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

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 36(1

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM LTD.,, AHMEDABAD

In the result, revenue’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowance under section 40(a)(ia) for any payments made to such non-resident agents without deduction of tax at source. Learned representatives, however, fairly agree, even as learned Departmental Representative dutifully relies upon the stand of the authorities below, that this issue is now covered by a coordinate bench decision of this Tribunal in the case of DCIT

KARNAVATI ENGINEERING LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-4,, AHMEDABAD

In the result, the appeal is allowed in the terms indicated above

disallowance under section 40(a)(ia) for any payments made to such non- resident agents without deduction of tax at source. Learned representatives, however, fairly agree, even as learned Departmental Representative dutifully relies upon the stand of the authorities below, that this issue is now covered by a coordinate bench decision of this Tribunal in the case of DCIT

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM PVT. LTD.,, AHMEDABAD

In the result, the appeal is dismissed

disallowance under section 40(a)(ia) for any payments made to such non-resident agents without deduction of tax at source. Learned representatives, however, fairly agree, even as learned Departmental Representative dutifully relies upon the stand of the authorities below, that this issue is now covered by a coordinate bench decision of this Tribunal in the case of DCIT

M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION,GANDHINAGAR vs. THE DY.CIT.,GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

THE ACIT,GNR CIRCLE,, GANDHINAGAR vs. M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION LTD., GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION LTD.,GANDHINAGAR vs. THE ADDL.CIT.,GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

THE ACIT,GNR CIRCLE,, GANDHINAGAR vs. M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION LTD., GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

THE DCITGANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION, GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

M/S. GUJARAT INDUSTRIAL INVESTMENT CORPORATION LTD.,GANDHINAGAR vs. THE JT.CIT.,GNR RANGE,, GANDHINAGAR

Appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

251 III 5% of the average value of investment Rs.84,81,427 on which tax free income is received or receivable. IV Total Rs.7,10,64,678 3.4 In view of the above, AO disallowed expense of Rs. 7,10,64,678/- under the provision of section 14A of the Act and added to the total income of the assessee

MAHENDRA PATEL BUILDERS PVT. LTD.,VADODARA vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarit(Ss)A No.61 To 65/Ahd/2025 Asstt.Year : 2015-16 To 2019-20 And

Disallowance under section 37(1): 6.1 In the course of assessment proceedings, the Assessing Officer noted from the profit and loss account and the supporting ledger that the assessee had claimed insurance premium expenditure under the head “Miscellaneous Expenses”, for various endowment life insurance policies taken in the names of its directors and their family members. The total premium paid

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. THE ACIT.,(OSD) RANGE-1,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT. LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT. LTD.,AHMEDABAD vs. THE ADDL. CIT, TDS RANGE,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

CORRTECH INTERNATIONAL PVT.LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)RANGE-1,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DCIT(OSD)RANGE-1,, AHMEDABAD vs. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses

THE DCIT(OSD) RANGE-1,, AHMEDABAD vs. M/S. CORRTECH INTERNATIONAL PVT.LTD.,, AHMEDABAD

Bench: Ms. Suchitra Kamble& Shri Waseem Ahmed

Section 36(1)(iii) the issue has also decided in Ground No. 3 of assessee’s appeal for A.Y. 2009-10 hereinabove. Therefore, Ground No. 4 is dismissed. 23. As relates to Ground No. 5 of Revenue’s appeal regarding deletion of disallowance of stamp duty and share capital expenses, the Ld. D.R. submitted that the said expenses