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

disallowed the depreciation primarily on the ground that no cost was incurred for acquiring the goodwill and that the goodwill was not recorded in the books of the amalgamating company prior to amalgamation. The AO held that such goodwill arose merely on account of accounting adjustments and hence no depreciation was allowable under section

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

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

disallowed proportionate interest of Rs. 26,25,000/- (calculated at 15% of Rs. 1,75,00,000/-) under Section 36(1)(iii) of the Act. 12. Before

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

disallowed proportionate interest of Rs. 26,25,000/- (calculated at 15% of Rs. 1,75,00,000/-) under Section 36(1)(iii) of the Act. 12. Before

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

disallowed proportionate interest of Rs. 26,25,000/- (calculated at 15% of Rs. 1,75,00,000/-) under Section 36(1)(iii) of the Act. 12. Before

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

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for deduction under section

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

section 80-IA of the Act. 64.1 However, the AO was of the view that no benefit of bad debts recovery can be granted by allowing deduction under section 80IA of the Act for the reason that the amount of bad debt was recognized by the assessee when its unit was not eligible for 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 made by it to the tune of Rs.1,00,86,493/-. Ground nos.8 and 9 raised by the Revenue are dismissed. 72. Ground Nos.10 and 11 relate to the issue of adjustment made to book profits of the assessee under section 115JB of the Act on account of provision for bad and doubtful debts and provision for diminution

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 made by it to the tune of Rs.1,00,86,493/-. Ground nos.8 and 9 raised by the Revenue are dismissed. 72. Ground Nos.10 and 11 relate to the issue of adjustment made to book profits of the assessee under section 115JB of the Act on account of provision for bad and doubtful debts and provision for diminution

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 made by it to the tune of Rs.1,00,86,493/-. Ground nos.8 and 9 raised by the Revenue are dismissed. 72. Ground Nos.10 and 11 relate to the issue of adjustment made to book profits of the assessee under section 115JB of the Act on account of provision for bad and doubtful debts and provision for diminution

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 made by it to the tune of Rs.1,00,86,493/-. Ground nos.8 and 9 raised by the Revenue are dismissed. 72. Ground Nos.10 and 11 relate to the issue of adjustment made to book profits of the assessee under section 115JB of the Act on account of provision for bad and doubtful debts and provision for diminution

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 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

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 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

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 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

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 14A of the Act.” ITA No.285/Ahd/2020 with C.O No.81/Ahd/2020 and 5 others A.Y. 2013-14 & Ors. 18 23.7 Givenabove, we hold that the disallowances made under the provisions of Sec. 14A r.w.r. 8D of the IT Rules, cannot be applied to the provision of Sec. 115JB of the Act as per the direction of the Hon'ble Calcutta High

GUJARAT FLUOROCHEMICALS LIMITED.,,VADODARA vs. THE DCIT, CIRCLE-1(1)(1),, VADODARA

The appeal of the assessee is partly allowed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumar"नधा"रणवष"/Assessment Year: 2014-15 Gujarat Fluorochemicals Ltd., Vs. Dcit, 2Nd Floor, Abs Tower, Old Circle 1(1)(1), Padra Road, Baroda-390007 Baroda Pan : Aaacg 6725 H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Revenue By : Shri Samir Tekriwal, Cit-Dr सुनवाई क" तार"ख/Date Of Hearing : 11.10.2022 घोषणा क" तार"ख /Date Of Pronouncement: 28.12.2022 आदेश/O R D E R Per Annapurna Gupta:

75,00,000/- of other expenses on estimation basis Net disallowance made by the Assessing Officer - Rs.7,92,83,524/- 6. The Assessing Officer further went on to make addition to the book profits of the assessee under Section

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 145(2) of the Act. Thus, while the assessee is at liberty to follow it in its books, for Income Tax purposes it ought to have added back the ITA Nos.1470, 1792 & 2045/Ahd/2018 (D) ITA No. 1398/Ahd/18, CO Nos. 88&89/Ahd/2019 (A) Assessee : Adani Petronet (Dahej) Port Ltd. AYs : 2012-13, 2013-14 & 2014-15 10 contingent liability

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 145(2) of the Act. Thus, while the assessee is at liberty to follow it in its books, for Income Tax purposes it ought to have added back the ITA Nos.1470, 1792 & 2045/Ahd/2018 (D) ITA No. 1398/Ahd/18, CO Nos. 88&89/Ahd/2019 (A) Assessee : Adani Petronet (Dahej) Port Ltd. AYs : 2012-13, 2013-14 & 2014-15 10 contingent liability

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 145(2) of the Act. Thus, while the assessee is at liberty to follow it in its books, for Income Tax purposes it ought to have added back the ITA Nos.1470, 1792 & 2045/Ahd/2018 (D) ITA No. 1398/Ahd/18, CO Nos. 88&89/Ahd/2019 (A) Assessee : Adani Petronet (Dahej) Port Ltd. AYs : 2012-13, 2013-14 & 2014-15 10 contingent liability

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 145(2) of the Act. Thus, while the assessee is at liberty to follow it in its books, for Income Tax purposes it ought to have added back the ITA Nos.1470, 1792 & 2045/Ahd/2018 (D) ITA No. 1398/Ahd/18, CO Nos. 88&89/Ahd/2019 (A) Assessee : Adani Petronet (Dahej) Port Ltd. AYs : 2012-13, 2013-14 & 2014-15 10 contingent liability