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

Disallowance of Weighted Deduction under 65,09,81,251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress

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

disallowance was warranted. It is further contended that the Assessing Officer failed to record the requisite satisfaction under section 14A(2) before rejecting the assessee’s working and 6

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

section 195(2) of the Act, which casts upon the assessee a duty to seek opinion or direction from the AO to determine the appropriate rate of TDS by the deductor. The assessee having failed to discharge his obligation, the ld.AO disallowed the impugned commission expenses of Rs.18,84,793/- and added the same to the total income

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 a sum of Rs. 77,58,44,809/- on account of expenditure attributable to exempt dividend income invoking the provision of Section 14A of the Act. 6

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

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)

6. So far as the fourth question is concerned, it pertains to addition of Rs.1,14,43,040/ under Section 115JB of the Act being the expenditure estimated on earning of dividend income under Section 14A of the Act. 6.1 The Assessing Officer on referring to the said provision of Section 115JB(2) of the Act added the said amount

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

disallowance u/s 14A of the Act r.w. Rule 8D(2)(iii) of I.T. Rules. 6. The Assessing Officer (AO) made an addition to the assessee’s book profit under Section

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

6 Disallowance Rs. 52,07,537/- The CIT(A) directed the Assessee is under Section AO to verify the in appeal

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

6 Disallowance Rs. 52,07,537/- The CIT(A) directed the Assessee is under Section AO to verify the in appeal

ORIENTAL ENTERPRISE PRIVATE LIMITED,VADODARA vs. THE ACIT, CIRCLE-2(1)(2), VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

6 Disallowance Rs. 52,07,537/- The CIT(A) directed the Assessee is under Section AO to verify the in appeal

TEKNI ENGINEERING PVT. LTD.,AHMEDABAD vs. THE ITO, WARD-4(1)(1), AHMEDABAD

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

Bench: Dr.Brr Kumarshri Siddhartha Nautiyal

disallowance made by the appellant company is shown under section 36(1)(va) and similarly the same has been accepted under section 143(1) column also. Similarly, in the intimation under section 14(1) at page no. 6

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. GUJARAT URJA VIKAS NIGAM LIMITED, 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: Smt. Annapurna Gupta & Ms. Madhumita Roy

disallowed a sum of Rs. 186,04,63,000/-/- on account of expenditure attributable to exempt dividend income invoking the provision of Section 14A r.w.r. 8D(2)(iii) of the Act. 6

GUJARAT URJA VIKAS NIGAM LIMITED,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-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: Smt. Annapurna Gupta & Ms. Madhumita Roy

disallowed a sum of Rs. 186,04,63,000/-/- on account of expenditure attributable to exempt dividend income invoking the provision of Section 14A r.w.r. 8D(2)(iii) of the Act. 6

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

6,78,94,834/- only. The AO after giving benefit of suo-moto disallowances made by the assessee for Rs. 1,34,29,521/- made a disallowance of Rs. 5,44,65,313/- under section

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

6,78,94,834/- only. The AO after giving benefit of suo-moto disallowances made by the assessee for Rs. 1,34,29,521/- made a disallowance of Rs. 5,44,65,313/- under section

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

6. Section 14A was introduced to the Income Tax Act by the Finance Act, 2001 with retrospective effect from 01.04.1962. The new section was inserted in aftermath of judgment of this Court in the case of Rajasthan State Warehousing Corporation Vs. CIT The said Section provided for disallowance

VARUN SATYAPAL SINGHAL,VADODARA vs. THE INCOMETAX OFFICER, WARD-1(2)(3( NOW THE DCIT, CIRCLE-1(1)(1), VADODARA

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

Bench: Us, At The Outset, Ld. Counsel For The Assessee Submitted That He Shall Not Be Pressing For Ground Nos. 3, 4 & 5 Of His

disallowance @ 6% coming to Rs. 6,86,717/- thereby treating 24% interest in question as excessive. The CIT(A) upholds Assessing Officer's action. 3. We have heard both the parties. There is no dispute that both the lower authorities have invoked the impugned section