THE DCITANAND CIRCLE,, ANAND vs. ELECON ENGINEERING CO.LTD.,, ANAND

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Roysr.No.

disallowance in respect of interest on loans and advnces given to overseas companies of the appellant.” 30. At the outset, we note that we have already adjudicated the identical issue in the ground no. 3 of the ITA 2641/AHD/2010 in favor of the assessee vide paragraph no. 20 of this order except for the minor change that the assessee

THE DCITANAND CIRCLE,, ANAND vs. ELECON ENGINEERING CO.LTD.,, ANAND

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Roysr.No.

disallowance in respect of interest on loans and advnces given to overseas companies of the appellant.” 30. At the outset, we note that we have already adjudicated the identical issue in the ground no. 3 of the ITA 2641/AHD/2010 in favor of the assessee vide paragraph no. 20 of this order except for the minor change that the assessee

ACIT CC 2(3) AHMEDABAD, AHMEDABAD vs. AISHA DHIRAJ GOGIA, AHMEDABAD

In the result: 50. To summarize the final outcome:

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha["ी संजय गग", "ाियक सद" एवं "ी नरे" साद िस!ा, लेखा सद" के सम#।]

disallowance in unabated years, without any specific incriminating material contradicting the documented transactions, is illegal. The AR submitted that it has never been accepted by Shri Shiv Kumar Gogia that these were penny stocks and that the Ld. AO has misunderstood his statement and has wrongly drawn adverse inference against the assessee. He submitted that firstly, there was nothing incriminating

THE DY. COMMISSIONER OF INCOME TAX, KHEDA CIRCLE,, KHEDA vs. ADF FOODS LTD.,, KHEDA

In the result, appeal of the Revenue is dismissed due to low tax effect

Bench: Shri Rajpal Yadav & Shri Amarjit Singh"नधा"रण वष"/ Asstt.Year: 2013-2014 Dcit, Kheda Circle Adf Foods Ltd Nadiad Vs. 83/6,Gidc Industrial Estate Dist: Kheda 387 002. Kamla Road Nadiad, Dist. Kheda 387 001. Pan : Aacca 2270 K

disallowance of sales commission at Rs.1,10,31,710/-. On legal and professional fees, business promotion expenses, the ld.CIT(A) has held that these are chargeable to tax in India and TDS was required to be deducted. Hence, this issue has been decided partly against the assessee. Be that as it may, we perused the record and impugned order

AMAZON TEXTILES PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(4),, AHMEDABAD

In the result, the appeal of the Revenue is dismissed due to low tax effect, whereas appeal of the assessee is dismissed due to non- prosecution

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.1406/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2013-2014

disallowance made under section 14A would be less than Rs.20 lakhs, and the appeal of the Revenue would not be maintainable in view of the recent CBDT circular restricting the filing of appeal by the Revenue before the Tribunal, where tax effective is below Rs.20 lakhs. On the other hand, the ld.DR is unable controvert this contention of the ld.counsel

THE INCOME TAX OFFICER, WARD-1(1)(4),, AHMEDABAD vs. AMAZON TEXTILES PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed due to low tax effect, whereas appeal of the assessee is dismissed due to non- prosecution

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.1406/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2013-2014

disallowance made under section 14A would be less than Rs.20 lakhs, and the appeal of the Revenue would not be maintainable in view of the recent CBDT circular restricting the filing of appeal by the Revenue before the Tribunal, where tax effective is below Rs.20 lakhs. On the other hand, the ld.DR is unable controvert this contention of the ld.counsel

DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1),, AHMEDABAD vs. SAGAR AGENCIES PVT.LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.1777/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2010-2011 Sagar Agencies Pvt. Ltd., D.C.I.T, 803 Sahjanand Complex, Circle-8, Vs. Shahi Baug, Ahmedabad. Ahmedabad-380004. Pan: Aadcs0473P आयकर अपील सं./Ita No.1832/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T, Sagar Agencies Pvt. Ltd., Circle-4(1)(1), 803 Sahjanand Complex, Vs. Shahi Baug, Ahmedabad. Ahmedabad-380004. Pan: Aadcs0473P

disallowance made u/s 14A of the Act. 5. On the facts and in the circumstances of the case, the Ld. Commissioner of Income-Tax (Appeals) ought to have upheld the order of the Assessing Officer. 6. It is therefore, prayed that the order of the Ld. Commissioner of Income-Tax (Appeals) may be set-a-side and that

SAGAR AGENCIES PVT.LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita No.1777/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2010-2011 Sagar Agencies Pvt. Ltd., D.C.I.T, 803 Sahjanand Complex, Circle-8, Vs. Shahi Baug, Ahmedabad. Ahmedabad-380004. Pan: Aadcs0473P आयकर अपील सं./Ita No.1832/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2010-2011 D.C.I.T, Sagar Agencies Pvt. Ltd., Circle-4(1)(1), 803 Sahjanand Complex, Vs. Shahi Baug, Ahmedabad. Ahmedabad-380004. Pan: Aadcs0473P

disallowance made u/s 14A of the Act. 5. On the facts and in the circumstances of the case, the Ld. Commissioner of Income-Tax (Appeals) ought to have upheld the order of the Assessing Officer. 6. It is therefore, prayed that the order of the Ld. Commissioner of Income-Tax (Appeals) may be set-a-side and that

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR vs. ADANI ENTERPRISES LIMITED, AHMEDABAD

In the result, appeal of the Revenue is dismissed due to low tax effect

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.264/Ahd/2024 िनधा"रण वष" /Assessment Year : 2018-19 The Acit Adani Enterprises Ltd. बनाम/ Circle-1 (1)(1) Adani Corporate House V/S. Ahmedabad Shantigram Near Vaishno Devi Circle S.G. Highway Khodiyar Ahmedabad- 382 421 (Gujarat) "थायी लेखा सं./Pan: Aabca 2804 L अपीलाथ&/ (Appellant) '( यथ&/ (Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Surendra Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 01/10/2024 घोषणा की तारीख /Date Of Pronouncement: 03/10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

disallowance of Rs.49,11,450/- under section 37 of the Act. The Revenue has raised the following grounds in this appeal: 1. Whether on the facts and in the circumstances of the case and in law, the Ld CIT(A) was justified in deleting the adjustment/addition of Rs. 1,12,17.629/- on account of the purchase of coal by violating

THE ACIT, CIRCLE-4,, BARODA vs. M/S. WELSPUN PROJECTS LTD.,(FORMERLY KNOWN AS MSK PROJECTS (INDIA) LTD.,), BARODA

In the result, appeals of Revenue are dismissed, whereas quantum appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2484 & 2485/Ahd/2014 "नधा"रण वष"/Asstt. Year: 2000-2001 Welspun Projects Ltd. (Formerly Vs. Acit, Cir.4 Known As Msk Projects Baroda. 707-708, Sterling Centre R.C.Dutta Road, Baroda 390 005. Pan : Aabcm 4107 C

section 268A of the Income Tax Act, we are of the view that the present appeals of the Revenue deserve to be dismissed. They are accordingly dismissed. However, it is observed that in case on re-verification at the end of the AO it comes to the notice that the tax effect is more or Revenue’s case falls within

WELSPUN PROJECTS LTD.(FORMERLY KNOWN AS MSK PROJECTS (INDIA) LTD.),BARODA vs. THE DY.CIT, CIRCLE-4,, BARODA

In the result, appeals of Revenue are dismissed, whereas quantum appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2484 & 2485/Ahd/2014 "नधा"रण वष"/Asstt. Year: 2000-2001 Welspun Projects Ltd. (Formerly Vs. Acit, Cir.4 Known As Msk Projects Baroda. 707-708, Sterling Centre R.C.Dutta Road, Baroda 390 005. Pan : Aabcm 4107 C

section 268A of the Income Tax Act, we are of the view that the present appeals of the Revenue deserve to be dismissed. They are accordingly dismissed. However, it is observed that in case on re-verification at the end of the AO it comes to the notice that the tax effect is more or Revenue’s case falls within

WELSPUN PROJECTS LTD.(FORMERLY KNOWN AS MSK PROJECTS (INDIA) LTD.),BARODA vs. THE ACIT, CIRCLE-4,, BARODA

In the result, appeals of Revenue are dismissed, whereas quantum appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2484 & 2485/Ahd/2014 "नधा"रण वष"/Asstt. Year: 2000-2001 Welspun Projects Ltd. (Formerly Vs. Acit, Cir.4 Known As Msk Projects Baroda. 707-708, Sterling Centre R.C.Dutta Road, Baroda 390 005. Pan : Aabcm 4107 C

section 268A of the Income Tax Act, we are of the view that the present appeals of the Revenue deserve to be dismissed. They are accordingly dismissed. However, it is observed that in case on re-verification at the end of the AO it comes to the notice that the tax effect is more or Revenue’s case falls within

THE ACIT, CIRCLE-4,, BARODA vs. M/S. WELSPUN PROJECTS LTD.,(FORMERLY KNOWN AS MSK PROJECTS (INDIA) LTD.,), BARODA

In the result, appeals of Revenue are dismissed, whereas quantum appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2484 & 2485/Ahd/2014 "नधा"रण वष"/Asstt. Year: 2000-2001 Welspun Projects Ltd. (Formerly Vs. Acit, Cir.4 Known As Msk Projects Baroda. 707-708, Sterling Centre R.C.Dutta Road, Baroda 390 005. Pan : Aabcm 4107 C

section 268A of the Income Tax Act, we are of the view that the present appeals of the Revenue deserve to be dismissed. They are accordingly dismissed. However, it is observed that in case on re-verification at the end of the AO it comes to the notice that the tax effect is more or Revenue’s case falls within

THE ACIT, CIRCLE-4,, BARODA vs. M/S. WELSPUN PROJECTS LTD.,(FORMERLY KNOWN AS MSK PROJECTS (INDIA) LTD.,), BARODA

In the result, appeals of Revenue are dismissed, whereas quantum appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No.2484 & 2485/Ahd/2014 "नधा"रण वष"/Asstt. Year: 2000-2001 Welspun Projects Ltd. (Formerly Vs. Acit, Cir.4 Known As Msk Projects Baroda. 707-708, Sterling Centre R.C.Dutta Road, Baroda 390 005. Pan : Aabcm 4107 C

section 268A of the Income Tax Act, we are of the view that the present appeals of the Revenue deserve to be dismissed. They are accordingly dismissed. However, it is observed that in case on re-verification at the end of the AO it comes to the notice that the tax effect is more or Revenue’s case falls within

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. HARIOM PROTIENS PVT. LTD., AHMEDABAD

In the result, appeal of the Revenue is dismissed due to low tax effect

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kedia"नधा"रण वष"/ Asstt. Year: 2012-13 Acit, Cir.2(1)(1) Hariom Proteins P.Ltd. Ahmedabad. 204, Rajlaxmi Plaza, Shahibag Rd. Vs. Ahmedabad. Pan : Aaacl 9508 P

disallowance of Rs.6,44,464/- with the aid of section 40(a)(ia) of the Income Tax Act for non-compliance of section 194A/194C on the payment of interest paid to certain parties. 4. We have gone through orders of the Revenue authorities. When we noticed from the order that quantum of disputed amount is Rs.6

M/S. RAMDEV PROFILE,,SABARKANTHA vs. THE INCOME TAX OFFICER, S.K. WARD-2,, HIMATNAGAR

In the result, the appeal of the Revenue is dismissed

Bench: The Ld. Cit(A). The Ld. Cit(A) Has Sustained The Disallowance Holding That Payment In Cash Was Not Covered In Any Of The Exceptions Provided In Rule 6Dd Of The It Rule.

disallowed. Thus, this ground of assessee is allowed. Respectfully following the decision of the coordinate bench and considering the undisputed fact that no banking facility was available at the location of the assessee, we are not inclined with the finding of ld. CIT(A), therefore, the appeal of the assessee on this issue is allowed. 7. The other two grounds

ITO, S.K.WARD-2,, HIMATNAGAR vs. M/S. RAMDEV PROFILES,, SABARKANTHA

In the result, the appeal of the Revenue is dismissed

Bench: The Ld. Cit(A). The Ld. Cit(A) Has Sustained The Disallowance Holding That Payment In Cash Was Not Covered In Any Of The Exceptions Provided In Rule 6Dd Of The It Rule.

disallowed. Thus, this ground of assessee is allowed. Respectfully following the decision of the coordinate bench and considering the undisputed fact that no banking facility was available at the location of the assessee, we are not inclined with the finding of ld. CIT(A), therefore, the appeal of the assessee on this issue is allowed. 7. The other two grounds

THE DY. CIT, CIRCLE-1(3),, BARODA vs. M/S. FINE LINE CIRCUIT COMPANY,, VADODARA

In the result, the appeal of the revenue is dismissed

section 268A of the Income Tax Act, we are of the view that the present appeal of the Revenue deserves to be dismissed. It is accordingly dismissed. 7. In addition to it on merit also, the assessee has clearly disclosed all the particulars in respect of their claim of deduction u/s. 10B of the act of deemed sale vide note