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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period

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

x B C A = Amount of interest, other than the amount of interest which is directly attributable to the exempt income stated in (a) above. B = The average of value of investment, income from which does not or shall not form part of the total income, as appearing in the balance sheet of the assessee, on the first

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

56 taxmann.com 456 (SC) 2. CIT vs. Neha Builders (P) LTD. [2007] 164 Taxman 342 (Guj.) . 3. Radha Devi Dalmia Vs. CIT [1980] 4 taxman 183 (All.) 16. The Ld. CIT (A) after considering facts in totality deleted the addition made by the AO by following the order of its predecessor in the own case of the assessee

THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

56 taxmann.com 456 (SC) 2. CIT vs. Neha Builders (P) LTD. [2007] 164 Taxman 342 (Guj.) . 3. Radha Devi Dalmia Vs. CIT [1980] 4 taxman 183 (All.) 16. The Ld. CIT (A) after considering facts in totality deleted the addition made by the AO by following the order of its predecessor in the own case of the assessee

DHANLAXMI CREDIT CO. OP. SOCIETY LTD.,MEHSANA vs. THE ITO, WARD-2, PATAN

In the result, Ground Number 3 of the appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

56,732/- to the total income of the assessee. 4. In appeal, Ld. CIT(Appeals) confirmed the additions made by the assessing officer. Ground Number 1: Ld. CIT(Appeals) erred in confirming the disallowance of section 80P(2)(d) of the Act in respect of interest received from cooperative banks: 5. We are of the considered view that this controversy

ANUPAM INDUSTRIES LIMITED,ANAND vs. THE ACIT, ANAND CIRCLE, ANAND

The appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

56,35,105/- for A.Y. 2022-23. During assessment proceedings, after examining the information filed, the Assessing Officer passed an order under section 143(3) r.w.s. 144B determining the total income at Nil and reducing the returned loss to Rs. 5,18,07,905/-. This reduction was due to an addition of Rs. 5,59,39,900/-, being

ANUPAM INDUSTRIES LIMITED,ANAND vs. THE ACIT, ANAND CIRCLE, ANAND

The appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

56,35,105/- for A.Y. 2022-23. During assessment proceedings, after examining the information filed, the Assessing Officer passed an order under section 143(3) r.w.s. 144B determining the total income at Nil and reducing the returned loss to Rs. 5,18,07,905/-. This reduction was due to an addition of Rs. 5,59,39,900/-, being

ANUPAM INDUSTRIES LIMITED,ANAND vs. THE ACIT, ANANAD CIRCLE, ANAND

The appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

56,35,105/- for A.Y. 2022-23. During assessment proceedings, after examining the information filed, the Assessing Officer passed an order under section 143(3) r.w.s. 144B determining the total income at Nil and reducing the returned loss to Rs. 5,18,07,905/-. This reduction was due to an addition of Rs. 5,59,39,900/-, being

ASSISTANT COMMISSIONER OF INCOME TAX, ANAND CIRCLE, ANAND vs. ANUPAM INDUSTRIES LIMITED, ANAND

The appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

56,35,105/- for A.Y. 2022-23. During assessment proceedings, after examining the information filed, the Assessing Officer passed an order under section 143(3) r.w.s. 144B determining the total income at Nil and reducing the returned loss to Rs. 5,18,07,905/-. This reduction was due to an addition of Rs. 5,59,39,900/-, being

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts

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 :

x) r.w.s. 36(1)(va) and 43B of the Act. 10. SUNDRY DEBIT BALANCES WRITTEN OFF - RS. 58.35 LAKH - (PARA 4.10, PAGE 26 OF APPELLATE ORDER) 10.1 CIT(A) has grievously erred in fact and in law in upholding disallowance of part of the claim of business loss u/s.28 of the Act of Rs.58.35 lakh without appreciating the facts