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

d) That in the facts and circumstances of the case, the learned CIT(A) has failed to appreciate that the appellant company does not charge any interest on outstanding receivables from, both AEs and non-AEs and therefore adjustment made by AO/TPO by imputing interest on such receivables from AEs should be deleted. ITA No.281 and 222/Ahd/2021 5 e) Assuming

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

d) That in the facts and circumstances of the case, the learned CIT(A) has failed to appreciate that the appellant company does not charge any interest on outstanding receivables from, both AEs and non-AEs and therefore adjustment made by AO/TPO by imputing interest on such receivables from AEs should be deleted. ITA No.281 and 222/Ahd/2021 5 e) Assuming

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

d): Disallowance under section 14A r.w. Rule 8D and addition to book profits under section 115JB 8. The assessee has challenged the action of the Assessing Officer and the DRP in making a disallowance of Rs.8,26,43,616/- under section 14A of the Act read with Rule 8D(2)(iii), and further in increasing the book profits under section

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)

d] No Disallowance u/s. 14A of the Act while computing income under section 115JB of the Act. Assessee submitted the title itself suggest the section provides for disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between

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)

d] No Disallowance u/s. 14A of the Act while computing income under section 115JB of the Act. Assessee submitted the title itself suggest the section provides for disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between

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)

d] No Disallowance u/s. 14A of the Act while computing income under section 115JB of the Act. Assessee submitted the title itself suggest the section provides for disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between

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)

d] No Disallowance u/s. 14A of the Act while computing income under section 115JB of the Act. Assessee submitted the title itself suggest the section provides for disallowance of expenses to be made while computing TOTAL INCOME. It is pertinent to note that u/s. 115JB, total income is not computed but BOOK PROFIT is computed and comparison is made between

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

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

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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

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

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

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 :

D E R PER BENCH The assessee and the revenue have both appealed (9 appeals) against the separate orders passed by the Commissioner of Income Tax (Appeals) - 1, Vadodara [hereinafter referred to as “CIT(A)”] for different assessment years, i.e. 2002-03 to 2007-08 [hereinafter referred to as “A.Y.”]. The issues in dispute pertain to various additions, disallowances made

GUJARAT URJA VIKAS NIGAM LTD,VADODARA vs. THE ACIT, CIRECLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed for statistical purposes and the appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5. The assessee being aggrieved by the addition made by the Assessing Officer under Section 14A while computing book profit of the assessee under Section 115JB of the Act, 1961 ITA Nos.318&414/Ahd/2020 Gujarat Urja Vikas Nigam Ltd. vs. ACIT/DCIT Asst.Year– 2016-17 preferred an appeal before the CIT(A). The CIT(A), however, deleted addition made in the book

ACIT, CIRCLE-1(1)(1), AHMEDABAD, VEJALPUR, AHMEDABAD vs. AIA ENGINEERING LIMITED, AHMEDABAD

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 397/Ahd/2024 िनधा"रण वष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Dcit Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J आयकर अपील सं / Ita No. 532/Ahd/2024 िनधा"रणवष"/Assessment Year: 2016-17 बनाम Aia Engineering Limited, Acit, Vs. 115, Gvmm Estate, Odhav Road, Circle-1(1)(1), Odhav, Ahmedabad-382415 Ahmedabad Pan : Aabca 2777 J अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" िनधा"रती की ओर से / Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar ""थ" की ओर से / Revenue By : Shri Pratik Sharma, Sr Dr & Shri Sudhendu Das, Cit-Dr तारीख/Date Of Hearing : 09.10.2024 सुनवाई क" क" तारीख सुनवाई सुनवाई सुनवाई क" क" तारीख तारीख घोषणा क" क" तारीख तारीख /Date Of Pronouncement: 21.10.2024 घोषणा घोषणा घोषणा क" क" तारीख तारीख आदेश आदेश/O R D E R आदेश आदेश

5. The Ld. CIT(A) has erred in law and on facts of the case in confirming action of Ld. AO in levying penalty u/s. 271(1)(c) of the Act.” 10. The solitary issue in the present appeal relates to the disallowance of depreciation claimed by the assessee on goodwill. The contention of the ld. Counsel for the assessee