TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance of deduction under section 80-IE of the Act in Sikkim Unit on other incomes. 60. The AO during the assessment proceedings found that the assessee has claimed deduction of profit derived from Sikkim Unit under section 80-IE of the Act. As per the AO, there were certain incomes considered by the assessee eligible for deduction under section

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

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

Section 90(2), where there is a DTAA between India and any country outside India, the more favourable of the two provisions, viz., under the DTAA or under the I.T. Act, are to be applied in case of the assessee. However, in my view, the point as to whether the payments are in the nature of fees for technical services

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

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

Section 90(2), where there is a DTAA between India and any country outside India, the more favourable of the two provisions, viz., under the DTAA or under the I.T. Act, are to be applied in case of the assessee. However, in my view, the point as to whether the payments are in the nature of fees for technical services

TORRENT POWER LTD.,,AHMEDABAD vs. THE ACIT.,RANGE-8,, AHMEDABAD

In the result cross objection filed by the assessee is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

disallowing the deduction under section 80-IA of the Act. 69. The learned CIT (A) disregarded the contention of the assessee by observing that the impugned income does not have nexus with the distribution of power activity of the assessee. Thus the learned CIT (A) upheld the finding of the AO. 70. Being aggrieved by the order of the learned

PRATHAM INVESTMENTS,VADODARA, GUJARAT vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(2), VADODARA (NOW DCIT, CIRCLE 1(1)(1)), VADODARA, GUJARAT

disallowance\nof interest expenses relating to the earning of exempt income, in\nterms of the provisions of Section 14A of the Act amounting to\nRs.2,86,58,206

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

206/- covered under the exceptions in view of several reasons as mentioned in the body of the order; and (ii) the balance figure of Rs.65,20,741/- not covered under the exceptions, thus liable for disallowance under section

ORACLE GRANITO LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(2) NOW CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2008-09 Oracle Granito Limited The Dcit, Cir.3(1)(2) 206, Dev Arc, Second Floor Vs Now Cir.3(1)(1) Nr.Fun Republic Ahmedabad. Opp: Big Bazar S.G. Highway Road Ahmedabad 380 015. Pan : Aaaco 6238 P (Applicant) (Responent) : Assessee By Shri Aseem Thakkar, Ar Revenue By : Shri Amit Pratap Singh, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 09/01/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/03/2025

206, Dev Arc, Second Floor Vs Now Cir.3(1)(1) Nr.Fun Republic Ahmedabad. Opp: Big Bazar S.G. Highway Road Ahmedabad 380 015. PAN : AAACO 6238 P (Applicant) (Responent) : Assessee by Shri Aseem Thakkar, AR Revenue by : Shri Amit Pratap Singh, Sr.DR सुनवाई क" तारीख/Date of Hearing : 09/01/2025 घोषणा क" तारीख /Date of Pronouncement: 07/03/2025 आदेश आदेश

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

section 271(1B). The contentions of the Ld. Authorized Representatives that the Assessing Officer has not recorded proper and specific satisfaction while initiating penalty proceedings is found to be not correct. It is noticed from the assessment order that the Assessing Officer had recorded his specific satisfaction for initiating the penalty proceedings while making the addition/disallowances. The summary of satisfaction

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

section 271(1B). The contentions of the Ld. Authorized Representatives that the Assessing Officer has not recorded proper and specific satisfaction while initiating penalty proceedings is found to be not correct. It is noticed from the assessment order that the Assessing Officer had recorded his specific satisfaction for initiating the penalty proceedings while making the addition/disallowances. The summary of satisfaction

GMM PFAUDLER LTD.,,AHMEDABAD vs. THE DY. CIT., CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

section 44AB of the Income Tax Act. On perusal of the submissions and the records of the assessee, Ld. CIT(Appeals) accepted the assessee’s contention that the assessee has sufficient interest free funds for I.T.A Nos. 1370 & 951/Ahd/2015, 2003, 2827, 2212 & 2213/Ahd/2016 A.Y. 2010-11 to 2012-13 17 DCIT vs. GMM Pfaulder & GMM Pfaulder vs. DCIT making investments

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. GMM P FOULDER PVT. LIMITED,, AHMEDABAD

Appeal is dismissed

section 44AB of the Income Tax Act. On perusal of the submissions and the records of the assessee, Ld. CIT(Appeals) accepted the assessee’s contention that the assessee has sufficient interest free funds for I.T.A Nos. 1370 & 951/Ahd/2015, 2003, 2827, 2212 & 2213/Ahd/2016 A.Y. 2010-11 to 2012-13 17 DCIT vs. GMM Pfaulder & GMM Pfaulder vs. DCIT making investments

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GMM PFAULDER PVT. LIMITED,, AHMEDABAD

Appeal is dismissed

section 44AB of the Income Tax Act. On perusal of the submissions and the records of the assessee, Ld. CIT(Appeals) accepted the assessee’s contention that the assessee has sufficient interest free funds for I.T.A Nos. 1370 & 951/Ahd/2015, 2003, 2827, 2212 & 2213/Ahd/2016 A.Y. 2010-11 to 2012-13 17 DCIT vs. GMM Pfaulder & GMM Pfaulder vs. DCIT making investments

GMM PFAUDLER LTD.,,AHMEDABAD vs. THE DY. CIT., CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

section 44AB of the Income Tax Act. On perusal of the submissions and the records of the assessee, Ld. CIT(Appeals) accepted the assessee’s contention that the assessee has sufficient interest free funds for I.T.A Nos. 1370 & 951/Ahd/2015, 2003, 2827, 2212 & 2213/Ahd/2016 A.Y. 2010-11 to 2012-13 17 DCIT vs. GMM Pfaulder & GMM Pfaulder vs. DCIT making investments

GMM PFAUDLER LTD.,,AHMEDABAD vs. THE DY.CIT., CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

section 44AB of the Income Tax Act. On perusal of the submissions and the records of the assessee, Ld. CIT(Appeals) accepted the assessee’s contention that the assessee has sufficient interest free funds for I.T.A Nos. 1370 & 951/Ahd/2015, 2003, 2827, 2212 & 2213/Ahd/2016 A.Y. 2010-11 to 2012-13 17 DCIT vs. GMM Pfaulder & GMM Pfaulder vs. DCIT making investments

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD, VADODARA

In the result, the appeal filed by the Assessee in ITA No

section 271(1B). The contentions of the Ld. Authorized Representatives that the Assessing Officer has not recorded proper and specific satisfaction while initiating penalty proceedings is found to be not correct. It is noticed from the assessment order that the Assessing Officer had recorded his specific satisfaction for initiating the penalty proceedings while making the addition/disallowances. The summary of satisfaction

CERA SANITARYWARE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

206,33,48,260/- . The assessee has shown exempt income of Rs.1,04,87,339/- in which Rs.20,40,000/- is on account of Share of profit on investment in LLP and Rs.84,47,339/- on account of interest of tax-free bonds. The assessee suo moto disallowed of Rs. 4,77,572/- towards expenses debited to profit and loss

ASST. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), AHMEDABAD, AHMEDABAD vs. MS. JAGSON COLORCHEM LIMITED, PHASE -II GIDC ESTATE VATVA

In the result, the appeal of the Revenue is dismissed

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years:2018-19

disallowed the commission of Rs.5,63,28,206/- under the provision of section 40(a)(i) of the Act, for non-deduction

DCIT, CIRCLE 1(1)(1) , VADODARA vs. PRATHAM INVESTMENT, VADODARA

disallowance\nof interest expenses relating to the earning of exempt income, in\nterms of the provisions of Section 14A of the Act amounting to\nRs.2,86,58,206