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

section 115JB of the Income Tax Act, 1961 by Rs.61,45,72,000/- on account of disallowance made under section

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

section 144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance

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

section 144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance

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

section 115JB of the Income Tax Act, 1961 by Rs.61,45,72,000/- on account of disallowance made under section

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

section 115JB of the Income Tax Act, 1961 by Rs.61,45,72,000/- on account of disallowance made under section

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 of clinical trial expenses and analytical and testing expenses to the tune of Rs.6,41,494/- and Rs.2,72,33,452/- made by the AO on the ground that these expenses were not incurred in-house facility but testing R&D facility. 32. As per the AO, for the purpose of claiming weighted deduction under section

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 of clinical trial expenses and analytical and testing expenses to the tune of Rs.6,41,494/- and Rs.2,72,33,452/- made by the AO on the ground that these expenses were not incurred in-house facility but testing R&D facility. 32. As per the AO, for the purpose of claiming weighted deduction under section

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 of clinical trial expenses and analytical and testing expenses to the tune of Rs.6,41,494/- and Rs.2,72,33,452/- made by the AO on the ground that these expenses were not incurred in-house facility but testing R&D facility. 32. As per the AO, for the purpose of claiming weighted deduction under section

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 of clinical trial expenses and analytical and testing expenses to the tune of Rs.6,41,494/- and Rs.2,72,33,452/- made by the AO on the ground that these expenses were not incurred in-house facility but testing R&D facility. 32. As per the AO, for the purpose of claiming weighted deduction under section

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

disallowance of deduction claimed under section 80-IA of the Act for Rs. 93,15,306/- and Rs. 38,97,867/- on account of recovery of bad debts in Ahmedabad unit and Surat unit. 64. The assessee during the year has shown income on account of recovery of bad debts amounting to Rs. 2,88,72

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

disallowance of deduction claimed under section 80-IA of the Act for Rs. 93,15,306/- and Rs. 38,97,867/- on account of recovery of bad debts in Ahmedabad unit and Surat unit. 64. The assessee during the year has shown income on account of recovery of bad debts amounting to Rs. 2,88,72

THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

Section MA disallowance of Rs. 16,17,71, 216/- under both general and MAT provisions. (4) The CIT(A) has erred in law and in facts in deleting the disallowance of depreciation of Rs.4,77,009/- claimed on shares despite the fact that shares are not depreciable assets. (5) The CIT(A) has erred in law and in facts

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

Section MA disallowance of Rs. 16,17,71, 216/- under both general and MAT provisions. (4) The CIT(A) has erred in law and in facts in deleting the disallowance of depreciation of Rs.4,77,009/- claimed on shares despite the fact that shares are not depreciable assets. (5) The CIT(A) has erred in law and in facts

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

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

Section MA disallowance of Rs. 16,17,71, 216/- under both general and MAT provisions. (4) The CIT(A) has erred in law and in facts in deleting the disallowance of depreciation of Rs.4,77,009/- claimed on shares despite the fact that shares are not depreciable assets. (5) The CIT(A) has erred in law and in facts

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

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

Section MA disallowance of Rs. 16,17,71, 216/- under both general and MAT provisions. (4) The CIT(A) has erred in law and in facts in deleting the disallowance of depreciation of Rs.4,77,009/- claimed on shares despite the fact that shares are not depreciable assets. (5) The CIT(A) has erred in law and in facts

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET( DAHEJ) PORT PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 32 of the Act as amended by the Finance Act, 1998 and the assessee-company, therefore, was entitled to depreciation only @ 25% on computer software. He accordingly restricted the claim of the assessee for depreciation @ 25% and disallowed the excess depreciation of Rs.3,55,446/- allegedly claimed by the assessee. On appeal, the learned CIT(A) deleted the addition

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET( DAHEJ) PORT PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 32 of the Act as amended by the Finance Act, 1998 and the assessee-company, therefore, was entitled to depreciation only @ 25% on computer software. He accordingly restricted the claim of the assessee for depreciation @ 25% and disallowed the excess depreciation of Rs.3,55,446/- allegedly claimed by the assessee. On appeal, the learned CIT(A) deleted the addition

ADANI PETRONET( DAHEJ) PORT PVT. LTD.,,AHMEDABAD vs. THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 32 of the Act as amended by the Finance Act, 1998 and the assessee-company, therefore, was entitled to depreciation only @ 25% on computer software. He accordingly restricted the claim of the assessee for depreciation @ 25% and disallowed the excess depreciation of Rs.3,55,446/- allegedly claimed by the assessee. On appeal, the learned CIT(A) deleted the addition

DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. ADANI PETRONET (DAHEJ) PORT PVT. LTD, AHMEDABAD

In the result, the appeal of the Revenue for AY 2014-15 and CO of the assessee for AY 2013-14 are treated as partly allowed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2012-13 Adani Petronet (Dahej) Port The Dy. Commissioner Of Pvt. Ltd., Vs Income-Tax, 9Th Floor, Shikhar Building, Circle 1(1)(1), Nr. Mithakali Circle, Ahmedabad Navrangpura, Ahmedabad-380009 Pan: Aaeca 5046 R Assessment Year : 2012-13 The Dy. Commissioner Of Adani Petronet (Dahej) Port Income-Tax, Vs Pvt. Ltd., Circle 1(1)(1), Ahmedabad-380009 Ahmedabad Pan: Aaeca 5046 R

Section 32 of the Act as amended by the Finance Act, 1998 and the assessee-company, therefore, was entitled to depreciation only @ 25% on computer software. He accordingly restricted the claim of the assessee for depreciation @ 25% and disallowed the excess depreciation of Rs.3,55,446/- allegedly claimed by the assessee. On appeal, the learned CIT(A) deleted the addition