Interest capitalization of CWIP of Rs.6,97,664/- I.T.A Nos. 166/Ahd/22 & 231/Ahd/24 and Ors. A.Ys

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, VADODARA

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Ramit Kochar (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

135/-. The assessee shown book profit u/s. 115JB of Rs.165,54,21,963/-. The return was taken up for scrutiny assessment and various disallowances made by the Assessing Officer namely: (i) Disallowance u/s. 14A of Rs. 154,61,81,000/- (ii) Interest capitalization of CWIP of Rs.6,97,664/- I.T.A Nos. 166/Ahd/22 & 231/Ahd/24 and Ors. A.Ys

SEQUEL LOGISTICS PRIVATE LIMITED,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowance of CSR expenditure referred to in section 135 of the Companies Act, that such expenditure is application of income

TORRENT POWER GRID LIMITED,AHMEDABAD vs. THE PR.CIT-3, AHMEDABAD

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

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

disallowance of CSR expenditure referred to in section 135 of the Companies Act, that such expenditure is application of income