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.

disallowance of interest expenditure can be made under Section 58(2) of the Act as upheld by the Ld. CIT(A). The provision of Section 58 of the Act is found to be as under: 58. Amounts not deductible. (1) Notwithstanding anything to the contrary contained in section 57, the following amounts shall not be deductible in computing the income

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.

disallowance of interest expenditure can be made under Section 58(2) of the Act as upheld by the Ld. CIT(A). The provision of Section 58 of the Act is found to be as under: 58. Amounts not deductible. (1) Notwithstanding anything to the contrary contained in section 57, the following amounts shall not be deductible in computing the income

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

2,57,97,695. ITA Nos. 1184/Ahd/2018 & 1225/Ahd/2018 Assessee : Reckitt Benckiser Healthcare (I) Ltd Asst. Year : 2011-12 - 29– The Ld. Counsel for the assessee, therefore, argued that, as investments were made by RBHIL from its own surplus funds and no expenses were incurred by RBHIL with respect to the aforesaid investments, the question of applicability of Section

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

2,57,97,695. ITA Nos. 1184/Ahd/2018 & 1225/Ahd/2018 Assessee : Reckitt Benckiser Healthcare (I) Ltd Asst. Year : 2011-12 - 29– The Ld. Counsel for the assessee, therefore, argued that, as investments were made by RBHIL from its own surplus funds and no expenses were incurred by RBHIL with respect to the aforesaid investments, the question of applicability of Section

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

2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section 14A r.w.s. Rule 8D 8,70,747 5 Disallowance of Weighted Deduction under 65,09,81,251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section

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

2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section 14A r.w.s. Rule 8D 8,70,747 5 Disallowance of Weighted Deduction under 65,09,81,251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section

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

disallowed by the Assessing Officer and deduction\ngranted by the Assessing Officer is tabularized and recorded as under\":\nHon'ble Court thereafter put reliance upon the decision of Hon'ble Punjab\n& Haryana High Court's decision and held that gross interest income is to be\ngranted as deduction under section 80P(2)(d) of the Act. The finding recorded

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

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

disallowed by the Assessing Officer and deduction granted by the Assessing Officer is tabularized and recorded as under”: 7. Hon’ble Court thereafter put reliance upon the decision of Hon’ble Punjab & Haryana High Court’s decision and held that gross interest income is to be granted as deduction under section 80P(2)(d) of the Act. The finding recorded

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

Bench: Smt.Annapurna Gupta & Ms.Suchitra R. Kamble

disallowed by the Assessing Officer and deduction granted by the Assessing Officer is tabularized and recorded as under”: 7. Hon’ble Court thereafter put reliance upon the decision of Hon’ble Punjab & Haryana High Court’s decision and held that gross interest income is to be granted as deduction under section 80P(2)(d) of the Act. The finding recorded

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)

section 14A(2). Merely writing in the assessment order that he is not satisfied with the claim of the assessee is not sufficient, but he has also to give reasons after examining the accounts of the assessee that the claim of disallowance made by the assessee is not enough or is not adequately related to exempted income. The compliance

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)

section 14A(2). Merely writing in the assessment order that he is not satisfied with the claim of the assessee is not sufficient, but he has also to give reasons after examining the accounts of the assessee that the claim of disallowance made by the assessee is not enough or is not adequately related to exempted income. The compliance

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)

section 14A(2). Merely writing in the assessment order that he is not satisfied with the claim of the assessee is not sufficient, but he has also to give reasons after examining the accounts of the assessee that the claim of disallowance made by the assessee is not enough or is not adequately related to exempted income. The compliance

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)

section 14A(2). Merely writing in the assessment order that he is not satisfied with the claim of the assessee is not sufficient, but he has also to give reasons after examining the accounts of the assessee that the claim of disallowance made by the assessee is not enough or is not adequately related to exempted income. The compliance

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

section 143(2)\nwere issued and duly served. The Assessing Officer, after examining the\nmaterial placed on record, made various disallowances and additions under\ndifferent heads, determining the assessed income for each year as set out\nbelow. The Assessing Office completed the assessment by passing order u/s\n143(3) of the Act. The details of the assessment and the additions

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

disallowed commission expenditure of Rs.23,71,88,037/- paid by the assessee to various nonresident commission agents on the ground that no tax was deducted at source under section 195 of the Act. The AO held that in view of section 5(2

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

section 143(2)\nwere issued and duly served. The Assessing Officer, after examining the\nmaterial placed on record, made various disallowances and additions under\ndifferent heads, determining the assessed income for each year as set out\nbelow. The Assessing Office completed the assessment by passing order u/s\n143(3) of the Act. The details of the assessment and the additions

UNION BANK CO. OP. CREDIT SOCIETY LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1228 & 1229/Ahd/2024 िनधा"रण वष" /Assessment Years: 2018-19 & 2020-21 Respectively Union Bank Co-Op. Credit The Dy.Cit बनाम/ Society Ltd. Circle-1(1)(1) V/S. 1, Dhalaxmi Market Ahmedabad Revadi Bazar Kalupur Ahmedabad – 380 001 (Gujarat) "थायी लेखा सं./Pan:Aaau 0802 F (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Anil Kshatriya, Advocate Revenue By : Smt. Bhavna Gupta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/09/2024 घोषणा की तारीख /Date Of Pronouncement: 08/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

71,157/- 3. The assessee preferred and appeal before the CIT(A) against the order of AO. The CIT(A) upheld the additions made by the Assessing Officer (AO) in both assessment years 2018-19 and 2020-21, disallowing the deductions claimed by the assessee under sections 80P(2

UNION BANK CO.OP. CREDIT SOCIETY LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1228 & 1229/Ahd/2024 िनधा"रण वष" /Assessment Years: 2018-19 & 2020-21 Respectively Union Bank Co-Op. Credit The Dy.Cit बनाम/ Society Ltd. Circle-1(1)(1) V/S. 1, Dhalaxmi Market Ahmedabad Revadi Bazar Kalupur Ahmedabad – 380 001 (Gujarat) "थायी लेखा सं./Pan:Aaau 0802 F (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Anil Kshatriya, Advocate Revenue By : Smt. Bhavna Gupta Singh, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 24/09/2024 घोषणा की तारीख /Date Of Pronouncement: 08/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

71,157/- 3. The assessee preferred and appeal before the CIT(A) against the order of AO. The CIT(A) upheld the additions made by the Assessing Officer (AO) in both assessment years 2018-19 and 2020-21, disallowing the deductions claimed by the assessee under sections 80P(2

THE DY.CIT, CENTRAL CIRCLE-1, VADODARA vs. PAWAN EDIFICE PVT. LTD., VADODARA

Appeals are partly allowed for\nstatistical reasons

section 143(2)\nwere issued and duly served. The Assessing Officer, after examining the\nmaterial placed on record, made various disallowances and additions under\ndifferent heads, determining the assessed income for each year as set out\nbelow. The Assessing Office completed the assessment by passing order u/s\n143(3) of the Act. The details of the assessment and the additions