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 was added to the assessee’s total income under the normal computation and also considered as an adjustment to the book profit under section 115JB, thereby giving rise to Ground No. 8 of the appeal. 89

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 was added to the assessee’s total income under the normal computation and also considered as an adjustment to the book profit under section 115JB, thereby giving rise to Ground No. 8 of the appeal. 89

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

Section 36(1)(iii) of the Act. 12. Before the Ld.CIT(A), the assessee argued that it had sufficient interest-free funds to cover the loan to the subsidiary, and hence no disallowance of interest expenditure was warranted. The assessee provided a breakdown of its interest-free funds, including share capital, general reserves, and unsecured loans, totalling to Rs.17,89

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

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

Section 36(1)(iii) of the Act. 12. Before the Ld.CIT(A), the assessee argued that it had sufficient interest-free funds to cover the loan to the subsidiary, and hence no disallowance of interest expenditure was warranted. The assessee provided a breakdown of its interest-free funds, including share capital, general reserves, and unsecured loans, totalling to Rs.17,89

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

Section 36(1)(iii) of the Act. 12. Before the Ld.CIT(A), the assessee argued that it had sufficient interest-free funds to cover the loan to the subsidiary, and hence no disallowance of interest expenditure was warranted. The assessee provided a breakdown of its interest-free funds, including share capital, general reserves, and unsecured loans, totalling to Rs.17,89

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), AHMEDABAD vs. N K PROTEINS PVT. LIMITED, AHMEDABAD

In the result the appeal filed by the Revenue is hereby dismissed

Bench: Shri T R Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowance of Rs. 13,89,08,810/- made u/s 43(5) read with section 73 and 40A(2)(b) of the Act. 3. On the facts

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Disallowance under section 14A read with Rule 8D -Rs.69,89,859/- 4. Ground No.4. Disallowance of amortization of Intangibles under

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Disallowance under section 14A read with Rule 8D -Rs.69,89,859/- 4. Ground No.4. Disallowance of amortization of Intangibles under

TORRENT INVESTMENTS LIMITED (FORMERLY KNOWN AS TORRENT INVESTMENTS PRIVATE LIMITED),AHMEDABAD vs. THE PR.CIT, AHMEDABAD-3, AHMEDABAD

In the result, the appeal of the assessee is partly allowed

Bench: Smt. Annapurna Gupta & Shri T.R. Senthil Kumar

disallowance made under section 14Aof the Act is Rs. 4,92,537/- and hence, this has resulted into underassessment of income of Rs. 37,89

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Section 14A of the Act amounting to Rs. 1,89,45,957/- 28. Before us, at the outset, the Counsel for the assessee submitted that since for the impugned year under consideration since no exempt income was earned by the assessee, there is no question of making any disallowance

THE ASST. CIT.,CIRCLE-1(1),, BARODA vs. AMBALAL SARABHAI ENTERPRISES LIMITED,, BARODA

In the result, the appeal is allowed for statistical purposes

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

Section 14A of the Act amounting to Rs. 1,89,45,957/- 28. Before us, at the outset, the Counsel for the assessee submitted that since for the impugned year under consideration since no exempt income was earned by the assessee, there is no question of making any disallowance

JCIT(OSD), CIR-3(1)(2), AHMEDABAD vs. RECKITT BENCKISER HEALTHCARE (INDIA) LTD, HARYANA

In the result, appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 14A of the Act does not arise. 6.5 The Ld. DR, placing reliance on the assessment order, contended that the Assessing Officer has rightly made the disallowance u/s 14A of the Act and relied on the order of the Tribunal in assessee’s own case in ITA No. 3098/Ahd/2013 for AY 2008-09. 6.6. We have heard the rival

RECKITT BENCKISER HEALTHCARE INDIA PVT. LTD., ( FORMERLY KNOWN AS RECKITT BENCKISER HEALTHCARE INDIA LTD.,),HARYANA vs. DCIT, CIRCLE-3(1)(2), AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 14A of the Act does not arise. 6.5 The Ld. DR, placing reliance on the assessment order, contended that the Assessing Officer has rightly made the disallowance u/s 14A of the Act and relied on the order of the Tribunal in assessee’s own case in ITA No. 3098/Ahd/2013 for AY 2008-09. 6.6. We have heard the rival

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

disallowances in earlier years had been deleted by appellate authorities or the Tribunal, making the issue covered in favour of the assessee. 38. The AR, during the course of the hearing, before us stated that the issue was already decided in favour of the assessee in its own case by the Co- ordinate Bench in ITA No. 1762/Ahd/2015