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

INOX INDIA LIMITED,VADODARA vs. THE DCIT, CIRCLE-1 NOW CIRCLE 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

2) of the Act and enhancing the scope of set aside proceedings. 3. The learned CIT(A) erred in fact and in law in restricting the deduction u/s 80HHC and 801A of the Act by invoking provisions of section 801A(9) despite the fact that no such directions were given by Hon'ble Income Tax Appellate Tribunal, Ahmedabad ("ITAT

INOX INDIA LIMITED,VADODARA vs. THE ACIT, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

2) of the Act and enhancing the scope of set aside proceedings. 3. The learned CIT(A) erred in fact and in law in restricting the deduction u/s 80HHC and 801A of the Act by invoking provisions of section 801A(9) despite the fact that no such directions were given by Hon'ble Income Tax Appellate Tribunal, Ahmedabad ("ITAT

INOX INDIA LIMITED,VADODARA vs. THE ACIT, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

2) of the Act and enhancing the scope of set aside proceedings. 3. The learned CIT(A) erred in fact and in law in restricting the deduction u/s 80HHC and 801A of the Act by invoking provisions of section 801A(9) despite the fact that no such directions were given by Hon'ble Income Tax Appellate Tribunal, Ahmedabad ("ITAT

INOX INDIA LIMITED,VADODARA vs. THE ACIT, CIRCLE-1(2) NOW CIRCLE- 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

2) of the Act and enhancing the scope of set aside proceedings. 3. The learned CIT(A) erred in fact and in law in restricting the deduction u/s 80HHC and 801A of the Act by invoking provisions of section 801A(9) despite the fact that no such directions were given by Hon'ble Income Tax Appellate Tribunal, Ahmedabad ("ITAT

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

2 per cent. We observe that in the instant facts, the assessee has computed the ALP at LIBOR plus 2.5%. The Ld. CIT(Appeals) has upheld the order of the Ld. Assessing Officer on the Ground that the assessee has not given the comparable basis for arriving at the aforesaid rate. However, in our view, the Ld. CIT(Appeals

SHRI VIDHYUT BOARD CREDIT AND CONSUMERS CO OPERATIVE SOCIETY LIMITED ,BHAVNAGAR vs. A.C.I.T., CIRCLE-1, BHAVNAGAR, BHAVNAGAR

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

section 2(19) of the IT Act relied upon by\nhimself defining Cooperative society and not considering Saurashtra\nGramin Bank a Regional Rural bank as Cooperative society though\nSection 2(19) clearly provide that Regional Rural Bank (which is the\nstatus of Saurashtra Gramin Bank) is Cooperative Society. Rejection of\nClaim of Rs.13,97,679/- for deduction u/s.80P(2

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

Appeal is allowed for statistical purposes

2) do not prescribe affixation of digital signature as the sole mode of authentication in such cases. In our considered view, the absence of DSC, at best, constitutes an irregularity curable under section 292B of the Act, and does not vitiate the assessment order per se.\n4.3 Accordingly, we uphold the findings of the learned CIT(A) on this issue

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

251 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 21-12-2023 by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “CIT(A)”) for the Assessment Years (AY) 2016-17 and 2017-18. The primary challenge is against the addition of Rs.1,16,49,66,875/- and Rs.90

DILIPKUMAR PASHABHAI PRAJAPATI,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(5), AHMEDABAD

In the result, both the appeals of the assessee in ITA Nos

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1095 & 1096/Ahd/2024 िनधा"रण वष" /Assessment Years : 2016-17 & 2017-18 Respectively Dilipkumar Pashabhai Prajapati The Income Tax Officer बनाम/ C/Sf 211 Pushp Business Campus Ward-3(3)(5) V/S. Nr. Vastral Cross Road Ahmedabad Sp Ring Road Vastral Ahmedabad – 382 418 "थायी लेखा सं./Pan:Atrpp 9632 R (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Jinesh Shah, Ar Revenue By : Shri R.N. Dsouza, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 10/09/2024 घोषणा की तारीख /Date Of Pronouncement: 25/09/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

251 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), dated 21-12-2023 by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “CIT(A)”) for the Assessment Years (AY) 2016-17 and 2017-18. The primary challenge is against the addition of Rs.1,16,49,66,875/- and Rs.90

BABUBHAI RAMANBHAI PATEL,AHMEDABAD vs. NATIONAL FACELESS ASSESSMENT CENTRE,DELHI PRESENT JURISDICTION THE ITO, WARD-1(2)(1), AHMEDABAD

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

2. The brief facts of the case are that the assessee filed return of income on 31.07.2012, declaring total income of Rs.1,20,000/-. Notice ITA No. 904&905/Ahd/2023 Babubhai Ramanbhai Patel vs. ITO Asst. Years –2012-13 & 2015-16 under Section 148 of the act. Act was issued on 28.03.2019. Assessment Order under Section 144 r.w.s

BABUBHAI RAMANBHAI PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1) PRESENT JURISDICTION THE ITO, WARD-1(2)(1), AHMEDABAD

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

2. The brief facts of the case are that the assessee filed return of income on 31.07.2012, declaring total income of Rs.1,20,000/-. Notice ITA No. 904&905/Ahd/2023 Babubhai Ramanbhai Patel vs. ITO Asst. Years –2012-13 & 2015-16 under Section 148 of the act. Act was issued on 28.03.2019. Assessment Order under Section 144 r.w.s

RUPEN MARKETING PVT. LTD.,AHMEDABAD vs. THE DY. CIT, CENT. CIR.-3(1)(2), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2015-16

section 251 of the Income Tax Act, 1961 w.e.f. 01.10.2024 on the basis of observations/findings given the appellate order and without going to the merits of the case and different grounds of appeal raised by the appellant company. 2. The learned CIT(A) has grievously erred in law and on facts in not appreciating the fact that the DCIT Circle

PIRAMAL FINANCE PVT. LTD.,,MUMBAI vs. THE ACIT, CIRCLE-2(1)(2),, VADODARA

In the result, appeal preferred by the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

251(2) of the Act 2. He further erred in not appreciating that the expense was incurred wholly and exclusively for the purpose of business and therefore allowable u/s 37(1) of the Act and has been so allowed in the earlier year. 3. The Appellant prays that the disallowance of 50% of the guarantee commission paid be deleted GROUND

MUNJAL AUTO INDUSTRIES LIMITED,VADODARA, GUJARAT vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 2(1)(1), VADODARA, VADODARA, GUJARAT

In the result, the appeal of the assessee is allowed for statistical purposes with the direction that the matter is restored to the file of the CIT(A) for adjudication afresh in accordance with law

Bench: Shri Siddhartha Nautiyal & Shri Makarand V.Mahadeokarasstt.Year : 2018-19 Munjal Auto Industries Ltd. Dcit, Cir.2(1)(1) 187 Gide Estate Vadodara. Waghodia Dist. Vadodara-391 760 Gujarat. Pan: Aaacg 8588 L (Applicant) (Responent) : Ms.Amrin Pathan, Ar Assessee By : Shri Yoeesh Mishra, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 17/09/2025 आदेश आदेश/O R D E R आदेश आदेश

251 of the Act and enhancing the disallowance u/s 14A by 10% of salary paid to CFO. 9. The learned CIT(A) erred in fact and in law in directing the AO to enhance the disallowance u/s 14A by disallowing 10% of salary paid to CFO. 10. The learned CIT(A) erred in fact and in law in confirming

BACKBONE TARMET NG JV,AHMEDABAD vs. THE INCOME-TAX OFFICER, WARD-5(2)(2), AHMEDABAD

The appeal of the assessee is allowed in above terms

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2005-06 Vs. Backbone Tarmet Ng Jv, The Income-Tax Officer, A-9, Kumud Apartment, Ward-5(2)(2), Near Stadium Five Roads, Ahmedabad Navrangpura, Ahmedabad-380009 Pan : Aaaab 3885 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sakar Sharma, Ca Revenue By : Shri Vipul Chavda, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 28/03/2024 घोषणा की तारीख /Date Of Pronouncement: 05/04/2024 आदेश/O R D E R Per Annapurna Guptapresent Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 20.06.2022 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2005-06. 2. Grounds Raised Are As Under :- “1. The Ld. Cit(A)-Nfac Erred On Facts & In Law In Deciding Appeal Ex- Parte Without Appreciating That Business Of The Appellant Has Been Closed Since Covid-19 & Therefore, In Absence Of Any Office, Notice(S) Claimed To Be Have Been Served Through Email Could Not Be Communicated To The Partners Of The Appellant. Without Prejudice To This It Is Submitted That No Notice(S) Came To Be Served On The Appellant At The Designated Email Stated In Form No. 35 For The Purpose Of Service Of Notice(S). Backbone Tarmet Ng Jv Vs. Ito Ay : 2005-06 2

251(1)(a) has held by Hon'ble Bombay High Court in the case of CIT vs Premkumar Arjundas Luthra (HUF) 297 CTR 614 (Bom) 3. The Ld. CIT(A)-NFAC erred on facts and in law in not directing the Assessing Officer to rectify order passed u/s 154 in view of judgement of Hon'ble Supreme Court holding

DEPUTY COMMISIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. AADINATH DEVELOPERS, AHMEDABAD

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

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

disallowed the deduction claimed under Section 80-IBA of the Act. Further, the Assessing Officer noticed that the assesee had taken unsecured loan of Rs. 1,43,82,420/-, however, out of the same, unsecured loans amounting to Rs. 1,37,90,033/- remained unexplained. Accordingly, the same were added as income of the assessee under Section

DEPUTY COMMISSIONER OF INCOME TAX, GANDHINAGAR vs. GUJARAT STATE PETROLEUM CORPORATION LIMITED, GANDHINAGAR

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

251, of the Income-tax Act, 1961 - Deductions - Profits and gains from infrastructure industrial undertakings (Reassessment) - Assessment year 2012-13 - Assessee, engaged in business of solid waste management, claimed exemption under section 80-IA which was initially disallowed by Assessing Officer - But on appeal, Commissioner (Appeal) allowed assessee's claim of deduction in its entirety - Later on, assessment was sought