DARED SEVA SAHKARI MANDALI LIMITED,BHAVNAGAR, GUJARAT vs. ITO, WARD-1(1), BHAVNAGAR

In the result, appeal of the assessee in ITA no

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Has Arisen From The Separate Appellate

80A(5), the claim for deduction under Section 80P could be made by an assessee in a return filed within the time prescribed for filing such returns under any of the above provisions. The amendment to Section 80AC with effect from 1.4.2018, however mandated that for an assessee to get a deduction under Section

DARED SEVA SAHKARI MANDALI LIMITED,BHAVANAGAR vs. ITO, WARD-1(1), BHAVNAGAR

In the result, appeal of the assessee in ITA no

Bench: Income Tax Appellate Tribunal, Ahmedabad Bench, Ahmedabad Has Arisen From The Separate Appellate

80A(5), the claim for deduction under Section 80P could be made by an assessee in a return filed within the time prescribed for filing such returns under any of the above provisions. The amendment to Section 80AC with effect from 1.4.2018, however mandated that for an assessee to get a deduction under Section

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

disallowed the same by holding that the deduction under section 80-IC of the Act is eligible only for the profit and gains derived from the activity of manufacturing and income on account of refund of service tax does not arise from the manufacturing activity. 17.2 On appeal by the assessee, the learned CIT(A) allowed the claim

M/S. BODAL CHEMICALS LIMITED,AHMEDABAD vs. THE DY.CIT., CENTRAL CIRCLE-1(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

disallowing claim u/s 35(1)(ii) of the Act. Bodal Chemicals Ltd Vs. DCIT Asst. Year : 2016-17 - 2– 3.0 That on the facts and in the circumstances of the case, the Ld. CIT(A) was not justified and grossly erred in not allowing the deduction u/s 80IA(4)(ia) of the Action respect of operating and maintaining infrastructure facilities

CHILODA SEVA SAHAKARI MANDALI LIMITED,GANDHINAGAR vs. THE ITO, WARD-1 (PREVIOUSLY WARD-5), GANDHINAGAR

In the result, the appeal of the assessee is partly allowed for statistical purpose

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

1. The order passed u/s 250 by ADDL/JCIT (A)-12. Hyderabad confirming addition of Rs 10,48,964/= is against law, equity and justice. 2. The Ld ADDL/JCIT (A) - 12, Hyderabad erred in law and or on facts in confirming the disallowance of claim made u/s 80P invoking section 80A

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. RAJKAMAL BUILDERS INFRASTRUCTURE PRIVATE LIMITED, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1466/Ahd/2024 & 1467/Ahd/2024 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively The Acit Rajkamal Builders बनाम/ Circle-3(1)(1) Infrastrucutre Pvt.Ltd. V/S. Ahmedabad – 380 015 54, Park Hill Nr.Heaven Park Ramdevnagar, Ahmedabad (Gujarat) – 380 015 "थायी लेखा सं./Pan: Aabcr 0326 A अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri Ritesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 25/10/2024 घोषणा की तारीख /Date Of Pronouncement: /10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

disallowed Rs.49,39,271/- from the deduction under Section 80IA on the grounds that the losses from four infrastructure units were not set off against the profits from other units. 6.1. The assessee argued that the overall computation of profits and losses for the infrastructure units was done in accordance with the provisions of the Income

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEDABAD vs. RAJKAMAL BUILDERS INFRASTRUCTURE PRIVATE LIMITED, AHMEDABAD

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.1466/Ahd/2024 & 1467/Ahd/2024 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively The Acit Rajkamal Builders बनाम/ Circle-3(1)(1) Infrastrucutre Pvt.Ltd. V/S. Ahmedabad – 380 015 54, Park Hill Nr.Heaven Park Ramdevnagar, Ahmedabad (Gujarat) – 380 015 "थायी लेखा सं./Pan: Aabcr 0326 A अपीलाथ%/ (Appellant) &' यथ%/ (Respondent) Assessee By : Shri Mehul K. Patel, Ar Revenue By : Shri Ritesh Parmar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 25/10/2024 घोषणा की तारीख /Date Of Pronouncement: /10/2024 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

disallowed Rs.49,39,271/- from the deduction under Section 80IA on the grounds that the losses from four infrastructure units were not set off against the profits from other units. 6.1. The assessee argued that the overall computation of profits and losses for the infrastructure units was done in accordance with the provisions of the Income

THE GANDHINAGAR DISTRICT CO-OPERATIVE CREDIT SOCIETY LIMITED,GANDHINAGAR vs. THE ITO, WARD-1 (PREVIOUSLY WARD-4), GANDHINAGAR

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

1. The order passed u/s. 250 by ADDL/JCIT (A)-12, Mumbai confirming addition of Rs. 13,44,561/= is against law, equity and justice. 2. The Ld. ADDL/JCIT (A) 12, Mumbai erred in law and or on facts in confirming the disallowance of claim made u/s 80P invoking section 80A

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

THE ACIT., PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowed. In response to the said notice, the assessee company furnished the reply dated 08.12.2010 and 20.12.2010. The assessee highlighted in the said reply that the assessee is doing the development of Infrastructure Faciality and, therefore, entitled for deduction under Section 80IA(4)(i) of the Act. The assessee also submitted that the assessee is dealing with the development work

INOX INDIA LIMITED,VADODARA vs. THE DCIT, CIRCLE-1 NOW CIRCLE 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

80A. Therefore, the theory that the Legislature has in far more complex and detailed expression desired to bring about the same result, though in plain terms, when the sub-section read as a whole, conveys entirely different connotation could not be accepted. [Para 24] - In plain terms when read as a whole sub-section (9) of section 80-IA does

INOX INDIA LIMITED,VADODARA vs. THE ACIT, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed for assessment year 2000-2001 and other years before us, on the above two issues which were argued before us

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

80A. Therefore, the theory that the Legislature has in far more complex and detailed expression desired to bring about the same result, though in plain terms, when the sub-section read as a whole, conveys entirely different connotation could not be accepted. [Para 24] - In plain terms when read as a whole sub-section (9) of section 80-IA does