THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM LTD.,, AHMEDABAD

In the result, revenue’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be made on all payments

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM PVT. LTD.,, AHMEDABAD

In the result, the appeal is dismissed

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be made on all payments

KARNAVATI ENGINEERING LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-4,, AHMEDABAD

In the result, the appeal is allowed in the terms indicated above

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be made on all payments

THE ACIT, CIRCLE- 2(1)(1),, AHMEDABAD vs. M/S. GUJARAT AMBUJA EXPORTS LIMITED,, AHMEDABAD

Bench: Us.

property in India, or through or from any asset or source of income in India or through the transfer of a capital asset situated in India. I.T.A No. 1550/Ahd/2017 A.Y. 2014-15 Page No 15 ACIT vs. M/s. Gujarat Ambuja Exports Ltd. Explanation - 1: Business of which all the operations are not carried out in India. It means: The overseas

THE DY.DIT, (INTL. TAXN.)- 1,, AHMEDABAD vs. VODAFONE WEST LTD., AHMEDABAD

In the result, appeal of the Revenue stands dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.2398/Ahd/2014 "नधा"रण वष" /Assessment Year : 2013-14 The Dcit (International Vodafone West Ltd. बनाम/ Taxation)-1 Vodafone House Ahmedabad Corporate Road V/S. Prahladnagar Off S.G. Highway Ahmedabad-380 051 "थायी लेखा सं./Pan: Aaacf 1190 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Dinal Shah, Ar Revenue By : Shri Sudhakar Verma, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 04/07/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Revenue As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-Gandhinagar (Ahmedabad) [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 02/06/2014, Arising Out Of The Assessment Order Passed By The Dy.Director Of Income-Tax (International Taxation)-1, Ahmedabad (Ao) Under Section 201(1) & 201(1A) The Dcit (Intl.Taxn.)-1 Vs. Vodafone West Ltd. Asst. Year : 2013-14

House Ahmedabad Corporate Road v/s. Prahladnagar Off S.G. Highway Ahmedabad-380 051 "थायी लेखा सं./PAN: AAACF 1190 P अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee by : Shri Dinal Shah, AR Revenue by : Shri Sudhakar Verma, Sr.DR सुनवाई क" तार"ख/Date of Hearing : 04/07/2024 घोषणा क" तार"ख /Date of Pronouncement: 12/07/2024 आदेश/O R D E R PER SHRI MAKARAND

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

permanent establishment in India; that in any case, the impugned amounts were not liable to tax in India. References were made to several decisions in this regard. 12. The ld.DR, on the other hand, pointed out that these arguments were not made by the ld.counsel for the assessee before the lower authorities and were being raised for the first time

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

permanent establishment in India; that in any case, the impugned amounts were not liable to tax in India. References were made to several decisions in this regard. 12. The ld.DR, on the other hand, pointed out that these arguments were not made by the ld.counsel for the assessee before the lower authorities and were being raised for the first time

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

permanent establishment in India; that in any case, the impugned amounts were not liable to tax in India. References were made to several decisions in this regard. 12. The ld.DR, on the other hand, pointed out that these arguments were not made by the ld.counsel for the assessee before the lower authorities and were being raised for the first time

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

permanent establishment in India; that in any case, the impugned amounts were not liable to tax in India. References were made to several decisions in this regard. 12. The ld.DR, on the other hand, pointed out that these arguments were not made by the ld.counsel for the assessee before the lower authorities and were being raised for the first time

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be made on all payments

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax From The Payments Made To M/S. Urja International, Usa Which Proves That The

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be made on all payments

M/S. HAATHEE VENTURES,,VADODARA vs. INCOME TAX OFFICER, WARD-3(1)(1),, VADODARA

In the result, ground number 3 of the assessee’s appeal is allowed

Bench: The Hearing Of The Appeal.”

established legal position that once the permission is allowed, it relates back to the date of application in substance. Moreover, the purchaser was fully aware about this factual position about the permission and having agreed to purchase the property, he had taken a calculated risk. It is also worthwhile to mention that from the date of allotment, the purchaser

SHRI PRASHANT MANHARLAL SHAH,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-7(1),, AHMEDABAD

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasadआयकर अपील सं./I.T.A. No.08/Ahd/2014 ("नधा"रण वष" / Assessment Year : 2008-09) Prashant Manharlal Shah The Income-Tax बनाम/ Prop. Prashant Auto Parts Officer, Vs. 4, India Estate Ward-7(1), B/H. Relief Hotel Ahmedabad. Sanand Road, Sarkhej Ahmedabad. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aeaps 0277 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) Shri S.N. Divatia, Ar अपीलाथ" ओर से / Appellant By : Shri Dinesh Singh, Sr.Dr ""यथ" क" ओर से/Respondent By :

house property.: (i) Stamp duty Rs. 42,145 (ii) Life time maintenance contribution Rs. 2,02,920 (iii) Extra Civil works Rs. 5,80,607 (iv) Painting expenses Rs. 2,09,100 (v) Termite exp. Rs. 25,000 (vi) GEB Elec. charges Rs. 40,000 ii.b That in the facts and circumstances of the case as well

THY ACIT, CIRCLE-2(1)(2), , AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

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

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

House Technologies LLC S, Vibgyour International FZ LLC have also been paid in the preceding years and the AO has allowed such commission payments and no disallowance in this regard has been made in the scrutiny assessment completed for A. Y. 2011-12. It was also pleaded that they have complied the provisions of I. T. Act, DTAA and accordingly

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

In the result, the revenue’s appeal is thus dismissed

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

House, 51, Chandrodaya Ahmedabad-380 014. Society, Opp: Golden Tirangle, Stadium Road, Ahmedabad -380 014. [PAN No. AAACM 7930 Q] (Appellant) (Respondent) .. Appellant by : Shri Lalit P. Jain, Sr. D.R. Respondent by : Shri Sunil Talati, A.R. Date of Hearing 06/09/2018 Date of Pronouncement 30/11/2018 O R D E R PER Ms. MADHUMITA ROY - JM: The instant appeal has been preferred

THE DCIT, CIRCLE-4(1)(2), AHMEDABAD vs. TROIKAA PHARMACEUTICALS LTD, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be ITA nos.939 & 1129/AHD/2019 With C.O.Nos

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD vs. TROIKAA PHARMACEUTICLAS LIMITED,, AHMEDABAD

In the result, the CO filed by the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms Madhumita Royआयकर अपील सं./Ita Nos. 939 & 1129/Ahd/2019 With C.O.Nos.169 & 181/Ahd/2019 िनधा"रण वष"/Asstt. Years: 2011-2012 & 2012-2013 D.C.I.T., Troikaa Pharmaceuticals Ltd., Circle-4(1)(2), Vs. Commerce House-I, Ahmedabad. Opp. Rajvansh Apartment, Judges Bunglow Road, Ahmedabad-380054. Pan: Aabct0228K

permanent establishment in India, they are liable to be taxed in India. 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount by way of commission to foreign agents for the services rendered outside India; (b) the Tax Deduction at Source (TDS) is required to be ITA nos.939 & 1129/AHD/2019 With C.O.Nos

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

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

permanent establishment in India, they are liable to be taxed in India. ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 17 of 37 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

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

permanent establishment in India, they are liable to be taxed in India. ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 17 of 37 5.1 Yet another contention of the learned counsel for the assessee is that: (a) the assessee paid the amount