THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section !4A disallowance of Rs. 137,53,16,0061- under both general and ', MAT provisions. (3) The ld. CIT('A) has erred

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section !4A disallowance of Rs. 137,53,16,0061- under both general and ', MAT provisions. (3) The ld. CIT('A) has erred

SHRI DINESH MILLS LTD.,BARODA vs. THE ACIT, CIRCLE -2(1)(1), BARODA

In the result, the appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

section 36 1(iii) of the Act. 34. At the outset we note that the impugned issue has already been restored back to the file of the AO for fresh adjudication as per the provision of law in its own case pertaining to the assessment year 2012- 13 in ITA No. 781/AHD/2016. Please refer the relevant paragraph bearing number

SHRI MAHUDI MADHUPURI JAIN NSM BHOJANSHALA & PRASHADI BHAVAN,,MAHUDI vs. THE INCOME TAX OFFICER,WARD-2, EXEMPTION,, AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

disallowance of exemption u/s.11 of the Act was correctly made. 6. We have carefully considered the rival submissions. The provision of Section 12A of the Act stipulates that the provision of section 11 & ITA No.184/Ahd/2024 (Shri Mahudi Madhupuri Jain NSM Bhojanshala& Prashadi Bhavan vs. ITO) A.Y.– 2020-21- 4 – section 12 of the Act will not be applicable in relation

THE DCIT, CIRCLE-1,, AHMEDABAD vs. AIA ENGINEERING LTD.,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

AIA ENGINEERING LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

NIRMA CHEMICAL WORKS PVT.LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

NIRMA CHEMICALS WORKS PVT.LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

NIRMA CHEMICALS WORKS PVT.LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4A of the I.T. Act. 13. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of interest expenses of Rs.2,05,49,614/- u/s.36(l)(III) of the I.T, Act, 14. The Ld. Commissioner of Income tax (A) has erred in law and on facts in deleting the disallowance of business

THE DCIT,GANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. GUJARAT STATE PETRONET LTD., GANDHINAGAR

In the result appeal of the Revenue is partly allowed for the statistical purposes

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 272-273/Ahd/2020 िनधा"रण वष"/Asstt. Years: 2014-2015 & 2015-16 D.C.I.T, M/S. Gujarat State Petronet Ltd., Gnr Circle. Vs. Plot No.E-18, Jamnagar Gidc Electronics Estate, Sector-26, Gandhinagar.

disallowance u/s.!4A applying Rule 8D amounting to Rs. 1,51,46,813/- . 2. Whether the Id.CIT(A) has erred in law and on facts in allowing depreciation of Rs.30,90,866/- on WDV of certain Administrative Expenses capitalized in earlier years. 3. Whether the Id.CIT(A) has erred in law and on facts in allowing ESOP Compensation Expenses

THE DCIT,GANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. GUJARAT STATE PETRONET LTD., GANDHINAGAR

In the result appeal of the Revenue is partly allowed for the statistical purposes

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 272-273/Ahd/2020 िनधा"रण वष"/Asstt. Years: 2014-2015 & 2015-16 D.C.I.T, M/S. Gujarat State Petronet Ltd., Gnr Circle. Vs. Plot No.E-18, Jamnagar Gidc Electronics Estate, Sector-26, Gandhinagar.

disallowance u/s.!4A applying Rule 8D amounting to Rs. 1,51,46,813/- . 2. Whether the Id.CIT(A) has erred in law and on facts in allowing depreciation of Rs.30,90,866/- on WDV of certain Administrative Expenses capitalized in earlier years. 3. Whether the Id.CIT(A) has erred in law and on facts in allowing ESOP Compensation Expenses

SHRI PRAVINCHANDRA R PATEL,VADODARA vs. DCIT, CENTRAL CIRCLE-2, VADODARA

4A) of the Act refers to the books of accounts inter-alia, found during the course of search that these belongs to the assessee and the contents of such books of accounts are true. It does not deal with respect to the loose paper found during the course of search. Accordingly, there cannot be any inference against the assessee based

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

4A) of the Act refers to the books of accounts inter-alia, found during the course of search that these belongs to the assessee and the contents of such books of accounts are true. It does not deal with respect to the loose paper found during the course of search. Accordingly, there cannot be any inference against the assessee based

DCIT, CENTRAL CIRCLE-2, VADODARA vs. NEOTECH EDUCATION FOUNDATION, VADODARA

4A) of the Act refers to the books of accounts inter-alia, found during the course of search that these belongs to the assessee and the contents of such books of accounts are true. It does not deal with respect to the loose paper found during the course of search. Accordingly, there cannot be any inference against the assessee based

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

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

4A read with rule 8D, without appreciating that: ITA Nos.922 & 1234/Ahd/2017 (By Revenue) and ITA Nos.929 & 1237/Ahd/2017 (By Assessee) DCIT vs. Sun Pharmaceuticals Inds.Ltd.vs. DCIT Asst.Years – 2010-11 & 2012-13 1 The income earned by the appellant on its investment in partnership firm was not exempt andhence was not to be considered for disallowance under section