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

disallowable sum. A breakdown of the allocation across expenditure heads was provided and it included the following items: Amount Sr. Description No. (Rs.) Sitting fees to members of Investment 56,000 1 Committee 2 Sitting fees of Board of Directors 36,800 Salary Cost – various departments 3 7,04,931 (proportionate) 4 Conveyance and Fuel

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

disallowed by the Ld. AO the same was subsequently allowed by the Ld. CIT(A) on the basis of the order passed by the Coordinate Bench in assessee’s own case. In this respect, the assessee further relied upon the judgment passed in the matter of Dakshin Gujarat ITA Nos.318&414/Ahd/2020 Gujarat Urja Vikas Nigam Ltd. vs. ACIT/DCIT Asst.Year

DCIT, CIR-3(1)(2), AHMEDABAD vs. M/S. OZONE INDIA LTD, AHMEDABAD

In the result, the appeal of the revenue as well as cross objection of the Assessee is dismissed

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kedia

56(2)(viib) of the Act on account of difference of net asset value of Rs.54,21,16,156/- credited in the books without appreciating the factual backdrop of the case in which the addition was made by the Assessing Officer. (b) The Ld.CIT(A) has erred in law and on facts in not appreciating the fair market value

GUJARAT APOLLO INDUSTRIES LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms.Annapurna Gupta & T.R. Senthil Kumarasstt.Year : 2014-15 The Dcit, Cir.2(1)(1) Gujarat Apollo Industries Ltd. Ahmedabad. ‘Apollo House’ Rashmi Society Nr.Mithakhali Six Roads Navrangpura Ahmedabad 380 009. Pan : Aaacg 7248 P

56,98,44,760/- under normal provision of the Act and Rs.66,87,64,960/- under section 115JB of the Act. The return was processed under section 143(1) of the Act, the case of the assessee was selected for scrutiny assessment. During the assessment proceedings, it was noticed by the AO that the assessee has paid payment of commission

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

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

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

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

disallowances under the head "business income" should not result in denial of deduction on the enhanced income. The Revenue has not challenged this working, nor has it shown that any portion of depreciation relating to the Sikkim unit was ineligible. ITA No.281 and 222/Ahd/2021 31 52. We have considered the objections raised by the Departmental Representative regarding the computation

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

disallowances under the head "business income" should not result in denial of deduction on the enhanced income. The Revenue has not challenged this working, nor has it shown that any portion of depreciation relating to the Sikkim unit was ineligible. ITA No.281 and 222/Ahd/2021 31 52. We have considered the objections raised by the Departmental Representative regarding the computation

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LIMITED, AHMEDABAD

56. The first objection raised by the assessee vide ground nos. 1 & 2 is that the learned CIT(A) erred in sustaining the disallowance of deduction under section

THE ACIT, CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. TORRENT POWER LTD.,, AHMEDABAD

56. The first objection raised by the assessee vide ground nos. 1 & 2 is that the learned CIT(A) erred in sustaining the disallowance of deduction under section

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2009-10 Dcit, M/S. Adani Enterprises Ltd., Circle 1(1)(1), Vs Adani House, Nr. Mithakhali Ahmedabad Six Roads, Navrangpura, Ahmedabad - 380009 Pan : Aabca 2804 L अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Mohd. Usman, Cit-Dr Assessee By : Shri Vartik Choksi, Ar & Shri Biren Shah, Ar सुनवाई क" तार"ख/Date Of Hearing : 11/05/2022 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2022

disallowance under Section 14A is deleted. DCIT Vs.Adani Enterprises Ltd AY : 2009-10 7 In the result, the entire levy of penalty under Section 271(1)(c) of the Act for Rs.7,56

PARASMANI GEMS PVT. LTD.,AHMEDABAD vs. THE DCIT, CIR-3(1)(1),, AHMEDABAD

In the result, the appeal filed by the assessee is dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 2263/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2013-14) बनाम/ Parasmani Gems Pvt. Ltd. The D.C.I.T. 2, Supan Complex, Nr. Circle 3(1)(1), Vs. Dharnidhar Derasar, Paldi, Ahmedabad Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcp6337M (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Mehul K Patel, Ar ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr Date Of Hearing 23/10/2024 21/11/2024 Date Of Pronouncement

Section 56(2)(viib) of the Act as the machinery provision to work out the disallowance fails in the absence

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance made under section 40(a)(i) of the Act to the tune of Rs.30,68,538/- pertaining to legal and professional services rendered from entities based in USA. Ground no.5 of appeal is accordingly dismissed. 56

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance made under section 40(a)(i) of the Act to the tune of Rs.30,68,538/- pertaining to legal and professional services rendered from entities based in USA. Ground no.5 of appeal is accordingly dismissed. 56

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance made under section 40(a)(i) of the Act to the tune of Rs.30,68,538/- pertaining to legal and professional services rendered from entities based in USA. Ground no.5 of appeal is accordingly dismissed. 56

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeals of the Revenue are dismissed and that of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal

disallowance made under section 40(a)(i) of the Act to the tune of Rs.30,68,538/- pertaining to legal and professional services rendered from entities based in USA. Ground no.5 of appeal is accordingly dismissed. 56