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

disallowance. The Assessing Officer would have to arrive at his determination after furnishing an opportunity to the assessee to produce its accounts and to place on the record all relevant material in support of the circumstances which are considered to be relevant and germane. For this purpose and in light of our observations made earlier in this section

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 u/s.14A of the Act, is the revenue's reliance on the Hon'ble Apex Court decision in Maxopp Investment Ltd. v. CIT(2018) 91 taxmann.com 154. An observation in paragraph 40 of the said judgment is to the effect that Section

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 u/s.14A of the Act, is the revenue's reliance on the Hon'ble Apex Court decision in Maxopp Investment Ltd. v. CIT(2018) 91 taxmann.com 154. An observation in paragraph 40 of the said judgment is to the effect that Section

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 u/s.14A of the Act, is the revenue's reliance on the Hon'ble Apex Court decision in Maxopp Investment Ltd. v. CIT(2018) 91 taxmann.com 154. An observation in paragraph 40 of the said judgment is to the effect that Section

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 u/s.14A of the Act, is the revenue's reliance on the Hon'ble Apex Court decision in Maxopp Investment Ltd. v. CIT(2018) 91 taxmann.com 154. An observation in paragraph 40 of the said judgment is to the effect that Section

PATEL INN AND TRAVELS PRIVATE LIMITED,AHMEDABAD vs. THE JT.CIT(OSD), CIRCLE-3(1)(1), NOW THE ITO WARD-3(1)(1), AHMEDABAD

In the result, the appeal preferred by the assessee is allowed

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 814/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12) िनधा"रण वष" Patel Inn & Travels The Jt.Cit(Osd) बनाम बनाम/ बनाम बनाम Circle-3(1)(1), Ahmedabad Private Limited Vs. 59, Op. Rural Police Head Quarters, B/H. S. G. Now The Ito, Ward- Highway, Makarba Road, 3(1)(1), Ahmedabad Ahmedabad, Gujarat, 380054 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcp9068M (Appellant) .. (Respondent) Ms. Urvashi Shodhan, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri J L Bhatia, Sr. Dr Date Of Hearing 25/07/2024 29/07/2024 Date Of Pronouncement O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’) Dated 22.08.2023 For The Assessment Year 2011-12. 2. The Brief Facts Of The Case Are That The Original Return Of Income For A.Y. 2011-12 Was Filed By The Assessee On 30.09.2011 Declaring Total Income Of Rs.81,08,580/-. Subsequently, The Assessee Had Filed A Revised Return On 17.02.2012 Declaring Total Income Of Rs.68,93,150/-. The Assessment Was

Section 154 of the Act on 19.03.2018 and the income was revised to Rs.1,06,55,305/-. In the rectification order, the unabsorbed brought forward depreciation of Rs.37,62,155/- for the A.Y. 2009-10 was disallowed

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. The Assessing Officer would have to arrive at his determination after furnishing an opportunity to the assessee to produce its accounts and to place on the record all relevant material in support of the circumstances which are considered to be relevant and germane. For this purpose and in light of our observations made earlier in this section

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. The Assessing Officer would have to arrive at his determination after furnishing an opportunity to the assessee to produce its accounts and to place on the record all relevant material in support of the circumstances which are considered to be relevant and germane. For this purpose and in light of our observations made earlier in this section

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

Appeal is dismissed

154, for any assessment year beginning on or before the 1st day of April, 2001.” 12. The sub-Section (2) and (3) were introduced to the main section by the Finance Act, 2006 with effect from 01.04.2007. 13. The question therefore to be answered is whether Section 14A, enables the Department to make disallowance

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 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

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 35(2AB) on gross research and development (R&D) expenditure, without reducing contract research income amounting to Rs.1,09,00,069 from the eligible R&D expenditure.” 82. A perusal of the above Grounds, it is apparent that the same is similar to the ground no.1 raised by the assessee in 2008-09. While ground no.2 is similar

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 35(2AB) on gross research and development (R&D) expenditure, without reducing contract research income amounting to Rs.1,09,00,069 from the eligible R&D expenditure.” 82. A perusal of the above Grounds, it is apparent that the same is similar to the ground no.1 raised by the assessee in 2008-09. While ground no.2 is similar

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 35(2AB) on gross research and development (R&D) expenditure, without reducing contract research income amounting to Rs.1,09,00,069 from the eligible R&D expenditure.” 82. A perusal of the above Grounds, it is apparent that the same is similar to the ground no.1 raised by the assessee in 2008-09. While ground no.2 is similar

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

section 35(2AB) on gross research and development (R&D) expenditure, without reducing contract research income amounting to Rs.1,09,00,069 from the eligible R&D expenditure.” 82. A perusal of the above Grounds, it is apparent that the same is similar to the ground no.1 raised by the assessee in 2008-09. While ground no.2 is similar

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

disallowance under Section14A as per the provisions of Rule 8D. 47.3 The Supreme Court of India in the case of Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 has also come to a conclusion that the language of Section

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

disallowance under Section14A as per the provisions of Rule 8D. 47.3 The Supreme Court of India in the case of Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 has also come to a conclusion that the language of Section

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

disallowance under Section14A as per the provisions of Rule 8D. 47.3 The Supreme Court of India in the case of Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 has also come to a conclusion that the language of Section

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

disallowance under Section14A as per the provisions of Rule 8D. 47.3 The Supreme Court of India in the case of Maxopp Investment Ltd. v. CIT [2018] 402 ITR 640/254 Taxman 325/91 taxmann.com 154 has also come to a conclusion that the language of Section