M/S. VAIBHAV CONSTRUCTION,ANAND vs. THE INCOME TAX OFFICER,WARD-1,, ANAND

In the result the appeal of the assessee is partly allowed

c) of the Act/12/2010. 3. The learned Commissioner of Income Tax (Appeals)-IV, Baroda, erred in law and on facts in holding that deduction u/s.80IB(10) is not allowable to the appellant. The appellant craves liberty to add, alter, delete, amend or modify any of the ground mentioned herein above. 2. The 1st issue raised by the assessee in ground

M/S. VAIBHAV CONSTRUCTION,ANAND vs. THE INCOME TAX OFFICER,WARD-1,, ANAND

In the result the appeal of the assessee is partly allowed

c) of the Act/12/2010. 3. The learned Commissioner of Income Tax (Appeals)-IV, Baroda, erred in law and on facts in holding that deduction u/s.80IB(10) is not allowable to the appellant. The appellant craves liberty to add, alter, delete, amend or modify any of the ground mentioned herein above. 2. The 1st issue raised by the assessee in ground

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LTD.,,AHMEDABAD vs. DCIT CIRCLE-2(1) (2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE JT. CIT, RANGE-4,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

THE DCIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

SHRI UMANG H. THAKKAR,AHMEDABAD vs. THE DY.CIT.,WARD-7(2),, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

801B(10) of the I.T. Act, 1961. 8. The learned Commissioner of Income Tax (Appeals) has erred in confirming the addition of Rs.12,99,159/- u/s.40(a)(ia) of the I.T. Act being an amount of expenses on which TDS has not been paid and disallowed by the appellant himself in A.Yr. 2006-07 which are now paid and claimed

THE DCIT, CIRCLE-11,, AHMEDABAD vs. SHRI UMANG HIRALAL THAKKAR, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

801B(10) of the I.T. Act, 1961. 8. The learned Commissioner of Income Tax (Appeals) has erred in confirming the addition of Rs.12,99,159/- u/s.40(a)(ia) of the I.T. Act being an amount of expenses on which TDS has not been paid and disallowed by the appellant himself in A.Yr. 2006-07 which are now paid and claimed

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

disallowed. 10.2.3.2 Considering the above facts and circumstances of the case, the assesses was asked during assessment proceedings various queries relating to its claim u/s 801B/IC of the 1. T. Act, 1961. 10.3.0 The assessee was asked to justify the following during the course of assessment proceedings: i. Justification of claim u/s. 80IB/IC ii. Details of products manufactured u/s. 80IB/1C

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

disallowed u/s 40(a)(ia) of the Act. IT(TP)A Nos.1782/Del/2014 & 781/Del/2015 Ranbaxy Laboratories Ltd. vs. DCIT/Addl.CIT Asst.Years – 2009-10 & 2010-11 respectively 12.6. In view of the above, the AO held that reversal of Rs. 21,79,471/- in respect of option not exercised by the employee is in the nature of income as assessee could not demonstrate

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

disallowed u/s 40(a)(ia) of the Act. IT(TP)A Nos.1782/Del/2014 & 781/Del/2015 Ranbaxy Laboratories Ltd. vs. DCIT/Addl.CIT Asst.Years – 2009-10 & 2010-11 respectively 12.6. In view of the above, the AO held that reversal of Rs. 21,79,471/- in respect of option not exercised by the employee is in the nature of income as assessee could not demonstrate

ROTOFILT ENGINEERS LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(1), AHMEDABAD

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

Bench: This Tribunal. Brief Facts Of The Case Are That The Assessee Is A Company

801B of the Act in respect of Plant and Machinery used for R&D purpose. c) Regarding the allegation of the Ld. AO that more than 60% of the machinery has been transferred from Plant & Machinery to I.T.A No. 1628/Ahd/2025 A.Y. 2012-13 Page No 9 Rotofilt Engineers Ltd. vs. ACIT Research and Development, yet there was no significant change

P.CHHOTALAL MANUFACTURERS & EXPORTE,R,AHMEDABAD vs. THE DY.CIT.,CIRCLE-10,, AHMEDABAD

In the result, appeal filed by the Assessee is allowed

Bench: Shri Pramod Kumar & Shri Mahavir Prasad)

801B. But the explanation offered was rejected, there would arisen no 4 . A.Y. 2008-09 presumption of concealment of the particulars of income that was added or disallowed. 7. Therefore, we object to your proposal to levy the penalty u/s. 271(l)(c) of the l.T. Act on additions made by AO for reasons mentioned above. 6. The reply