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

22)(a) & Section 47. In the instant case, the assessee failed to comply with the provisions of Section 2(19AA) (ii) & (iii). Hence, the order of the Ld. CIT(A) on these grounds are affirmed. In the result, Ground Nos. 1 & 2 of the assessee’s appeal are dismissed. 6. Ground No. 3: Disallowance

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

22)(a) & Section 47. In the instant case, the assessee failed to comply with the provisions of Section 2(19AA) (ii) & (iii). Hence, the order of the Ld. CIT(A) on these grounds are affirmed. In the result, Ground Nos. 1 & 2 of the assessee’s appeal are dismissed. 6. Ground No. 3: Disallowance

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.

section 40A(2)(b). He has adjudged that the interest paid is higher than it should have been paid by the appellant. However to arrive at the quantum of such excessive disallowance he has actually charged notional interest on loans advanced to the related parties. Here it is uncontroverted fact that unsecured loans were taken with several parties @ rates ranging

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.

section 40A(2)(b). He has adjudged that the interest paid is higher than it should have been paid by the appellant. However to arrive at the quantum of such excessive disallowance he has actually charged notional interest on loans advanced to the related parties. Here it is uncontroverted fact that unsecured loans were taken with several parties @ rates ranging

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.

section 40A(2)(b). He has adjudged that the interest paid is higher than it should have been paid by the appellant. However to arrive at the quantum of such excessive disallowance he has actually charged notional interest on loans advanced to the related parties. Here it is uncontroverted fact that unsecured loans were taken with several parties @ rates ranging

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. TORRENT POWER LTD.,, AHMEDABAD

In the result, the appeal of the Revenue and the Cross-objection of the assessee, both are dismissed

Bench: Shri Sandeep Gosain & Shri Amarjit Singh

section 14A, where he is not satisfied with the correctness of the claim of the assessee in respect of such an expenditure. In view of the above narrated facts and points of law disallowance u/s. 14A r.w.r. 8D is reworked as under. Details Rs. (a) Direct expenses Nil (b) Indirect expenses (Interest charged to P & L A/c.) 434725125 (c) Investment

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms.Annapurna Gupta & T.R. Senthil Kumarasstt.Year : 2014-15 The Dcit, Cir.2(1)(1) Gujarat Apollo Industries Ltd. Ahmedabad. ‘Apollo House’ Rashmi Society Nr.Mithakhali Six Roads Navrangpura Ahmedabad 380 009. Pan : Aaacg 7248 P

22,165/- minus Rs.3,98,520/- (disallowed by the assessee)], and determined total income at Rs.158,80,43,590/- under normal provision. This disallowance of Rs.1,34,23,645/- was further added to the book profit declared at Rs.166,87,64,960/- under section 115JB for MAT purpose. 10. Aggrieved against these disallowances the assessee filed an appeal before

THE DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S. UNITED WAY OF BARODA,, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

THE DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S. UNITED WAY OF BARODA,, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

THE DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S. UNITED WAY OF BARODA,, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S.UNITED WAYOF BARODA, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

THE DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S. UNITED WAY OF BARODA,, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

THE DCIT (EXEMPTIONS), CIRCLE-2,, AHMEDABAD vs. M/S. UNITED WAY OF BARODA,, VADODARA

In the result, ITA No. 3565/Ahd/16 is dismissed

disallowed the following expenses : Sr. Particulars Amount (Rs.) No. 1 FSF Doubtful Loan Provided 2205000 2 Assistance to Voluntary Agencies 10822700 3 Management Assistance & Training 120317 4 Public Education Programme 468116 5 Research & Publications 37179 6 Expenses for Community Service 898840 ITA Nos.: 772 and 2656/Ahd/17, 3565/Ahd/16, 426, 2657 and 2658/Ahd/17 Assessment years

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 40(a)(i) would 22 stand attracted. The assessee, a manufacturer and exporter of dyes and chemicals, engaged the following foreign entities to undertake testing of its products for regulatory compliance in the destination countries where export sales were being made: S. Amount Paid Name of the Party No. (INR) 1 Eurofins Analytics (France) 69,170.28 2

MOHAN B AGRAWAL,AHMEDABAD vs. DCIT, CIRCLE-4(2), AHMEDABAD

Appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 1009/Ahd/2019 "नधा"रणवष"/Asstt. Year: 2013-2014 Mohan B. Agrawal, D.C.I.T., 4Th Floor, Shoppers Plaza-Ii, Vs. Circle-4(2), Opp. B.S.N.L Telephone Exchange, Ahmedabad. Navrangpura, Ahmedabad-380009. Pan: Aaopa4030C

section 2(22)(e) of the Act do not apply when shareholder is paying interest on such loan and advances. In this respect the assessee placed his reliance on the multiple judgment of Kolkata Tribunal. 5. However the learned CIT (A) confirmed the addition made by the AO by observing a under: Therefore, I decide to confirm the addition

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

2 - Disallowance of Weighted Deduction under Section 35(2AB) of the Act amounting to Rs. 11,24,98,182/- 16. The Assessing Officer noted that the assessee had claimed weighted deduction under section 35(2AB) of the Act amounting to Rs.399,01,05,709/-, comprising Rs.6,30,74,642/- towards capital expenditure and Rs.199,50,52,854/- towards revenue expenditure

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

2 - Disallowance of Weighted Deduction under Section 35(2AB) of the Act amounting to Rs. 11,24,98,182/- 16. The Assessing Officer noted that the assessee had claimed weighted deduction under section 35(2AB) of the Act amounting to Rs.399,01,05,709/-, comprising Rs.6,30,74,642/- towards capital expenditure and Rs.199,50,52,854/- towards revenue expenditure

THE DY. COMMR. OF INCOME TAX, (EXEMPTION) CIRCLE-2,, AHMEDABAD vs. JAMNAGAR AREA DEVELOPMENT AUTHORITY, JAMNAGAR

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Pradip Kumar Kedia & Smt. Madhumita Roy

disallowing the claim of exemption of the appellant under section 11 of the Income tax Act, 1961, and assessing the income of the appellant under sections 28 to 44 of the Income tax Act, 1961?" Findings of Hon'ble Gujarat High Court: 10. The short hut interesting question of law posed for the consideration of this Court in the present