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)

disallowance under Section 14A in absence of any exempt income during an assessment year. Section 14A of the Act provides that no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income that does not form part of the total income as per the provisions of the Act (exempt income). 2

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)

disallowance under Section 14A in absence of any exempt income during an assessment year. Section 14A of the Act provides that no deduction shall be allowed in respect of expenditure incurred by the assessee in relation to income that does not form part of the total income as per the provisions of the Act (exempt income). 2

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

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowable under section 14A is covered under clause (f) of Explanation 1 to section 115JB(2) and it is required

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

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

disallowance under Section 14A was required to be made? Learned counsel for the respondents-assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2

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

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Smt. Annapurna Gupta & Ms. Madhumita Roy

disallowance under Section 14A was required to be made? Learned counsel for the respondents-assessee, during the course of hearing, has fairly conceded that the first question has to be answered in favour of the Revenue and against the assessee in view of specific provisions in the Explanation 1 below Section 115JB(2

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

disallowance under section 14A to the book profit computed under section 115JB, we find such adjustment to be legally untenable. Clause (f) of Explanation 1 to section 115JB(2

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

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

2)(iii) of I.T. Rules. 6. The Assessing Officer (AO) made an addition to the assessee’s book profit under Section 115JB of the Act based on the disallowance under Section 14A

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR vs. AXIS BANK LIMITED, ELLISBRIDGE

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowing the administrative expense under Section 14A r.w. Rule 8D(2)(iii) over and above the suo-moto disallowance of administrative

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT., CIRCLE-1(1)(1),, AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowing the administrative expense under Section 14A r.w. Rule 8D(2)(iii) over and above the suo-moto disallowance of administrative

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR vs. AXIS BANK LTD, ELISBRIDGE

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowing the administrative expense under Section 14A r.w. Rule 8D(2)(iii) over and above the suo-moto disallowance of administrative

AXIS BANK LIMITED,AHMEDABAD vs. THE ACIT., CIRCLE-1(1)(1),, AHMEDABAD

In the result, the appeal of the Department is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowing the administrative expense under Section 14A r.w. Rule 8D(2)(iii) over and above the suo-moto disallowance of administrative

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(22) of the Act, quantum of dividend which is paid by way of specie distribution of assets needs to be considered as market value on the date of distribution and not average book value of shares of resulting company. Ground No. 3: Disallowance under section 14A

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(22) of the Act, quantum of dividend which is paid by way of specie distribution of assets needs to be considered as market value on the date of distribution and not average book value of shares of resulting company. Ground No. 3: Disallowance under section 14A

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

disallowance under Section 14A was deleted entirely, following ITAT precedent.", "result": "Partly Allowed", "sections": [ "80P(2)(d)", "80P(2)(a)(iv)", "14A

URMIN PRODUCTS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(3), AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

disallowance made by the assessee under section 14A of the Act. We may reproduce the relevant observations of the Supreme Court in this regard thus: "Having regard to the language of section 14A(2

URMIN PRODUCTS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(3), AHMEDABAD

In the result, the appeal filed by the assessee bearing ITA

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

disallowance made by the assessee under section 14A of the Act. We may reproduce the relevant observations of the Supreme Court in this regard thus: "Having regard to the language of section 14A(2

N. K. PROTEINS LTD.,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), AHMEDABAD

Bench: Or During The Course Of Hearing Of The Appeal.”

disallowances made under section 14A read with rule 8D could not be applied to provision of section 115JB of the Act. The Delhi ITAT in the case of Vireet Investment (P.) Ltd [2017] 82 taxmann.com 415 (Delhi - Trib.) (SB) held that computation under clause (f) of Explanation 1 to section 115JB(2

DCIT, CENTRAL CIRCLE - 1(3), AHMEDABAD vs. M/S LOK PRAKASHAN LTD., AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

2,63,92,67,830/- N/A Return Date of AO’s Assessment 27.12.2019 23.09.2021 Order Order Date Section Section 143(3) Section 143(3) Under Which Order Passed Disallowance Exempt Income 13,18,58,605/- 10,43,12,707 under Section Earned in Rs. 14A