VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

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

274 (Supreme Court), held that section 10A of the Act is a “deduction provision” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

JT.CIT(E), CIRCLE-2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

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

274 (Supreme Court), held that section 10A of the Act is a “deduction provision” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

JT.CIT(EXEMPTION)CIRCL-2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY, VADODARA

In the result, the appeal of the Department is dismissed

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

274 (Supreme Court), held that section 10A of the Act is a “deduction provision” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

JT.CIT(E),CIRCLE -2 AHMEDABAD, AHMEDABAD vs. VADODARA URBAN DEVELOPMENT AUTHORITY , VADODARA

In the result, the appeal of the Department is dismissed

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

274 (Supreme Court), held that section 10A of the Act is a “deduction provision” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

VADODARA URBAN DEVELOPMENT AUTHORITY,VADODARA vs. THE ACIT, CIRCLE-2 (EXEMP), AHMEDABAD

In the result, the appeal of the Department is dismissed

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

274 (Supreme Court), held that section 10A of the Act is a “deduction provision” and not an “exemption provision”. Therefore, apparently there seems to be a difference of opinion to whether section 10A/B provisions qualify as “Exemption” or Deduction” provisions. Therefore, since it is well-settled principle of law that deduction provisions, which have been introduced in the Statute

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

disallowance computed under\nsection 14A could not be added while computing book profit under section\n115JB, since there is no specific provision in the Act permitting such an\nadjustment. The addition under section 115JB was therefore deleted by the\nCIT(A).\nΑ.Υ. 2014-15\n11. The assessee earned exempt income of Rs. 49,98,203/- as share of\nprofit

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

Appeals are partly allowed for\nstatistical reasons

2)(iii) of Rs.1,73,278/-\nwas confirmed. Accordingly, the total disallowance sustained was Rs.\n7,81,819/-.\n10.\nOn the issue of adjustment to book profit under section 115JB, the\nCIT(A) followed the Special Bench decision in ACIT v. Vireet Investment (P.)\nLtd. [165 ITD 27 (Del) (SB)] and held that disallowance computed under\nsection 14A could

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

Appeals are partly allowed for\nstatistical reasons

2)(iii) of Rs.1,73,278/-\nwas confirmed. Accordingly, the total disallowance sustained was Rs.\n7,81,819/-.\n10.\nOn the issue of adjustment to book profit under section 115JB, the\nCIT(A) followed the Special Bench decision in ACIT v. Vireet Investment (P.)\nLtd. [165 ITD 27 (Del) (SB)] and held that disallowance computed under\nsection 14A could

GUJARAT STATE FINANCIAL SERVICES LTD.,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed in part

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2020-21

disallowance of Rs.1,78,71,274/- in respect of donation claimed as deduction under Section 80G of the Income Tax Act, 1961 (hereinafter A.Y. 2020-21 Gujarat State Financial Services Ltd. vs. DCIT Page 2

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

section 14A 3. On the facts and in the circumstances of the case and in law, the ld CIT(A) has erred in deleting the disallowance u/s 14A of Rs 1,80,634/- out of total disallowance of Rs 2,12,799/- despite the IT(SS)A No. 27 to 30/Ahd/2021 and 14/Ahd/2022 A.Ys. 2006-07 to 2010-11 DCIT

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

Disallowance of 864686 293907 881721 expenditure on repairs treating them as capital expenditure Total 14664117 43992351 A. Provisions u/s.115JB Tax Tax sought Sr. Particulars of additions Amount sought to to be No. made involved be evaded evaded Rs. Rs. Rs. @300% @100% 1. Provisions for doubtful 9471966 1073174 3219522 debts & advances 2. Deduction of 574950297 65141869 195425607 remuneration received from

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

Disallowance of 864686 293907 881721 expenditure on repairs treating them as capital expenditure Total 14664117 43992351 A. Provisions u/s.115JB Tax Tax sought Sr. Particulars of additions Amount sought to to be No. made involved be evaded evaded Rs. Rs. Rs. @300% @100% 1. Provisions for doubtful 9471966 1073174 3219522 debts & advances 2. Deduction of 574950297 65141869 195425607 remuneration received from

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD, VADODARA

In the result, the appeal filed by the Assessee in ITA No

Disallowance of expenditure on repairs treating them as capital expenditure | 864686 | 293907 | 881721 |\n| | Total | | 14664117 | 43992351 |\n\nA. Provisions u/s.115JB\n\n| Sr. No. | Particulars of additions made | Amount involved Rs. | Tax sought to be evaded Rs. @100% | Tax sought to be evaded Rs. @300% |\n|---|---|---|---|---|\n| 1. | Provisions for doubtful debts & advances | 9471966 | 1073174 | 3219522 |\n| 2. | Deduction

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

disallowing the claim made by the Appellant on account of refund of excess DDT paid during the year without appreciating the law in proper perspective. Other Grounds: 10) The learned CIT(A) erred in fact and in law in confirming the action of the AO in charging interest u/s 234A of the Act. 11) The learned CIT(A) erred