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 qua the properties held as stock in trade on account of deemed rental income. 6.4 As the assessee succeeds on the reasoning as elaborated in the preceding paragraph, therefore we are not inclined to adjudicate the other contentions raised by the Ld.AR for the assessee. Hence the ground of appeal of the assessee is allowed. ITA Nos.37-38/AHD/2021 A.Y.s

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period

THE ACIT., PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. M/S. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE ACIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

THE DCIT, PATAN CIRCLE,, PATAN vs. RANJIT BUILDCON LTD.,, UNJHA

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

property for 59 months and defect liability period of 2 months specifically in some of the projects which envisage that the assessee is sole infrastructure developer in the present scenario in the projects where CIT(A) has observed so and there was no other third party involved in these projects for conducting the sub- delegation of the work awarded

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

House, Vs Ahmedabad Near Kalgi X Rasta, Gujarat College Road, Ellisbridge, Ahmedabad-380006, Gujarat, India PAN: AACCC7727M (Respondent) (Appellant) Assessee Represented: Shri DhaneshBafna, Shri Amol Mahajan & Ms. Nidhi Agarwal, A.Rs. Revenue Represented: Shri Alpesh Parmar, CIT- DR Date of hearing : 08-01-2026 Date of pronouncement : 29-01-2026 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

property cannot be assessed at its citizen’s income. • that alleged income tax refund money receipts of Rs. 21.98 lakhs, belongs to Govt. of India, and hence same has been recovered fully by Govt. of India. Even though same has been assessed as income of Appellant vide

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

property cannot be assessed at its citizen’s income. • that alleged income tax refund money receipts of Rs. 21.98 lakhs, belongs to Govt. of India, and hence same has been recovered fully by Govt. of India. Even though same has been assessed as income of Appellant vide

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

x) That "a contractor" is not responsible for the development of the project but his responsibility is limited to the job- AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited AY:2014-15 assigned to him. (xi) That a "contractor's" duties and responsibilities can only

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

x) That "a contractor" is not responsible for the development of the project but his responsibility is limited to the job- AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited AY:2014-15 assigned to him. (xi) That a "contractor's" duties and responsibilities can only

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. AJAY ENGG. INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

x) That "a contractor" is not responsible for the development of the project but his responsibility is limited to the job- AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited AY:2014-15 assigned to him. (xi) That a "contractor's" duties and responsibilities can only

THE ACIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

x) That "a contractor" is not responsible for the development of the project but his responsibility is limited to the job- AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited AY:2014-15 assigned to him. (xi) That a "contractor's" duties and responsibilities can only