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

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

1% of the average value of investments at Rs.8,34,69,516/-, and after reducing the amount already disallowed suo motu by the assessee, made a net disallowance of Rs.8,26,43,616/-. This amount was also added back to the book profits under section 115JB while computing minimum alternate tax. 10. The DRP, in its directions, upheld

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

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

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

1,73,278/-.\n8. The total disallowance thus worked out to Rs. 9,33,104/-, which was\nadded to the total income. The AO further made a similar adjustment to the\nbook profits computed under section 115JB.\n9. Before the CIT(A), the assessee submitted that certain interest\nexpenses considered by the AO under Rule 8D(2)(ii) pertained

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

1 of the Revenue’s appeal for A.Y. 2016-17 is dismissed. 13. Ground No. 2:- Treatment of interest income from staff loans and advances of Rs.33.36 lacs, interest income from other loans and advances of Rs. 33.23 lacs and miscellaneous income of Rs. 9.46 lacs. 14. The interest income from staff loans and advances of Rs. 33.36 lakhs under

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

1)\ndated 12.06.2015 as to why disallowance under section 14A read with Rule\n8D should not be made, considering the nature of investments and exempt\nincome earned therefrom. In response, the assessee submitted details of\nnon-current investments and ledger accounts but did not furnish specific\ndetails of current investments or evidence demonstrating that such\ninvestments were made entirely

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:-

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. 52. We have considered the objections raised by the Departmental Representative regarding the computation and recognition of goodwill

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

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 :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015