REAL CARGO MUMBAI,ARVALLI vs. THE ITO, WARD-1, MODASA

In the result, the appeal of the assessee in ITA No

Bench: Income-Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad. This Appeal In Ita No.268/Ahd/2024 For Assessment Year 2010-11, Is Filed By The Assessee Before Income Tax Appellate Tribunal, Ahmedabad Division Bench, Ahmedabad Has Arisen From The Appellate Order Dated 25.09.2023 Passed By Ld. Commissioner Of Income-Tax(Appeals), Nfac, Delhi U/S. 250 Of The Income- Tax Act,1961 , Vide Din & Order No. Itba/Nfac/S/250/2023- 24/1056508501(1), Which Has In Turn Arisen From The Assessment Order Dated 18.12.2018 Passed By The Assessing Officer U/S. 143(3) Read With Section 254 Of The Income-Tax Act 1961. 2. The Grounds Of Appeal Raised By The Assessee In Memo Of Appeal Filed With The Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , Reads As Under:-

Section 254 of the Income-tax Act 1961. 2. The grounds of appeal raised by the assessee in Memo of Appeal filed with the Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad , reads as under:- “1. The order passed u/s 250 passed on 25.09.2023 by NFAC, Delhi for AY 2010-11 upholding the disallowance of freight expenses

VARUN SATYAPAL SINGHAL,VADODARA vs. THE INCOMETAX OFFICER, WARD-1(2)(3( NOW THE DCIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Us, At The Outset, Ld. Counsel For The Assessee Submitted That He Shall Not Be Pressing For Ground Nos. 3, 4 & 5 Of His

3. We have heard both the parties. There is no dispute that both the lower authorities have invoked the impugned section 40A(2)(b) disallowance by benchmarking assessee's interest rate paid in other cases @ 18% to disallow 6% excessive rate in case of above three payees. There is not even iota of discussion in the lower orders about market

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

disallowance of deduction u/s 80IA(4) without appreciating the fact that the assessee did not fulfill the conditions precedent and the assessee was only a contractor not a developer. 2. On the facts and in the circumstances of the case, the ld. CIT(A) ought to have upheld the order of the Assessing Officer. 3. It is, therefore, prayed that

THE ACIT.(OSD), CIRCLE-1,, AHMEDABAD vs. KHURANA ENGINEERING LTD.,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

disallowance of deduction u/s 80IA(4) without appreciating the fact that the assessee did not fulfill the conditions precedent and the assessee was only a contractor not a developer. 2. On the facts and in the circumstances of the case, the ld. CIT(A) ought to have upheld the order of the Assessing Officer. 3. It is, therefore, prayed that

KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

disallowance of deduction u/s 80IA(4) without appreciating the fact that the assessee did not fulfill the conditions precedent and the assessee was only a contractor not a developer. 2. On the facts and in the circumstances of the case, the ld. CIT(A) ought to have upheld the order of the Assessing Officer. 3. It is, therefore, prayed that

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

253 ITR 749) for the proposition that for the purpose\nof section 32, registration in the assessee's own name is not mandatory if\nbeneficial ownership and business use are established.\n80. On this issue, the learned AR placed reliance on the findings of the\nlearned CIT(A), whereas the learned DR supported the order of the\nAssessing Officer

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

Appeals are partly allowed for\nstatistical reasons

253 ITR 749) for the proposition that for the purpose\nof section 32, registration in the assessee's own name is not mandatory if\nbeneficial ownership and business use are established.\n80.\nOn this issue, the learned AR placed reliance on the findings of the\nlearned CIT(A), whereas the learned DR supported the order of the\nAssessing Officer

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

Appeals are partly allowed for\nstatistical reasons

3 – Addition on account of Notional interest on advances/rent\n49.\nFor A.Y. 2013–14, the Assessing Officer noted from the financial\nstatements that the assessee had shown advances for land aggregating to Rs.\n67,00,000/- as on 31.03.2013, comprising Rs.12,00,000/- to Shri Shailesh S.\nParikh for land at Navagam, Ankleshwar, and Rs.55,00,000/- to M/s\nSatyam

GUJARAT POWER CORPORATION LIMITED,GANDHINAGAR vs. THE PR. CIT, AHMEDABAD-3, AHMEDABAD

In the result, Ground No. 4 of the assessee’s appeal is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

253 Less: Already disallowed in the return Rs. 1,00,000) 3. Disallowance U/s. 14A r.w. Rule 8D(2) of Rs. 1,10,47,762/- in addition to disallowance u/s 14A made in the assessment order dated 24-09-21 while Calculating Book Profit U/s. 115JB of the Act – MAT (Disallowance as computed in Revision Order dated

GUJARAT STATE ELECTRICITY CORPORATION LTD,VADODARA vs. THE PR. CIT-1, VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.572/Ahd/2020 िनधा"रण वष" /Assessment Year : 2015-16 Gujarat State Electricity The Pr.Cit-1 Corporation Ltd. बनाम/ Vadodara – 390 015 Sardar Patel Vidhyut Bhavan V/S. Race Course Circle Vadodara – 390 007 "थायी लेखा सं./Pan: Aaacg 6864 F अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Manish J. Shah & Shri Jimi Patel, Ars Revenue By : Shri A.P. Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 02/04/2025 घोषणा की तारीख /Date Of Pronouncement: 08/04/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

disallowance under section 14A of the Act, capital grants, prior period items, liquidated damages, and others. Gujarat State Electricity Corporation Ltd. vs. Pr.CIT-1 Asst. Year : 2015-16 3 2.4. Subsequently, the Principal Commissioner of Income Tax–1, Vadodara, issued a notice under section 263 of the Act on 13.09.2019, proposing to revise the assessment on the ground that

THE ITO, WARD-3(2)(4), AHMEDABAD vs. M/S. RADHE KRISHNA DEVELOPERS, AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

disallowance of Rs.11,00,000/- made u/s 40A(3) of the Act. 6. Let us deal with each Ground raised by the Revenue. Ground No.1 is deletion of addition of Rs.1,11,69,600/- being under statement of value of investment in immovable property u/s. 69B of the Act. Brief facts of the case are that during the course

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

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)

section 14A Particulars Amount (Rs) Employee Cost 3,62,625 Depreciation 19.433 Cost + Dep)] 95,514.40 Other overheads [25% of (Emp. Total 4,77,572 Employees cost Total Cost Total time Amount involved (%) (Rs.) 1,31,39,648 1% 1,31,396 Rajesh B. Shah, CFO and COO (Fin. & Comm.) Vinit Jain, Asst. Manager

NIRMA CHEMICAL WORKS PVT. LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

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

Bench: Shri Ramit Kochar & Ms. Suchitra Kambleassessment Year : 2013-14 Nirma Chemical Works Pvt. The Dy. Commissioner Of Income- Ltd. V. Tax Nirma House Circle-3(1)(1) Ashram Road, Ahmedabad Near Income Tax Circle Gujarat Ahmedabad-380 009 Gujarat Pan: Aaacn 5353 L अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" य "" यथ" "" य "" य थ" थ"/ (Respondent) थ" Assessee By : Shri Hemanshu Shah, Ca Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 18/01/2024 & 23.01.2024 घोषणा क" तारीख /Date Of Pronouncement: 23/01/2024 आदेश/O R D E R आदेश आदेश आदेश Per Coram: This Appeal Filed By Assessee Is Directed Against The Appellate Order Dated 19/05/2022 Passed By Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi [“Cit(A)” In Short] Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called “The Act”) For Assessment Year 2013-14 (Din & Order No.Itba/ Nfac/S/250/2022- 23/1043081956(1)), The Appellate Proceedings Have Arisen Before Ld.Cit(A) From Rectification Order Dated 16/02/2022 Passed By Ld. Assessing Officer(Hereinafter Called “The Ao”) U/S 154 Of The 1961 Act (Din & Order Nirma Chemical Works Pvt. Ltd. V. Dcit Ay 2013-14

Section 253(6)(d). Thus, the appeal fee paid was deficient by Rs. 9500/- which the assesse is required to deposit, were the contention of ld. DR. The ld. counsel for the assessee submitted that the assesse will deposit the deficient fee of Rs. 9,500/- , although the assesse was earlier having a bonafide belief that the assesse was liable

SATYAGRAH CHHAVNI CO OP HOUSING SOCIETY LIMITED,AHMEDABAD vs. THE ITO, WARD-3(3)(5), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesatyagrah Chhavni Co-Op. Housing Vs. Society Limited, Income Tax Officer, Lane 13, 253 Office, Building, Nr. Ward 3(3)(5), Bhav Nirzar, Satellite, Ahmedabad Ahmedabad-380015 [Pan : Aaaas 6148 N] (Appellant) .. (Respondent) Appellant Represented By : Shri B.T. Thakkar, Ar & Shri Mehul K. Patel, Advocate Respondent Represented By: Shri Abhijit, Sr. Dr Date Of Hearing 03.02.2026 Date Of Pronouncement 03.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:-

253 Office, Building, Nr. Ward 3(3)(5), Bhav Nirzar, Satellite, Ahmedabad Ahmedabad-380015 [PAN : AAAAS 6148 N] (Appellant) .. (Respondent) Appellant represented by : Shri B.T. Thakkar, AR & Shri Mehul K. Patel, Advocate Respondent represented by: Shri Abhijit, Sr. DR Date of Hearing 03.02.2026 Date of Pronouncement 03.02.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- This appeal

SHRI BABUBHAI BHIMAJIBHAI MALI,AHMEDABAD vs. THE ITO, WARD-1(2)(1), AHMEDABAD

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

Bench: Shri Ramit Kochar & Ms. Suchitra Kambleassessment Year : 2014-15 Shri Babubhai Bhimajibhai The Ito Mali V. Ward-1(2)(1) 120, M.G. Market, Ahmedabad-380015 Shanti Commercial Centre Gujarat Nagar Sheth Ho Vando Gheekanta Ahmedabad – 360 001 Gujarat Pan:Aappm 7611 N अपीलाथ"/ (Appellant) अपीलाथ" "" यथ" "" य थ"/ (Respondent) अपीलाथ" अपीलाथ" "" य "" य थ" थ" Assessee By : Shri Prashant Shrivastav, Ca Revenue By : Shri Vipul Chavda,Sr. Dr

disallowed as stated in Ground No. 2 above. 4. Any other ground which may be urged before or during the time of hearing of the appeal.” 3. The brief facts of the case are that the assessee has filed its return of income for assessment year 2014-15 on 29/03/2016 declaring income at Rs.4,29,105/-. The case was selected

M. PRATAPRAY PRINTS PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-2(1)(2), AHMEDABAD

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

253 ITR 798 (SC) has reiterated that a pragmatic and justice-oriented approach should be adopted while deciding applications for condonation of delay. In the present case, the explanation offered by the assessee appears to be bona fide and there is nothing on record to suggest that the delay was deliberate or due to negligence on the part

BHAVNATH EDUCATION TRUST,BAVNAGAR vs. THE ITO(EXEMPTION) WARD, BHAVNAGAR

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

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1559/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2018-19) बनाम/ Bhavnath Education Trust Income Tax Officer Bhanagar Highway, Dist. (Exemption) Vs. Bhavnagar, Ranghola- Ward, Bhavnagar 364230 / Aayakar Bhawan, Income Sanghavi & Company, Tax Office, Bhavanagar Prasham, 4Th Floor, Kasturba Road, Nr. Bilkha Plaza, Rajkot - 360001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaatb2003J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri M K Patel, Advocate ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr Date Of Hearing 06/01/2026 07/01/2026 Date Of Pronouncement

Section. 253(3) of the Act, the last date of filing the present appeal was 30/04/2025 however the appeal is being filed on 04.08.2025 i.e belated by 97 days. 5. That I beg to submit that since the old income tax portal and even after the implementation of the new income tax portal, the registered email address on its profile