MOHIT VIJAYKUMAR GUPTA,MUMBAI vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed, Ground No

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1091/Ahd/2025 िनधा"रण वष" /Assessment Year : 2021-22 Mohit Vijaykumar Gupta The Dcit बनाम/ B-1001, Juhu Trishul, Circle-2(1)(1) V/S. Gulmohar Cross Road No.6 Ahmedabad – 380 015 Jvpd Vile Parle West Mumbai – 400 049 "थायी लेखा सं./Pan: Adfpg 7162 D (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri J. C. Desai, Ca Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 06/08/2025 घोषणा की तारीख /Date Of Pronouncement: 06/11/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 14/12/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2021-2022. 2. The Assessee Has Raised The Following Grounds Of Appeal: Mohit Vijaykumar Gupta Vs. Dcit Asst. Year : 2021-22

108,675). (b) Your appellant prays that the Ld. A O may be directed to modify the addition on account of deemed rent to ₹.2,53,575/- as against ₹.13,86,000/-. 4. Your Appellant craves leave to add, to alter to vary or to amend the above grounds of appeal.” 3. The brief facts of the case are that

LALITADEVI N. TIBREWALA,,AHMEDABAD vs. THE PR. CIT, , AHMEDABAD

In the result, the appeal of the assessee is dismissed as infructuous

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita No. 318/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2012-2013 Lalitadevi N. Tibrewala, Pr. Commissioner Of 6, Professor Colony, Vs. Income Tax, Nr. Vijay Cross Roads, Ahmedabad-5 Navrangpura, Ahmedabad-380009. Pan: Aappt0073M

house was constructed on or before 4th March 2011, a date much before the transfer of the property in dispute i.e. 27-05-2011. Accordingly, the PCIT was of the view that the assessee is not eligible for exemption/deduction under section 54 of the Act against the sale of the property dated 27th of May 2011. However, the AO without

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

108 (Kerala) iii. Netra Software Technologies (P.) Ltd. vs. ACIT (CPC), [2022] 138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

108 (Kerala) iii. Netra Software Technologies (P.) Ltd. vs. ACIT (CPC), [2022] 138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77

SHRI GIRISHBHAI VADILAL SHAH,,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, appeal preferred by the assessee in ITA No

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 330, 331 & 332/Ahd/2020 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Years : 2014-15, 2015-16 & 2016-17) िनधा"रण वष" Girishbhai Vadilal Shah Dcit बनाम बनाम/ बनाम बनाम 139, V R Shah Smruti Circle – 4(1)(2), Vs. Shikshan Mandir, Nr. Ahmedabad Dharnidhar Derasar, Vasna, Ahmedabad, Gujarat, 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Abjps3102P (Appellant) .. (Respondent) Shri Jaimin Shah, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Ms. Saumya Pandey Jain, Sr. Dr Date Of Hearing 26/06/2024 Date Of Pronouncement 15/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: These Three Appeals Are Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-8, Ahmedabad, (In Short The ‘Cit(A)’), (In Short ‘The Cit(A)’) All Dated 16.03.2020 For The Assessment Year 2014-15, 2015-16 & 2016-17. As The Issues Involved In The Three Appeals Are Common, They Were Heard Together & Are Being Disposed Vide This Common Order.

108 (Kerala) iii. Netra Software Technologies (P.) Ltd. vs. ACIT (CPC), [2022] 138 taxmann.com 309 (Bangalore-Trib.) ITA Nos. 330, 331 & 332/Ahd/2020 [Shri Girishbhai Vadilal Shah vs. DCIT] A.Ys. 2014-15 to 2016-17 - 7 – 9. We have carefully considered the rival submissions and perused the materials on record. There is no dispute to the fact that disallowance of Rs.77

THE ITO, WARD-1(2)(4), BARODA vs. SHRI NATWARBHAI J. PATEL, VADODARA

In the result, both the appeals are partly allowed for statistical purposes in the terms indicated above

property and if such investment is made within the period stipulated therein, then Section 54F(4) is not at all attracted and therefore the contention that the assessee has not deposited the amount in the Bank account as stipulated and therefore, he is not entitled to the benefit even though he has invested the money in construction is also

SHRI NATWARBHAI J. PATEL,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(4), VADODARA

In the result, both the appeals are partly allowed for statistical purposes in the terms indicated above

property and if such investment is made within the period stipulated therein, then Section 54F(4) is not at all attracted and therefore the contention that the assessee has not deposited the amount in the Bank account as stipulated and therefore, he is not entitled to the benefit even though he has invested the money in construction is also

THE ITO, WARD-1(2)(5), VADODARA vs. SHRI VINODBHAI J. PATEL, VADODARA

In the result, both the appeals are partly allowed for statistical purposes in the terms indicated above

property and if such investment is made within the period stipulated therein, then Section 54F(4) is not at all attracted and therefore the contention ITA Nos. 464 & 513/Ahd/2016 ITO vs. Vinodbhai J Patel -cross Assessment Year : 2012-13 Page 6 of 12 that the assessee has not deposited the amount in the Bank account as stipulated and therefore

SHRI VINODBHAI J. PATEL,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(5), VADODARA

In the result, both the appeals are partly allowed for statistical purposes in the terms indicated above

property and if such investment is made within the period stipulated therein, then Section 54F(4) is not at all attracted and therefore the contention ITA Nos. 464 & 513/Ahd/2016 ITO vs. Vinodbhai J Patel -cross Assessment Year : 2012-13 Page 6 of 12 that the assessee has not deposited the amount in the Bank account as stipulated and therefore

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

House Property [as per Return of Income] Rs. 10,34,525/- B. Business Income [as per Return of income] Rs.14,81,24,50,439/- Add: Additions / disallowances as discussed above ITA No. 162/Ahd/2021 (Zydus Lifesciences Ltd. vs. DCIT) A.Y.– 2016-17 - 7 – 1. Transfer pricing adjustment on account Rs. 10,29,60,436/- of corporate guarantee (as per Para

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

properties. 8.2 Shri Mohan Bishnoi was authorized by M/s. Bishnoi Trading Corporation for the purpose of banking transactions whereas Shri Omprakash Bishnoi was authorized by M/s. Bishnoi Trading Corporation for effecting import- export related transactions; that they had authorized M/s. Palak Logistics, Mumbai for their activities at Nhava Sheva and M/s. Trinity Shipping, Gandhidham for their activities at Gandhidham; that

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

properties. 8.2 Shri Mohan Bishnoi was authorized by M/s. Bishnoi Trading Corporation for the purpose of banking transactions whereas Shri Omprakash Bishnoi was authorized by M/s. Bishnoi Trading Corporation for effecting import- export related transactions; that they had authorized M/s. Palak Logistics, Mumbai for their activities at Nhava Sheva and M/s. Trinity Shipping, Gandhidham for their activities at Gandhidham; that

AXIS BANK LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-1 NOW CIRCLE-1(1)(1), AHMEDABAD

In the result appeal of the Revenue is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedsl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 311/Ahd/2016 2010-11 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 2. 2176/Ahd/2016 2011-12 Axis Bank Limited, D.C.I.T., “Trishul”, 3Rd Floor, Circle-1(1)(1) Opp. Samtheshwar Ahmedabad. Mahadev Near Law Garden, Ellisbridge, Ahmedabad-380006. Pan: Aaacu2414K 3. 2173/Ahd/2016 2011-12 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 4. 165/Ahd/2017 2012-13 Axis Bank Limited, D.C.I.T., Ahmedabad. Circle-1(1)(1) Ahmedabad. Pan: Aaacu2414K 5. 287/Ahd/2017 2012-13 D.C.I.T., Axis Bank Limited, Circle-1(1)(1) Ahmedabad. Ahmedabad. Pan: Aaacu2414K 6-7 520 & 2013-14 Axis Bank Limited, D.C.I.T., 521/Ahd/2018 & Ahmedabad. Circle-1(1)(1) 2014-15 Ahmedabad. Pan: Aaacu2414K 8-9 604 & 605/ 2013-14 D.C.I.T., Axis Bank Limited, Ahd/2018 & Circle-1(1)(1) Ahmedabad. 2014-15 Ahmedabad. Pan: Aaacu2414K

section 43D is a beneficial provision but the provision iS very clear when it states that " {a} in the case of a scheduled bank the income by way of interest in relation to such categories of bad and^dou^btful debts as may be prescribed having regard to the guidelines issued by the Reserve Bank of India in relation

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

In the result, the appeal of the Revenue and the Cross-objection of the assessee, both are dismissed

Bench: Shri Sandeep Gosain & Shri Amarjit Singh

House Vs. Ahmedabad Nr.Dinesh Hall Off Ashram Road, Ahmedabad "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AACCT 0294 J (अपीलाथ" /Appellant) .. (""यथ"/Respondent & Cross Objector) Revenue by : Shri Samir Tekriwal, CIT-DR Assessee by : Shri Vartik Chowkshi सुनवाई क" तार"ख /Date of Hearing 03/03/2020 05 /03/2020 घोषणा क" तार"ख /Date of Pronouncement आदेश

SANDIP KANUBHAI PATEL,AHMEDABAD vs. THE PR.CIT-3, AHMEDABAD

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

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकर अपील सं./Ita No. 104/Ahd/2022 िनधा"रण वष"/Asstt. Year:2017-2018 Sandip Kanubhai Patel, Principal Commissioner Of Avirat House, Vs. Income Tax-3, Nr. Science City, Ahmedabad. Sola Science City Road, Sola, Ahmedabad.

housing project going on said land. 4.3 Similarly, with respect to new property, the inspector submitted that the land is vacant and there was boundary wall constructed on the same. The inspector also received report from Talati stating that no crop was grown on said land. The said land on the date of purchase by the assessee already included

SHRI NANDKISHORE S. SODHAN(HUF),,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 994/Ahd/2016 "नधा"रण वष"/Assessment Year: 2011-12 Shri Nandkishore S. Shodhan Ito, Ward-5(2)(3) (Huf) Vs Ahmedabad. D/11-12, Silver Arc Kavi Nanalal Marg Ellisbridge Pan : Aadhs 4064 F

properties were owned by the Assessee : (i) Devji Saraiya S.Pole, Sankadi Sheri, Ahmedabad (ii) D/ll-12, Silver Arc, Kavi Nanalal Marg, Ellisbridge, Ahmedabad (e) As per the proviso to section 54F(1) of the Act, if the assessee owns more than one residential house, other than the new asset, on the date of transfer of the original asset; the deduction u/s.54F

SMT. ARUNABEN S. PATEL,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(3), VADODARA

In the result, the appeal for the assessee is partly allowed for statistical purpose

108/-. The assessing officer has rejected the claim of deduction u/s. 54F of the act on the ground that the original asset was transferred on 17th Sep, 2011 therefore the assessee should have purchased a new house within a span of two years or should have constructed a new house within a period of three years from the date

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, CIRCLE-1(1)(2), AHMEDABAD

Appeal are dismissed as not pressed

property transferred or services provided in a comparable uncontrolled transaction, or a number of such transactions, is identified, and then such price is adjusted to account for differences, if any, between the international transaction and the comparable uncontrolled transactions or between the enterprises entering into such transactions, which could materially affect the price in the o pen market. Usually loan

SHRI AMRUTBHAI ATMARAMBHAI PATEL, HUF,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-6(3),, AHMEDABAD

In the result, the ground no 1 of appeal is partly allowed for statistical purpose, ground no

108/- charged by the learned AO on the ground that such levy is consequential. It is submitted that in the facts and circumstances of the case, interest u/s 234B is not chargeable upon the assessee and the same should be directed to be deleted.” I.T.A No. 1737/Ahd/2015 & 118/Ahd/2016 A.Y. 2011-12 Page No 3 Ritaben P Patel & Amrutbhai A. Patel