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

50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

50,439/- Add: Additions / disallowances as discussed above 1. Transfer pricing Rs. 89,20,39,641 (as per Para No. 3.1) 2. Product Registration Expenses (-) Rs. 20,08,34,851 depreciation on the above (as per Para No. 4.7) 3. Trade Mark Registration fee & Rs. 14,14,36,698 Patent Fee (as per Para No. 5.6) 4. Research & Development

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

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 :

section 143(3) of the Act. The AO made certain disallowances and additions in the ITA No.1772/Ahd/2015 and other 8 appeals Ambalal Sarabhai Enterprises Ltd. vs. ACIT-DCIT (by Assessee and Revenue) Asst. Years : 2002-03 to 2007-08 3 income of the assessee for the respective A.Y.s. The details of the returns filed, and assessment completed are tabulated below

SANGATH INFRASTRUCTURE PVT. LTD,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance of such expenditure shall be made under the proposed sub-section (3) of section 40A or the payment shall be deemed to be the profits and gains of business or profession under the proposed sub-section (3A) of section 40A,as the case may be. EXCEPTION TO ABOVE PROVISION: The provisions of this section are subject to exceptions

RAMCHAND BHULCHAND RAJAI,BHAVNAGAR vs. THE DY.CIT.,CIRCLE-1, , BHAVNAGAR

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarआयकर अपील सं / Ita No. 167/Ahd/2024 िनधा"रण वष"/Assessment Year : 2009-10 बनाम बनाम बनाम बनाम Ramchand Bhulchand Rajai, The Deputy Commissioner C/O. Jayesh Tyres, Vs. Of Income-Tax, Opp. Railway Station, Circle-1, Bhavnagar Bhavnagar-364001 Pan : Abmpr 4841 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) िनधा"रती की ओर से / Assessee By : Shri B.R. Popat, Ar ""थ" की ओर से / Revenue By: Shri Prateek Sharma, Sr Dr सुनवाई की तारीख /Date Of Hearing : 22/04/2024 घोषणा की तारीख /Date Of Pronouncement: 15/07/2024 आदेश/O R D E R Per Annapurna Gupta

3) of the Act is not sustainable and we direct deletion of the same. Ramchand Bhulchand Rajai Vs. DCIT AY : 2009-10 12 17. We regard to the addition made by disallowing loading and unloading expenses, the contention made by the assessee before the ld. CIT(A) is as under:- “2.2.1 In so far as the penalty levied in respect

SHITAL VIPULKUMAR DHOLAKIA,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

In the result, the appeal filed by the assessee is allowed for statistical\npurposes

section 40A(3) lay on the Revenue, and\nthe same had not been discharged. Mere suspicion, however strong, cannot\nsubstitute for evidence, and therefore, the disallowance based solely on\npresumptions deserves to be struck down.\n2.10 The AR submitted that the purchases made from the three parties,\nnamely, Shree Laxmi Gold, Shri Parvati Gold, and Dhanadeepa Gold, were\nduly supported

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 was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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 was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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

3) of the Income Tax Act. The tax auditor had not reported these expenses as personal or non-genuine in the tax audit report, implying their ITA Nos.661/Ahd/2023 (By Assessee), 732 & 807/Ahd/2023 (By Revenue) Oriental Enterprise Pvt.Ltd. vs. ACIT Asst. Years : 2016-17 & 2018-19 acceptance as business expenses. The assessee maintained that the expenses on gifts and entertainment were