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

66,85,957 Average CWIP Funds (C) 3,65,68,91,720 Proportionate Interest Disallowance (B × C) ÷ A Amount Disallowed u/s 36(1)(iii) Rs. 11,29,21,996 ITA No.281 and 222/Ahd/2021 43 80. Before the CIT(A), the assessee submitted that the disallowance was unjustified and that it had substantial interest-free funds available throughout the year

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

66,85,957 Average CWIP Funds (C) 3,65,68,91,720 Proportionate Interest Disallowance (B × C) ÷ A Amount Disallowed u/s 36(1)(iii) Rs. 11,29,21,996 ITA No.281 and 222/Ahd/2021 43 80. Before the CIT(A), the assessee submitted that the disallowance was unjustified and that it had substantial interest-free funds available throughout the year

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

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

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

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

section 133(6) notices also contributed to this disallowance. 21. The assessee filed an appeal before the Ld.CIT(A), who partly allowed the grounds of appeal and deleted the addition of Rs.2,66,47,479/- u/s 37(1

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

section 133(6) notices also contributed to this disallowance. 21. The assessee filed an appeal before the Ld.CIT(A), who partly allowed the grounds of appeal and deleted the addition of Rs.2,66,47,479/- u/s 37(1

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

section 133(6) notices also contributed to this disallowance. 21. The assessee filed an appeal before the Ld.CIT(A), who partly allowed the grounds of appeal and deleted the addition of Rs.2,66,47,479/- u/s 37(1

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

section 36(1)(iii) in accordance with law\nand in line with our observations above. In case the assessee fails to produce\ncredible evidence, the disallowance as sustained by the CIT(A) shall stand\nconfirmed.\nIssue – 3 – Addition on account of Notional interest on advances/rent\n49. For A.Y. 2013–14, the Assessing Officer noted from the financial\nstatements that

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

66,69,14,229/-. The AO initiated penalty proceedings u/s.271(1)(c) of the Act by issuing notice dated 25/03/2013 u/s.274 of the Act. Penalty proceedings were kept in abeyance as the assessee had preferred appeal against the quantum assessment order before the CIT(A)-2, Vadodara and further appeal before ITAT. After disposal of the appeals by the Tribunal

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

In the result, the appeal filed by the Assessee in ITA No

Bench: Dr. Brr Kumar & Shri T.R.Senthil Kumar

66,69,14,229/-. The AO initiated penalty proceedings u/s.271(1)(c) of the Act by issuing notice dated 25/03/2013 u/s.274 of the Act. Penalty proceedings were kept in abeyance as the assessee had preferred appeal against the quantum assessment order before the CIT(A)-2, Vadodara and further appeal before ITAT. After disposal of the appeals by the Tribunal

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LTD, VADODARA

In the result, the appeal filed by the Assessee in ITA No

66,69,14,229/-. The AO initiated penalty proceedings u/s.271(1)(c) of the Act by issuing notice dated 25/03/2013u/s.274 of the Act. Penalty proceedings were kept in abeyance as the assessee had preferred appeal against the quantum assessment order before the CIT(A)-2, Vadodara and further appeal before ITAT. After disposal of the appeals by the Tribunal

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 :

1,48,66,928 1291/Ahd/2016 2006-07 Assessee 4 2,63,025 2066/Ahd/2016 2005-06 Revenue 5 15,73,662 12 Disallowance of 1290/Ahd/2016 2004-05 Assessee 10 Sundry Balances 58,35,000 written off 1291/Ahd/2016 2006-07 Assessee 71,91,000 6 15 Write-off of Loan 2066/Ahd/2016 2005-06 Revenue 3,66,67,734 7 Liabilities as Taxable

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 :

1,48,66,928 1291/Ahd/2016 2006-07 Assessee 4 2,63,025 2066/Ahd/2016 2005-06 Revenue 5 15,73,662 12 Disallowance of 1290/Ahd/2016 2004-05 Assessee 10 Sundry Balances 58,35,000 written off 1291/Ahd/2016 2006-07 Assessee 71,91,000 6 15 Write-off of Loan 2066/Ahd/2016 2005-06 Revenue 3,66,67,734 7 Liabilities as Taxable

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 :

1,48,66,928 1291/Ahd/2016 2006-07 Assessee 4 2,63,025 2066/Ahd/2016 2005-06 Revenue 5 15,73,662 12 Disallowance of 1290/Ahd/2016 2004-05 Assessee 10 Sundry Balances 58,35,000 written off 1291/Ahd/2016 2006-07 Assessee 71,91,000 6 15 Write-off of Loan 2066/Ahd/2016 2005-06 Revenue 3,66,67,734 7 Liabilities as Taxable