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

KIFS SECURITIES PVT. LTD.,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

THE ACIT, CIRCLE-3,, AHMEDABAD vs. KIFS SECURITIES LIMITED,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3),, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

DY.COMMISSIONER OF INCOME TAX CIRCLE-1(3),, AHMEDABAD vs. KIFS PVT.LTD.,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

THE DY. CIT., CIRCLE-3,, AHMEDABAD vs. KHANDWALA INTEGRATED FINANCIAL SERVICES PVT. LTD, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

section 36(2) of the I.T. Act, 1961 is not satisfied by the assessee. . 4.The CIT(A) has erred in law and on facts in deleting the addition of Rs.5,41,251/- made by A.O u/s 40(a)(ia) of the Act, on account of Lease Line charges of Rs.5,41,251/- paid to BSNL. The AO has rightly disallowed

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

251 and the decision of the Hon'ble Kerala High Court in the case of CIT vs. Kerala Electric Lamp Works Ltd.,183 CTR 182, the assessee contended that depreciation should not be reduced in the year under consideration. However, the AO did not accept the contentions of the assessee. While referring to the amendment in the provisions of section

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

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 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,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

INDUSTRIAL CO. OPERATIVE CREDIT SOCIETY LTD.,,KHEDA vs. THE PR. CIT-2,, VADODARA

In the result, the tax appeals are dismissed

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1064/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-13 Industrial Co-Operative Credit Vs. The Pr.Cit-2 Society Ltd. Vadodara. At-Kanjari, Anand-Nadiad Road Ta. : Nadiad, Dist: Kheda Pan : Aaaai 7424 B

251 ITR 522 (SC) 4. On consideration of submissions of the assessee, and on the basis of the above judgments, the ld.CIT(A)-2, Vadodara vide order dated 28.12.2015 directed the AO to allow deduction under section 80P(2)(a)(i) of the Act and thus, allowed claim of the assessee. Thereafter, the ld.Pr.CIT-2, Vadodara invoked his revisional power

ADITYA MEDISALES LIMITED,,BARODA vs. THE DY.CIT, CIRCLE-1(1),, BARODA

In the result, appeal of the assessee is partly allowed whereas

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr

Section 115JA of the Act. In parity with the decision of the co-ordinate bench in ASB International (P.) Ltd. 26 taxmann.com 87 (Mum) and CIT vs. Echjay Forgings (P.) Ltd. 251 ITR 15 (Bom.), the AO is directed to exclude the provision for wealth tax for the purposes of computation of book profit. 7.2 In the result, Ground No.5