THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

disallowance under section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee

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

disallowance made under section 36(1)(iii). The assessee has also placed reliance on its consistent accounting policy to capitalise interest cost only when directly attributable to acquisition of qualifying capital assets, which has been accepted in earlier years and remains unchanged. 87

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

disallowance made under section 36(1)(iii). The assessee has also placed reliance on its consistent accounting policy to capitalise interest cost only when directly attributable to acquisition of qualifying capital assets, which has been accepted in earlier years and remains unchanged. 87

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

87,314/- and administrative expenses disallowance of Rs.26,12,858/-, reducing suo-moto disallowance made by the assessee of Rs.1,00,86,493/- there from, he disallowed an amount of Rs.1,70,13,679/- 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

87,314/- and administrative expenses disallowance of Rs.26,12,858/-, reducing suo-moto disallowance made by the assessee of Rs.1,00,86,493/- there from, he disallowed an amount of Rs.1,70,13,679/- 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

87,314/- and administrative expenses disallowance of Rs.26,12,858/-, reducing suo-moto disallowance made by the assessee of Rs.1,00,86,493/- there from, he disallowed an amount of Rs.1,70,13,679/- 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

87,314/- and administrative expenses disallowance of Rs.26,12,858/-, reducing suo-moto disallowance made by the assessee of Rs.1,00,86,493/- there from, he disallowed an amount of Rs.1,70,13,679/- under section

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

87,695/- of Depreciation on Intangible Assets Decision of Confirmed Confirmed Confirmed Confirmed CIT(A) the the the the disallowance disallowance disallowance disallowance Disallowance 20,76,038/- 11,81,635/- 4,57,189/- 25,24,619/- u/s 14A Decision of Restricted Deleted the Deleted the Deleted the CIT(A) the disallowance disallowance disallowance disallowance to 9,12,638/- ITA Nos.960/Ahd/2016

THE DY.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,, AHMEDABAD

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

87,695/- of Depreciation on Intangible Assets Decision of Confirmed Confirmed Confirmed Confirmed CIT(A) the the the the disallowance disallowance disallowance disallowance Disallowance 20,76,038/- 11,81,635/- 4,57,189/- 25,24,619/- u/s 14A Decision of Restricted Deleted the Deleted the Deleted the CIT(A) the disallowance disallowance disallowance disallowance to 9,12,638/- ITA Nos.960/Ahd/2016

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT. LTD.,,AHMEDABAD vs. THE ASST.COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1),, AHMEDABAD

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

87,695/- of Depreciation on Intangible Assets Decision of Confirmed Confirmed Confirmed Confirmed CIT(A) the the the the disallowance disallowance disallowance disallowance Disallowance 20,76,038/- 11,81,635/- 4,57,189/- 25,24,619/- u/s 14A Decision of Restricted Deleted the Deleted the Deleted the CIT(A) the disallowance disallowance disallowance disallowance to 9,12,638/- ITA Nos.960/Ahd/2016

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(2),, AHMEDABAD

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

87,695/- of Depreciation on Intangible Assets Decision of Confirmed Confirmed Confirmed Confirmed CIT(A) the the the the disallowance disallowance disallowance disallowance Disallowance 20,76,038/- 11,81,635/- 4,57,189/- 25,24,619/- u/s 14A Decision of Restricted Deleted the Deleted the Deleted the CIT(A) the disallowance disallowance disallowance disallowance to 9,12,638/- ITA Nos.960/Ahd/2016

ANANYA FINANCE FOR INCLUSIVE GROWTH PVT.LTD.,,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

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

87,695/- of Depreciation on Intangible Assets Decision of Confirmed Confirmed Confirmed Confirmed CIT(A) the the the the disallowance disallowance disallowance disallowance Disallowance 20,76,038/- 11,81,635/- 4,57,189/- 25,24,619/- u/s 14A Decision of Restricted Deleted the Deleted the Deleted the CIT(A) the disallowance disallowance disallowance disallowance to 9,12,638/- ITA Nos.960/Ahd/2016

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

disallowance of commission paid to non-resident under section 40(a)(ia) of the IT Act." 3. At the outset itself, the Ld. AR, appearing for the assessee, submitted that all the issues raised by the Revenue in its grounds of appeal are squarely covered in favour of the assessee by the decision of the Co-ordinate Bench of this

LOK PRAKASHAN LIMITED,AHMEDABAD vs. ACIT, CENTRAL CIRCLE-1(3),, AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

DCIT, CENTRAL CIRCLE - 1(3), AHMEDABAD vs. M/S LOK PRAKASHAN LTD., AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income

DCIT, CENTRAL CIRCLE- 1(3), AHMEDABAD vs. M/S LOK PRAKASHAN LTD., AHMEDABAD

The appeal of the Revenue is dismissed accordingly

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.290 & 291/Ahd/2023 िनधा"रण वष" /Assessment Years : 2017-18 & 2018-19 Respectively Lok Prakashan Limited The Acit बनाम/ Gujarat Samachar Bhavan Central Circle-1(3) V/S. J.P. Chowk, Khanpur Ahmedabad – 380 009 Ahmedabad – 380 001 (अपीलाथ%/ Appellant) ('( यथ%/ Respondent) "थायी लेखा सं./Pan: Aaacl 2742 F

Section Earned in Rs. 14A in Rs. Self- 20,69,043/- 20,03,321/- Disallowance by Assessee AO's Calculation 17,37,10,409/- 24,52,39,198/- of Disallowance (Rule 8D) Additional 17,16,41,366/- 24,32,35,877/- Disallowance by AO CIT(A) Decision Partly allowed; directed recalculation per Rule 8D excluding investments not earning exempt income