DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

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.

138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77,15,185/- as made by the AO under Section

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.

138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77,15,185/- as made by the AO under Section

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.

138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77,15,185/- as made by the AO 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-2 of Motor Vehicle Act, 1988 in order to interpret light motor vehicle. (ii) I do not fully agree with the above argument of the assessee since by a conscious decision, the word) "Commercial" has been introduced by the Notification dated 21.04.2009 by the CBDT. Apart from taking help of the Motor Vehicle Act, it is also observed that

SHRI DINESH MILLS LTD.,BARODA vs. THE ACIT, CIRCLE -2(1)(1), BARODA

In the result, the appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 14A of the Act." 12.The Tribunal's finding that the investment made by the assessee company for purchase of shares in the subsidiary company was not a legitimate business activity, was in fact, an expansion beyond what the Assessing Officer had himself envisaged. It was not even the case of the Revenue that investment made by the assessee

M. PRATAPRAY PRINTS PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-2(1)(2), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

section 14A read with Rule 8D of the Income-tax Rules, the Assessing Officer computed disallowance of expenditure at ₹20,81,138

ADANI ENTERPRISES LTD.,AHMEDABAD vs. THE ADDL. CIT,RANGE-1, AHMEDABAD

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

ADANI ENTERPRISES LTD.,,AHMEDABAD vs. THE ADDL.CIT.,RANGE-1,, AHMEDABAD

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

THE ADDL. CIT, RANGE-1,, AHMEDABAD vs. M/S. ADANI ENTERPRISES LTD.,, AHMEDABAD

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

ADANI ENTERPRISES LTD.,AHMEDABAD vs. THE ADDL. CIT,RANGE-1, AHMEDABAD

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

THE DCIT, CIRCLE-1,, AHMEDABAD vs. ADANI ENTERPRISES LTD.,, AHMEDABAD

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

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

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

disallowance U/s. 14A instead of deleting entire disallowance made by AO as appellant had a separate "Investment Division" for which separate books of account were maintained and audited, copies of such accounts were provided to entire AO and appellant had opted to suo moto disallowance the entitle expenditure of that division viz Rs. 1,56,62,600 U/s. 14A while

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, CIRCLE-1(1)(2), AHMEDABAD

Appeal are dismissed as not pressed

section 35(2AB) as the expenses were incurred outside of the approved inhouse facilities, as was held by Ms predecessors all along. While he was alive to the fact that this issue is decided in favour of the assesses by the Tribunal and Hon'ble jurisdictional High Court has not admitted appeal against the same, be was equally alive

ANUPAM INDUSTRIES LIMITED,ANAND vs. THE ACIT, ANANAD CIRCLE, ANAND

The appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

138, GIDC Estate, Vithal Anand Circle, Anand Udyognagar, Anand-388121 [PAN No.AABCA9602Q] (Appellant) .. (Respondent) Shri Mehul K. Patel, Advocate Appellant by : Respondent by: Shri Alpesh Parmar, CIT-DR Date of Hearing 29.09.2025 Date of Pronouncement 17.11.2025 O R D E R PER BENCH: These appeals have been filed by the Assessee and the Department against the order passed