THE DCIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is hereby dismissed

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita Nos. 37 & 38/Ahd/2021 धििाधरणणवध/Asstt. Years: 2008-09 & 2017-18 D.C.I.T, M/S Venus Infrastructure & Central Circle-1(1), Vs. Developers Pvt. Ltd., Ahmedabad 1101 Venus Amadeus, Jodhpur Cross Road, Ahmedabad-380015. Pan: Aahcs6254J (Applicant) (Respondent) Revenue By : Shri Akhilendra Pratap Yadaw Assessee By : Shri Tushar Hemani, Sr. Advocate With Shri Parimalsinh B. Parmar & Shri Vijay Govani A.Rs सुिणाईकीतारीख/Date Of Hearing : 08/02/2024 घोवणाकीतारीख/Date Of Pronouncement: 14/02/2024 आदेश/O R D E R Per Waseem Ahmed: The Captioned Two Appeal Have Been Filed At The Instance Of The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-11, Ahmedabad, Of Even Dated 20/01/2021 Arising In The Matter Of Assessment Order Passed Under S. 147 R.W.S. 143(3) & 143(3) Of The Income Tax Act 1961 (Here- In-After Referred To As "The Act") Relevant To The Assessment Years 2008-09 & 2017-18. First, We Take Up Ita No. 38/Ahd/2021, An Appeal By The Revenue For Ay 2017-18

House property. 6. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) ought to have upheld the order of the A.O. 7. It is, therefore, prayed that the order of the Ld. CIT(A) be set aside and that of the A.O. be restored to the above extent. 3. The first issue

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

house properties given on rent and income from other sources such as saving interest, interest from bonds etc. were earned. No business is carried on by me during the year 2. Details of copy of Return of Income filed by you for the relevant Assessment Years along with copy of P&L a/c., Balance Sheet, Capital A/c., Auditor's report

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

house properties given on rent and income from other sources such as saving interest, interest from bonds etc. were earned. No business is carried on by me during the year 2. Details of copy of Return of Income filed by you for the relevant Assessment Years along with copy of P&L a/c., Balance Sheet, Capital A/c., Auditor's report

ARUNABEN KISHORKUMAR MANDALIA,AHMEDABAD vs. THE PR.CIT, CENTRAL, AHMEDABAD

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

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita Nos. 1052 To 1054/Ahd/2025 िनधा"रण वष"/Asstt. Years: 2017-18 To 2020-21 Arunaben Kishorkumar Mandalia, The Principal बनामVs 12, Ashwamegh-Iii, Commissioner Of . 132 Feet Ring Road, Income Tax (Central), Satellite, Ahmedabad. Ahmedabad-380015. Pan: Ablpm2848Q (अपीलाथ" /Appellant ( ""यथ" /Respondent) Assessee By : Shri M K Patel, With Shri Vartik Choksi, Ars Revenue By : Shri Sher Singh, Cit.Dr

house properties given on rent and income from other sources such as saving interest, interest from bonds etc. were earned. No business is carried on by me during the year 2. Details of copy of Return of Income filed by you for the relevant Assessment Years along with copy of P&L a/c., Balance Sheet, Capital A/c., Auditor's report

MAHALAXMI INFRACONTRACT LIMITED,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-1(4), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

House, Opp. Central Circle-1(4), Pakwan-II, S.G. Highway, Ahmedabad Bodakdev, Ahmedabad-380054 [PAN No.AAGCM4615E] (Appellant) .. (Respondent) I.T.A. No.1702/Ahd/2024 (Assessment Year: 2017-18) Mahalaxmi Infracontract Ltd., Vs. Deputy Commissioner of 816-817, Binori B Square-III, Income Tax, Nr. Tradebulls, Sindhu Bhavan Central Circle-1(4), Road, Ahmedabad-380054 Ahmedabad [PAN No.AAGCM4615E] (Appellant) .. (Respondent) Appellant by : Shri Dhinal Shah

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE)-1(4), AHMEDABAD, AHMEDABAD vs. MAHALAXMI INFRACONTRACT LIMITED, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

House, Opp. Central Circle-1(4), Pakwan-II, S.G. Highway, Ahmedabad Bodakdev, Ahmedabad-380054 [PAN No.AAGCM4615E] (Appellant) .. (Respondent) I.T.A. No.1702/Ahd/2024 (Assessment Year: 2017-18) Mahalaxmi Infracontract Ltd., Vs. Deputy Commissioner of 816-817, Binori B Square-III, Income Tax, Nr. Tradebulls, Sindhu Bhavan Central Circle-1(4), Road, Ahmedabad-380054 Ahmedabad [PAN No.AAGCM4615E] (Appellant) .. (Respondent) Appellant by : Shri Dhinal Shah

DEPUTY COMMISSIONER OF INCOME TAX (CENTRAL CIRCLE) -1(4), AHMEDABAD, AHMEDABAD vs. MAHALAXMI INFRACONTRACT LIMITED, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

House, Opp. Central Circle-1(4), Pakwan-II, S.G. Highway, Ahmedabad Bodakdev, Ahmedabad-380054 [PAN No.AAGCM4615E] (Appellant) .. (Respondent) I.T.A. No.1702/Ahd/2024 (Assessment Year: 2017-18) Mahalaxmi Infracontract Ltd., Vs. Deputy Commissioner of 816-817, Binori B Square-III, Income Tax, Nr. Tradebulls, Sindhu Bhavan Central Circle-1(4), Road, Ahmedabad-380054 Ahmedabad [PAN No.AAGCM4615E] (Appellant) .. (Respondent) Appellant by : Shri Dhinal Shah

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

123), the disallowance towards weighted portion works out at Rs. 104.35 lacs. The above grounds are independent and without prejudice to each other. The Appellant prays for leave to add, alter, amend and / or modify any of the grounds of appeal at or before the hearing of the appeal.” 3. The Department has raised the following grounds of appeal

PINKAL SURESHKUMAR KOTHARI,AHMEDABAD vs. THE ITO, WARD-5(2)(1), AHMEDABAD

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

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1303/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2017-18) बनाम/ Pinkal Sureshkumar Income Tax Officer Kothari Ward-5(2)(1), Vs. 4, Nemrajul Flat, Ahmedabad Navavikas Gruh Road, Vasna, Ahmedabad, Gujarat – 380007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Amlpk3944L (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Parth Mehta, A.R. ""यथ" क" ओर से/Respondent By : Shri Nitin Kulkarni, Sr. Dr

house to be Rs 3,60,000 out of salary income and Rs. 2,79,000 (Stamp Duty) out of Cash on hand balance However, Ld. CIT (A) erroneously comprehended our submission to mean that appellant is trying to prove entire source from cash balance. However, Appellant had clearly mentioned that "So, the amount of cash deposited and used

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

House, 1st Floor, G-Block, International Taxation-1, Plot No. C-60, Bandra Kurla Ahmedabad-380014 Complex, Bandra East, Mumbai-400051 [PAN No.AAHCS9360D] (Appellant) (Respondent) .. Appellant by : Shri S. N. Soparkar, Sr. Advocate, Shri Parin Shah, Shri Ankit Gandhi & Ms. Dhruvi Salot, A.Rs. Respondent by: Dr. Darsi Suman Ratnam, CIT D.R. Date of Hearing 23.02.2024 & 06.03.2024 Date of Pronouncement