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

disallowance of claim of depreciation of Goodwill without appreciating that goodwill is self- acquired asset, the actual cost of which in the hands of the amalgamated company is Nil, therefore, after amalgamation, the WDV of the same has also to be taken at NIL in the hands of the assessee company, in view of Explanation 2B to section 43(6

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

43(6)(c), (iv) Section 55(2)(a)(ii) and (v) Section 49(1)(iii)(e) relied upon by the Assessing Officer for disallowing

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

43,616/- under section 14A of the Act read with Rule 8D(2)(iii), and further in increasing the book profits under section 115JB of the Act by the said amount. It is the contention of the assessee that it had already made a suo motu disallowance of Rs.8,25,900/- in the return of income, based on a scientific

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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

Disallowance of Depreciation on Goodwill in pursuant to explanation to section 32(1), 43(1) and 43(6)to the tune

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

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount considering

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,,AHMEDABAD vs. THE ASST.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD

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

6,71,43,809/- NIL NIL NIL Bad Debts Decision of Deleted the NA NA NA CIT(A) disallowance 4. Aggrieved by the orders of CIT(A), both assessee and revenue are in appeal against the orders of CIT(A) with following grounds of appeal: A.Y. 2012-13 - Assessee’s Grounds in ITA No.960/Ahd/2016 1.1 The order passed u/s.250

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

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

6,71,43,809/- NIL NIL NIL Bad Debts Decision of Deleted the NA NA NA CIT(A) disallowance 4. Aggrieved by the orders of CIT(A), both assessee and revenue are in appeal against the orders of CIT(A) with following grounds of appeal: A.Y. 2012-13 - Assessee’s Grounds in ITA No.960/Ahd/2016 1.1 The order passed u/s.250

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

6,71,43,809/- NIL NIL NIL Bad Debts Decision of Deleted the NA NA NA CIT(A) disallowance 4. Aggrieved by the orders of CIT(A), both assessee and revenue are in appeal against the orders of CIT(A) with following grounds of appeal: A.Y. 2012-13 - Assessee’s Grounds in ITA No.960/Ahd/2016 1.1 The order passed u/s.250

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

6,71,43,809/- NIL NIL NIL Bad Debts Decision of Deleted the NA NA NA CIT(A) disallowance 4. Aggrieved by the orders of CIT(A), both assessee and revenue are in appeal against the orders of CIT(A) with following grounds of appeal: A.Y. 2012-13 - Assessee’s Grounds in ITA No.960/Ahd/2016 1.1 The order passed u/s.250

THE DY.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,, AHMEDABAD

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

6,71,43,809/- NIL NIL NIL Bad Debts Decision of Deleted the NA NA NA CIT(A) disallowance 4. Aggrieved by the orders of CIT(A), both assessee and revenue are in appeal against the orders of CIT(A) with following grounds of appeal: A.Y. 2012-13 - Assessee’s Grounds in ITA No.960/Ahd/2016 1.1 The order passed u/s.250

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

section 43(6), asserting that the cost or WDV in the hands of the amalgamating company should be taken as nil. We find that these provisions apply to tangible assets transferred in amalgamation, not to newly recognised intangible assets like goodwill which arises as a balancing figure under a recognised accounting method. The CIT(A) has dealt with these statutory

GUJARAT URJA VIKAS NIGAM LIMITED,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-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: Smt. Annapurna Gupta & Ms. Madhumita Roy

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount considering

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, 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: Smt. Annapurna Gupta & Ms. Madhumita Roy

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount considering

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

43(3) of the Act, assessing total income to Rs.3,42,96,135/-. The assessee preferred an appeal before Ld.CIT(A), who partly allowed the appeal of the assessee. The summary of additions and decision of the Ld.CIT(A) is tabulated as follows: Sr Particulars of Amount of Relief granted by Who is in disallowance / addition/ CIT(A) appeal addition

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

43(3) of the Act, assessing total income to Rs.3,42,96,135/-. The assessee preferred an appeal before Ld.CIT(A), who partly allowed the appeal of the assessee. The summary of additions and decision of the Ld.CIT(A) is tabulated as follows: Sr Particulars of Amount of Relief granted by Who is in disallowance / addition/ CIT(A) appeal addition