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

property, liabilities and issues of the resulting company. Under section 47(vib) of the Income Tax Act, 1961, a demerger involving transfer of capital assets by the demerged company to the resulting company (Indian Company). will not attract levy of capital gain tax. Similarly, under section 47(vid) of the Income Tax Act, 1961 if there is an issue

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

property, liabilities and issues of the resulting company. Under section 47(vib) of the Income Tax Act, 1961, a demerger involving transfer of capital assets by the demerged company to the resulting company (Indian Company). will not attract levy of capital gain tax. Similarly, under section 47(vid) of the Income Tax Act, 1961 if there is an issue

THE DCIT, CIRCLE-2(2), AHMEDABAD vs. SHREE PARSHWANATH CORPORATION,, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

housing project within the prescribed period of four years. The matter was carried before first appellate authority, wherein the various contentions were raised on behalf of assessee and having considered the same, the CIT(A) granted relief to the assessee on this account as well. The same has been opposed before us on behalf of revenue. On the other hand

THE DCIT, CIRCLE-2(2), AHMEDABAD vs. SHREE PARSHWANATH CORPORATION,, AHMEDABAD

Bench: Shri Pramod M Jagtap & Ms. Madhumita Roy

housing project within the prescribed period of four years. The matter was carried before first appellate authority, wherein the various contentions were raised on behalf of assessee and having considered the same, the CIT(A) granted relief to the assessee on this account as well. The same has been opposed before us on behalf of revenue. On the other hand

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

RAKESHKUMAR MAHENDRAKUMAR SHAH,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(3), AHMEDABAD

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

173/- and USD 18,700 were found and seized from his residence and lockers. Notices under sections 143(2) and 142(1) were issued on various dates, namely 04.10.2023, 14.08.2023, 22.08.2023, 09.01.2024, 18.01.2024 and 21.02.2024, calling for explanations from the assessee. Though several opportunities were provided, the assessee filed delayed and non-specific replies and avoided answering transaction-wise queries

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. RAKESHKUMAR MAHENDRAKUMAR SHAH , AHMEDABAD

The appeal of the assessee stand dismissed, and the order of the CIT(Appeals) is hereby affirmed in toto

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

173/- and USD 18,700 were found and seized from his residence and lockers. Notices under sections 143(2) and 142(1) were issued on various dates, namely 04.10.2023, 14.08.2023, 22.08.2023, 09.01.2024, 18.01.2024 and 21.02.2024, calling for explanations from the assessee. Though several opportunities were provided, the assessee filed delayed and non-specific replies and avoided answering transaction-wise queries

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-8,, AHMEDABAD

In the result appeal of the Revenue is partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita.No.1285 & 1286/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2009-10 & 2010-11 & Ita No.1396 & 1397/Ahd/2018 Asstt.Year 2011-12 & 2012-13 Torrent Pharmaceuticals Ltd. Acit, Circle-4(1)(2) Torrent House Ahmedabad. Vs. Off.Ashram Road Ahmedabad 380 009. आयकर अपील सं./Ita.No.1327 & 1328/Ahd/2017 िनधा"रण वष"/ Asstt. Year: 2009-10 & 2010-11 & आयकर अपील सं./Ita.No.1414 & 1415/Ahd/2018 िनधा"रण वष"/ Asstt. Year: 2011-12 & 2012-13 Acit, Circle-4(1)(2) Torrent Pharmaceuticals Ltd. Ahmedabad. Torrent House Vs. Off.Ashram Road Ahmedabad 380 009. (Applicant) (Responent) Assessee By : Shri Vartik Choksi, With Shri Biren Shah, Ars. Revenue By : Shri Mohd. Usman, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 23/11/2021 घोषणा क" तारीख /Date Of Pronouncement: 22/02/2022 आदेश/O R D E R Per Bench

properties of the company including manufacturing facilities, research facilities and office premises. v. A minimum fixed asset cover of 1.1 times over these assets. vi. Net debt / EBIDTA to be not more than 4.5 times vii. Debt gearing not to exceed 1.65 times during the currency of facility. viii. Debt service cover ratio shall not be less than 1.33 times

SHRI UMANG H. THAKKAR,AHMEDABAD vs. THE DY.CIT.,WARD-7(2),, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

property appreciating the facts of the case and the materials brought on record by the AO. (1.2) The Ld. CIT[A]-XVI, Ahmedabad has erred in law and on facts in accepting the contention of the assessee that the amount of unexplained income has already been offered for tax without appreciating that the assessee could not substantiate its claim

THE DCIT, CIRCLE-11,, AHMEDABAD vs. SHRI UMANG HIRALAL THAKKAR, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

property appreciating the facts of the case and the materials brought on record by the AO. (1.2) The Ld. CIT[A]-XVI, Ahmedabad has erred in law and on facts in accepting the contention of the assessee that the amount of unexplained income has already been offered for tax without appreciating that the assessee could not substantiate its claim

SHREE SANAND JAMALIYA PATIDAR PANCH,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

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

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

property and life and to help them and the victims in every possible way. 13 To start, manage and maintain the girls' school, schools, female colleges for the Girls education and, to undertake activities for the welfare of orphans or aged women, absorbed girls, widows, abandoned, destitute women. 14 To establish, run and maintain home industries, computer classes, education classes

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

Bench: Us.

173 to 385), the same is reproduced hereunder: "Your goodself called for to furnish details of commission paid on export sales along with evidences regarding fixation of commission, debit notes from overseas brokers, related export sale and its realization along with payment by bankers and copies of Form no. 15CA & 15CB in this regard. With regard to commission payment

TORRENT POWER LTD.,,AHMEDABAD vs. THE ACIT.,RANGE-8,, AHMEDABAD

In the result cross objection filed by the assessee is partly allowed for statistical purposes

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

House, Nr. Circle-8, Dinesh Hall, Off Ashram Ahmedabad. Road, Ahmedabad-380009. PAN: AACCT0294J 2. 776/Ahd/2012 2008-09 Torrent Power Limited, A.C.I.T., Ahmedabad. Range-8, Ahmedabad. PAN: AACCT0294J 3. 738/Ahd/2012 2008-09 A.C.I.T., Torrent Power Circle-8, Limited, Ahmedabad. Ahmedabad. PAN: AACCT0294J 4. 1581/Ahd/2012 2009-10 Torrent Power Limited, A.C.I.T., Ahmedabad-380009. Range-8, Ahmedabad. PAN: AACCT0294J ITA nos.1577/AHD/2015 with

THE DCIT, CIRCLE-1,, AHMEDABAD vs. AIA ENGINEERING LTD.,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

AIA ENGINEERING LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

CADILA HEALTHCARE LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

Section 90(2), where there is a DTAA between India and any country outside India, the more favourable of the two provisions, viz., under the DTAA or under the I.T. Act, are to be applied in case of the assessee. However, in my view, the point as to whether the payments are in the nature of fees for technical services

CADILA HEALTHCARE LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, the appeal for the assessment year 2013-14 is also partly allowed in the terms indicated above

Section 90(2), where there is a DTAA between India and any country outside India, the more favourable of the two provisions, viz., under the DTAA or under the I.T. Act, are to be applied in case of the assessee. However, in my view, the point as to whether the payments are in the nature of fees for technical services