ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Disallowance u/s 14A – Rs. 8,07,84,146 as discussed Book Profit u/s. 115JB Rs. 2011,70,46,681 Tax @ 18.5% Rs. 372,16,53,636 9. Ultimately, the assessment order was passed determining the total income of the assessee at Rs.18,04,62,99,990/- under Section 143C(B) r.w.s. 144C(5) of the Act under the normal provision

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

17,72,240/- under normal provisions and book profit of Rs.724,71,13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

17,72,240/- under normal provisions and book profit of Rs.724,71,13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from

RAMCHAND BHULCHAND RAJAI,BHAVNAGAR vs. THE DY.CIT.,CIRCLE-1, , BHAVNAGAR

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 167/Ahd/2024 िनधा"रण वष"/Assessment Year : 2009-10 बनाम बनाम बनाम बनाम Ramchand Bhulchand Rajai, The Deputy Commissioner C/O. Jayesh Tyres, Vs. Of Income-Tax, Opp. Railway Station, Circle-1, Bhavnagar Bhavnagar-364001 Pan : Abmpr 4841 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) िनधा"रती की ओर से / Assessee By : Shri B.R. Popat, Ar ""थ" की ओर से / Revenue By: Shri Prateek Sharma, Sr Dr सुनवाई की तारीख /Date Of Hearing : 22/04/2024 घोषणा की तारीख /Date Of Pronouncement: 15/07/2024 आदेश/O R D E R Per Annapurna Gupta

17. We regard to the addition made by disallowing loading and unloading expenses, the contention made by the assessee before the ld. CIT(A) is as under:- “2.2.1 In so far as the penalty levied in respect of the other disallowance on account of loading and unloading expenses is concerned, suffice is to state that while this expenditure was disallowed

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

17, wherein the CIT(A) allowed the appeal of the assessee against the order and CO No.10/Ahd/2024 (By Assessee) The Asstt.CIT vs. Inductotherm (India) Pvt.Ltd. Asst. Year:2016-17 passed by Assessing Officer [hereinafter referred to as “AO”] under Section 143(3) read with Section 144C(3) of the Income Tax Act, 1961 [hereinafter referred

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

17. In the result, Ground No. 2 of the Revenue appeal is allowed. Ground No. 3:- This Ground relates to the deletion of adjustment made 18. to the Book Profit computed under Section 115JB of the Act on account of disallowance

SHITAL VIPULKUMAR DHOLAKIA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

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

section 40A(3) lay on the Revenue, and\nthe same had not been discharged. Mere suspicion, however strong, cannot\nsubstitute for evidence, and therefore, the disallowance based solely on\npresumptions deserves to be struck down.\n2.10 The AR submitted that the purchases made from the three parties,\nnamely, Shree Laxmi Gold, Shri Parvati Gold, and Dhanadeepa Gold, were\nduly supported

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

3) Under Which Order Passed Disallowance Exempt Income 13,18,58,605/- 10,43,12,707 under Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17

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

3) Under Which Order Passed Disallowance Exempt Income 13,18,58,605/- 10,43,12,707 under Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17

LOK PRAKASHAN LIMITED,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(3),, 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

3) Under Which Order Passed Disallowance Exempt Income 13,18,58,605/- 10,43,12,707 under Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17

LOK PRAKASHAN LIMITED,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(3),, 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

3) Under Which Order Passed Disallowance Exempt Income 13,18,58,605/- 10,43,12,707 under Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17

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

17. The brief facts leading to the issue is this that the Ld. AO made addition of Rs. 186,04,63,000/- to the Book Profit under Section 115JB of the Act on account of disallowance under Section 14A of the Income Tax Act. 18. Before the First Appellate Authority the assessee submitted that in assessee’s own case

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

17. The brief facts leading to the issue is this that the Ld. AO made addition of Rs. 186,04,63,000/- to the Book Profit under Section 115JB of the Act on account of disallowance under Section 14A of the Income Tax Act. 18. Before the First Appellate Authority the assessee submitted that in assessee’s own case

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)

3) of Section 14A were inserted with effect from 1st April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in terms of Rule 8D only from 24 th March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance the aggregate

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)

3) of Section 14A were inserted with effect from 1st April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in terms of Rule 8D only from 24 th March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance the aggregate

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)

3) of Section 14A were inserted with effect from 1st April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in terms of Rule 8D only from 24 th March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance the aggregate

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)

3) of Section 14A were inserted with effect from 1st April, 2007 to provide for methodology for computing of disallowance under Section 14A. However, the actual methodology was provided in terms of Rule 8D only from 24 th March 2008. There was a further amendment to Rule 8D with effect from 2nd June 2016 limiting the disallowance the aggregate

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

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

3 relates to disallowance under Section 14A read with Rule 8D amounting to Rs. 52,07,537/-. 15. During the assessment proceedings, the AO identified that the assessee had made significant investments, income from which was claimed as exempt from tax. However, the assessee did not disallow any expenses related to earning this exempt income. The assessee claimed that

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

3 relates to disallowance under Section 14A read with Rule 8D amounting to Rs. 52,07,537/-. 15. During the assessment proceedings, the AO identified that the assessee had made significant investments, income from which was claimed as exempt from tax. However, the assessee did not disallow any expenses related to earning this exempt income. The assessee claimed that