Search: disallowance

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

section 44 of the Act and the allowance of expenses as per PSC would amount to double reimbursement to HO. 7.6 Without prejudice to the above, the Ld. AO/TPO failed to appreciate that out of the total HO expenditure of Rs. 555,31,914/ only Rs. 226,13,981/- could be claimed due to restrictions u/s 44C

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 80/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

Section 143(3)Section 32Section 80I

section 44 of the Act and the allowance of expenses as per PSC would amount to double reimbursement to HO. 7.6 Without prejudice to the above, the Ld. AO/TPO failed to appreciate that out of the total HO expenditure of Rs. 555,31,914/ only Rs. 226,13,981/- could be claimed due to restrictions u/s 44C

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

ITA 244/AHD/2022[2019-20]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R

Section 143(3)Section 32Section 80I

section 44 of the Act and the allowance of expenses as per PSC would amount to double reimbursement to HO. 7.6 Without prejudice to the above, the Ld. AO/TPO failed to appreciate that out of the total HO expenditure of Rs. 555,31,914/ only Rs. 226,13,981/- could be claimed due to restrictions u/s 44C

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

ITA 702/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad08 Apr 2021AY 2011-12

For Appellant: Shri S.N. Soparkar, Sr. A.RFor Respondent: Shri Mohd Usman, CIT-D.R

Section 115JSection 143(2)Section 143(3)Section 144CSection 144C(5)Section 37(1)Section 92C

disallowed. 10.2.3.2 Considering the above facts and circumstances of the case, the assesses was asked during assessment proceedings various queries relating to its claim u/s 801B/IC of the 1. T. Act, 1961. 10.3.0 The assessee was asked to justify the following during the course of assessment proceedings: i. Justification of claim u/s. 80IB/IC ii. Details of products manufactured u/s. 80IB/1C

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

ITA 2813/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad27 Mar 2019AY 2011-12

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

For Appellant: Shri

Section 36Section 40

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

ITA 2814/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad27 Mar 2019AY 2012-13

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

For Appellant: Shri

Section 36Section 40

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure

THE DCIT ( INTERNATIONAL TAXATION ),, AHMEDABAD vs. BLACK PEARL SERVICES LIMITED, G.S.E.C. LTD., AHMEDABAD

Appeal of the Revenue is dismissed

ITA 2815/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad27 Mar 2019AY 2013-14

Bench: Shri Waseem Ahmed & Shri Ms Madhumita Royआयकर अपील सं./Ita Nos. 2813-2815/Ahd/2017 "नधा"रण वष"/Asstt. Years: 2011-2012 To 2013-14 The D.C.I.T, Black Pearl Services Limited, (International Taxation), Vs. 2Nd Floor, Gujarat Chamber Of Ahmedabad Commerce Building, ‘’Sangram.’’ Ashram Road, Ahmedabad. Pan: Aaecb1176H

For Appellant: Shri

Section 36Section 40

44C. Notwithstanding anything to the contrary contained in sections 28 to 43A, in the case of an assessee, being a non-resident, no allowance shall be made, in computing the income chargeable under the head “Profits and gains of business or profession”, in respect of so much of the expenditure in the nature of head office expenditure