DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

80G(5)(vi) of the Act by and under the order dated 25.04.2006 issued under the signature of the Director of Income Tax (Exemption) being Memo No.DIT(E)/80G/42/W.2/2006-07. The assessee Trust is also registered under Section 35AC of the Act by and under the notification dated 23.10.2007. 4. On 22.09.2011 the assessee filed its return of income

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

5 others A.Y.2013-14 43 account of benchmarking of loan to AE. Thus, the ground of the appeal filed by the assessee is hereby allowed. Capital Infusion. 55. The TPO found that the assessee during the year has made payment of share application money to the following AEs: S. Name of AE Amount in Rs. Date of Date of share

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-8,, AHMEDABAD

In the result appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita.No.1285 & 1286/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2009-10 & 2010-11 & Ita No.1396 & 1397/Ahd/2018 Asstt.Year 2011-12 & 2012-13 Torrent Pharmaceuticals Ltd. Acit, Circle-4(1)(2) Torrent House Ahmedabad. Vs. Off.Ashram Road Ahmedabad 380 009. आयकर अपील सं./Ita.No.1327 & 1328/Ahd/2017 िनधा"रण वष"/ Asstt. Year: 2009-10 & 2010-11 & आयकर अपील सं./Ita.No.1414 & 1415/Ahd/2018 िनधा"रण वष"/ Asstt. Year: 2011-12 & 2012-13 Acit, Circle-4(1)(2) Torrent Pharmaceuticals Ltd. Ahmedabad. Torrent House Vs. Off.Ashram Road Ahmedabad 380 009. (Applicant) (Responent) Assessee By : Shri Vartik Choksi, With Shri Biren Shah, Ars. Revenue By : Shri Mohd. Usman, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 23/11/2021 घोषणा क" तारीख /Date Of Pronouncement: 22/02/2022 आदेश/O R D E R Per Bench

ix. Tangible net worth shall not be less than INR 3.4 billion at all times during the currency of the loan. x. Exposure to non-pharmaceutical group companies not to exceed 15% of tangible net worth, xi. Currency risk on the borrower. xii. The loan documents related to the loan drawn by Torrent Pharmaceuticals Ltd, the parent company

DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ADANI PORT & SPECIAL ECONOMIC ZONE LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

80G is to be allowed, and, as learned CIT(A) rightly observes, it is not an expense which is to be allocated to different heads or sources of income. As a matter of fact, a donation is in the nature of allocation of income and the tax deduction for eligible deduction is a tax policy driven deduction for encouraging such

DY. COMMISSIONER OF INCOME TAX , CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ADANI PORT & SPECIAL ECONOMIC ZONE LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

80G is to be allowed, and, as learned CIT(A) rightly observes, it is not an expense which is to be allocated to different heads or sources of income. As a matter of fact, a donation is in the nature of allocation of income and the tax deduction for eligible deduction is a tax policy driven deduction for encouraging such

THE TORRENT PHARMACEUTICALS,AHMEDABAD vs. THE ADDITIONAL CIT, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

80G will be allowed after allowing all other deduction of chapter VIA. The Ld. CIT (A) accordingly deleted the addition made by the AO. Being aggrieve by the order of the Ld. CIT (A), Revenue is in appeal before us. 43. The Ld. DR before us submitted that the amount of donation needs to be allocated to the Baddi Unit

THE ACIT, CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

80G will be allowed after allowing all other deduction of chapter VIA. The Ld. CIT (A) accordingly deleted the addition made by the AO. Being aggrieve by the order of the Ld. CIT (A), Revenue is in appeal before us. 43. The Ld. DR before us submitted that the amount of donation needs to be allocated to the Baddi Unit

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

80G will be allowed after allowing all other deduction of chapter VIA. The Ld. CIT (A) accordingly deleted the addition made by the AO. Being aggrieve by the order of the Ld. CIT (A), Revenue is in appeal before us. 43. The Ld. DR before us submitted that the amount of donation needs to be allocated to the Baddi Unit

THE TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

80G will be allowed after allowing all other deduction of chapter VIA. The Ld. CIT (A) accordingly deleted the addition made by the AO. Being aggrieve by the order of the Ld. CIT (A), Revenue is in appeal before us. 43. The Ld. DR before us submitted that the amount of donation needs to be allocated to the Baddi Unit

SHAH RAKESH BHIKHABHAI (HUF),AHMEDABAD vs. THE PCIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal filed by the assessee stands dismissed

Bench: Shri T.R Senthil Kumar & Shri Narendra Prasad Sinha

disallowed and added to the total income." From the above notice of the assessing officer, issued under section 142 (1) of the Act, it is vivid that assessing officer had conducted enquiry only in respect of deduction under section 80D of the Act amounting to Rs.25,000/-, We note that assessee had paid donations

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

80G of the Act. The AO further observed that the recipients did not show the amount as taxable receipts but accounted as donations. 24.3. The AO also noticed that the assessee has also not deducted TDS on such expenditure, therefore the same cannot be allowed as deduction u/s 40(a)(ia) of the Act. Hence, the AO disallowed the said

GUJARAT INDUSTRIES POWER CO.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

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

5. As against the Grounds of Appeal raised by both parties, five issues/disallowances were already considered by this Tribunal in ITA No.3003/Ahd/2010 & ors. relating to A.Ys. 2003-04 & ors., vide order dated 28.02.2022. It is being agreed by both the parties that those four issues are already covered in assessee’s own case in ITA No.3003/Ahd/2010. Similarly, issue regarding disallowance

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

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

5. As against the Grounds of Appeal raised by both parties, five issues/disallowances were already considered by this Tribunal in ITA No.3003/Ahd/2010 & ors. relating to A.Ys. 2003-04 & ors., vide order dated 28.02.2022. It is being agreed by both the parties that those four issues are already covered in assessee’s own case in ITA No.3003/Ahd/2010. Similarly, issue regarding disallowance

THE DCIT, CIRCLE-1(1),, BARODA vs. GUJARAT INDUSTRIES POWER CO.LTD.,, BARODA

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

5. As against the Grounds of Appeal raised by both parties, five issues/disallowances were already considered by this Tribunal in ITA No.3003/Ahd/2010 & ors. relating to A.Ys. 2003-04 & ors., vide order dated 28.02.2022. It is being agreed by both the parties that those four issues are already covered in assessee’s own case in ITA No.3003/Ahd/2010. Similarly, issue regarding disallowance

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowance in respect of deduction under Section 80IA(4)(i) of the Act. 7. The Ld. AR submitted that the assessee in fact has given detailed reply thereby stating that the assessee since the beginning was carrying on the business of infrastructure development such as construction of Dam, Bridges etc. and have maintained workwise accounts in its books of account

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowance in respect of deduction under Section 80IA(4)(i) of the Act. 7. The Ld. AR submitted that the assessee in fact has given detailed reply thereby stating that the assessee since the beginning was carrying on the business of infrastructure development such as construction of Dam, Bridges etc. and have maintained workwise accounts in its books of account

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

disallowance in respect of deduction under Section 80IA(4)(i) of the Act. 7. The Ld. AR submitted that the assessee in fact has given detailed reply thereby stating that the assessee since the beginning was carrying on the business of infrastructure development such as construction of Dam, Bridges etc. and have maintained workwise accounts in its books of account