THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., 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

1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill 2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), VADODARA, VADODARA vs. ORIENTAL ENTERPRISES PRIVATE LIMITED, PCC NOTIFIED AREA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

Sections 41(1) and 37(1) of the Act. This contradictory approach further undermined the AO's position. The Ld.CIT(A) further emphasized the need for judicial consistency and adherence to established legal principles. Disallowances

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 2(1)(1), VADODARA, VADODARA vs. ORIENTAL ENTERPRISES PRIVATE LIMITED,, PCC NOTIFIED AREA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

Sections 41(1) and 37(1) of the Act. This contradictory approach further undermined the AO's position. The Ld.CIT(A) further emphasized the need for judicial consistency and adherence to established legal principles. Disallowances

ORIENTAL ENTERPRISE PRIVATE LIMITED,VADODARA vs. THE ACIT, CIRCLE-2(1)(2), VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

Sections 41(1) and 37(1) of the Act. This contradictory approach further undermined the AO's position. The Ld.CIT(A) further emphasized the need for judicial consistency and adherence to established legal principles. Disallowances

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

disallowance made under section 40(a)(i) on account of non- deduction of tax was deleted. Reliance was also placed on the decision of the Agra Bench in Metro & Metro v. ACIT [ITA No. 393/Agra/2012], where payments for leather testing services to a German entity were held to be not taxable in India either under the Act or under Article

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A of the Act can be made for that year. Such an interpretation is not in line with the intention of the Legislature. To illustrate, if during a previous year, an assessee incurs an expense of Rs. 1 lakh to earn non-exempt income of Rs. 1.5 lakh and also incurs an expense

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

1,73,278/-\nwas confirmed. Accordingly, the total disallowance sustained was Rs.\n7,81,819/-.\n10. On 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 not be added while

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

41 to 43 which reads as under: ITA No.144 to 146/Ahd/2023 10. Referring to the same, he pointed out that the reopening was resorted to for the reason that the assessee’s claim for provision for bad and doubtful debts under section 36(1)(viia) of the Act was found to have not been computed correctly. He pointed out that

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

41 to 43 which reads as under: ITA No.144 to 146/Ahd/2023 10. Referring to the same, he pointed out that the reopening was resorted to for the reason that the assessee’s claim for provision for bad and doubtful debts under section 36(1)(viia) of the Act was found to have not been computed correctly. He pointed out that

THE MEHSANA URBAN CO. OPERATIVE BANK LTD.,MEHSANA vs. THE ACIT, MEHSANA CIRCLE , MEHSANA

In the result, the appeal of the assessee in ITANo

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

41 to 43 which reads as under: ITA No.144 to 146/Ahd/2023 10. Referring to the same, he pointed out that the reopening was resorted to for the reason that the assessee’s claim for provision for bad and doubtful debts under section 36(1)(viia) of the Act was found to have not been computed correctly. He pointed out that

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHAI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground of the assessee is dismissed. Ground related to Disallowance of PF Damages under Section 14B of the PF Act 12. The assessee challenges the disallowance of damages paid under Section 14B of the PF Act, which were levied