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)

Section 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee during the year. The PCIT has also noted the decision of the Hon’ble Supreme Court in CIT vs. Chettinad Logistics Pvt. Ltd [2018] 95

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)

Section 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee during the year. The PCIT has also noted the decision of the Hon’ble Supreme Court in CIT vs. Chettinad Logistics Pvt. Ltd [2018] 95

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)

Section 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee during the year. The PCIT has also noted the decision of the Hon’ble Supreme Court in CIT vs. Chettinad Logistics Pvt. Ltd [2018] 95

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)

Section 14A of the Act by Finance Act, 2022 will be applicable prospectively and disallowance should not exceed the exempt income earned by the assessee during the year. The PCIT has also noted the decision of the Hon’ble Supreme Court in CIT vs. Chettinad Logistics Pvt. Ltd [2018] 95

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 of Rs.8,70,747/- made under section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted that all the four investee companies were dormant, and no expenditure could

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 of Rs.8,70,747/- made under section 14A read with Rule 8D. He held that in the absence of any exempt income, the disallowance was ITA No.281 and 222/Ahd/2021 47 not sustainable in law, particularly in light of the binding precedents cited. The CIT(A) also noted that all the four investee companies were dormant, and no expenditure could

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 under section 14A in its entirety. This conclusion is also supported by the fact that no fresh investments were made during the year and the assessee had substantial interest-free own funds available, far in excess of the amount of investments. The ratio of interest free funds to total investment stood at 7.62 times as on 31 March

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

Section 14A for A.Y. 2012-13 is deleted entirely. Following the consistent application ITA Nos.960/Ahd/2016, 1186/Ahd/2016, 2275/Ahd/2017, 2276/Ahd/2017 & 1744//Ahd/2019 Ananya Finance for Inclusive Growth Pvt. Ltd. Vs. DCIT Asst. Years : 2012-13, 2012-13, 2013-14, 2014-15 & 2016-17 of judicial principles established by higher courts, the revenue’s ground is dismissed. Ground No. 2 of revenue

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

Section 14A for A.Y. 2012-13 is deleted entirely. Following the consistent application ITA Nos.960/Ahd/2016, 1186/Ahd/2016, 2275/Ahd/2017, 2276/Ahd/2017 & 1744//Ahd/2019 Ananya Finance for Inclusive Growth Pvt. Ltd. Vs. DCIT Asst. Years : 2012-13, 2012-13, 2013-14, 2014-15 & 2016-17 of judicial principles established by higher courts, the revenue’s ground is dismissed. Ground No. 2 of revenue

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

Section 14A for A.Y. 2012-13 is deleted entirely. Following the consistent application ITA Nos.960/Ahd/2016, 1186/Ahd/2016, 2275/Ahd/2017, 2276/Ahd/2017 & 1744//Ahd/2019 Ananya Finance for Inclusive Growth Pvt. Ltd. Vs. DCIT Asst. Years : 2012-13, 2012-13, 2013-14, 2014-15 & 2016-17 of judicial principles established by higher courts, the revenue’s ground is dismissed. Ground No. 2 of revenue

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

Section 14A for A.Y. 2012-13 is deleted entirely. Following the consistent application ITA Nos.960/Ahd/2016, 1186/Ahd/2016, 2275/Ahd/2017, 2276/Ahd/2017 & 1744//Ahd/2019 Ananya Finance for Inclusive Growth Pvt. Ltd. Vs. DCIT Asst. Years : 2012-13, 2012-13, 2013-14, 2014-15 & 2016-17 of judicial principles established by higher courts, the revenue’s ground is dismissed. Ground No. 2 of revenue

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

Section 14A for A.Y. 2012-13 is deleted entirely. Following the consistent application ITA Nos.960/Ahd/2016, 1186/Ahd/2016, 2275/Ahd/2017, 2276/Ahd/2017 & 1744//Ahd/2019 Ananya Finance for Inclusive Growth Pvt. Ltd. Vs. DCIT Asst. Years : 2012-13, 2012-13, 2013-14, 2014-15 & 2016-17 of judicial principles established by higher courts, the revenue’s ground is dismissed. Ground No. 2 of revenue

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

Appeals are partly allowed for\nstatistical reasons

95,635/-\n18,19,68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18.\nIt was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

95,635/-\n18,19,68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18. It was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section

N. K. PROTEINS LTD.,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), AHMEDABAD

Bench: Or During The Course Of Hearing Of The Appeal.”

disallowance under section 14A could be restricted to amount of exempt income only, SLP filed against said order was to be dismissed. The Hon'ble Supreme Court in the case of Chettinad Logistics (P.) Ltd.[2018] 95

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1)(1) VADODARA, VADODARA vs. M/S. INOX WIND ENERGY LIMITED, VADODARA

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

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.654/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 The Deputy Commissioner M/S. Inox Wind Energy Of Income Tax, बनाम/ Limited, V/S. Circle-1(1)(1), Abs Tower S. No.1837 & Vadodara. 1834, Op Road, Vadodara-390007. (Gujarat) "थायी लेखा सं./Pan: Aafc14628K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Rignesh Das, Cit-Dr Assessee By : Shri Bandish Soparkar, Ar सुनवाई की तारीख/Date Of Hearing : 21/08/2025 घोषणा की तारीख /Date Of Pronouncement: 26/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Revenue Is Directed Against The Order Of The Commissioner Of Income-Tax (Appeals)-11, Ahmedabad [Hereinafter Referred To As “The Cit(A)”] Dated 27.01.2025, Arising Out Of The Assessment Order Passed By The Assessing Officer Under Section 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], On 18.12.2017 For The Assessment Year 2015-16. Dcit Vs. Inox Wind Energy Limited Assessment Year 2015-16

95,365). The case was selected for scrutiny under CASS. Notice u/s 143(2) was issued on 08.04.2016. Thereafter notices u/s 142(1) were issued on multiple occasions. 3. During the course of the scrutiny assessment proceedings, the Assessing Officer examined the books of account, the investments made by the assessee in various companies, the expenditure claimed in the profit

THE DCIT, CIRCLE-1(1),, VADODARA vs. GUJARAT STATE FERTILIZERS & CHEMICALS LTD.,, VADODARA

Appeal is dismissed and assessee’s appeal is partly allowed

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

disallowed the interest expenses of Rs.1,82,91,360/- and administrative expenses of Rs.2,12,49,050/- invoking the provisions of Section 14A by making total addition of Rs.3,95

GUJARAT STATE FERTILISERS & CHEMICALS LTD.,,VADODARA vs. THE DY,CIT, CIRCLE-1(1)(1), VADODARA

Appeal is dismissed and assessee’s appeal is partly allowed

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

disallowed the interest expenses of Rs.1,82,91,360/- and administrative expenses of Rs.2,12,49,050/- invoking the provisions of Section 14A by making total addition of Rs.3,95

DUSHYANTSINH YADVENDRASINH CHUDASAMA,VADODARA vs. INCOME TAX OFFICER, WARD-1(2)(4), VADODARA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita Nos.353/Ahd/2022 & 354/Ahd/2022 िनधा"रण वष" /Assessment Years : 2014-15 & 2015-16 Respectively Dushyantsinh Yadvendrasinh The Dy.Commissioner Of बनाम/ Chudasama Income Tax V/S. C/O.Anil R. Shah (Ca), Circle -1 (2) Shreeji House, 4Th Floor Vadodara – 390 007 B/H. M.J. Library Ahmedabad - 380 006 "थायी लेखा सं./Pan: Acrpc 1888 M (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Kinjal Shah, Ar Revenue By : Shri Rignesh Das, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 12 /03/2025 घोषणा की तारीख /Date Of Pronouncement: 19 /03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am:

95,380/- 23,18,010/- 21.12.2016 28.12.2017 Date & Section of AO's Passed u/s 143(3) Passed u/s 143(3) Order of the Act of the Act 2.1. For A.Y. 2014-15, the Assessing Officer (AO) disallowed