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

THE ITO, WARD-2(1)(1),, AHMEDABAD vs. M/S. GPSAR HEALTHCARE LTD.,, AHMEDABAD

In the result, both the appeals filed by the revenue on this issue for A

house property, capital gain, interest on security and any other sources but income from other business activities. Now, with regard to the allocation of the expenditures, the appellant has simply contended that on the share trading business, it had only incurred the fund management expenses of Rs.1,24,488/- and no other expenses have been incurred is found not correct

GPSAR HEALTH CARE LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-4,, AHMEDABAD

In the result, both the appeals filed by the revenue on this issue for A

house property, capital gain, interest on security and any other sources but income from other business activities. Now, with regard to the allocation of the expenditures, the appellant has simply contended that on the share trading business, it had only incurred the fund management expenses of Rs.1,24,488/- and no other expenses have been incurred is found not correct

APPLEWOODS ESTATE PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1),, AHMEDABAD

In the result, appeal of the assessee in ITA No

Bench: Shri Rajpal Yadav & Shri Pradip Kumar Kediaआयकर अपील सं./I.T.A. No. 198/Ahd/2018 ("नधा"रण वष" / Assessment Year : 2012-13)

housing for economically weaker section, commercial offices and shops within the residual FSI left as per the approved master plan by AUDA. In the given set of arrangement, the total cost of remaining land, and construction WIP was suitably reduced having regard to the cost attributable to sale of FSI and only reduced cost has been allocated towards sale

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

313 ITR 340 has held that if there are mixed funds then the power presumption would be that the investments have been made out of interest free funds. This ratio of the Hon'ble High Court of Bombay was subsequently followed in the case of HDFC Ltd. 266 ITR 505. As mentioned elsewhere, the assessee was having sufficient own funds

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

property. Rather, goodwill is a composite intangible, often representing a spectrum of commercial advantages and strategic benefits which accrue to the acquiring entity as a result of the amalgamation. It is well-settled that goodwill may encompass diverse elements such as the continuity of trained workforce, access to regulatory licenses, embedded operational systems, management expertise, optimized supply chain alignment, intra

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

property. Rather, goodwill is a composite intangible, often representing a spectrum of commercial advantages and strategic benefits which accrue to the acquiring entity as a result of the amalgamation. It is well-settled that goodwill may encompass diverse elements such as the continuity of trained workforce, access to regulatory licenses, embedded operational systems, management expertise, optimized supply chain alignment, intra

THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. PRIYAL INTERNATIONAL PVT. LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./Ita.No.91/Ahd/2019 "नधा"रण वष"/Asstt. Year: 2015-16 Dcit, Cir.3(1)(1) M/S. Priyal Internaional P. Ltd. Ahmedabad. 297/300, Phase-Ii, Gidc Vs. Vatva, Ahmedabad. Pan : Aaecp 4640 A (Applicant) (Responent) Assessee By : Shri M.K. Patel, Advocate Revenue By : Shri S.S. Shukla, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 04/03/2022 घोषणा क" तार"ख /Date Of Pronouncement: 20/04/2022 आदेश/O R D E R

Section 14A of the Act cannot be applied for taxing interest on such borrowed funds." (iv) CIT vs. Deepak Mittal (2013) 361 ITR 131 (P&H-HC) "The AO had not brought on record any expense having been incurred by the assessee to earn the non-exempt income or the exempt income. In the absence of the same, it could

ASSTT.COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. PRIYAL INTERNATIONAL P.LTD.,, AHMEDABAD

In the result Ground No. 4 of the Revenues appeal is dismissed

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasadआयकर अपील सं./I.T.A. No. 3115/Ahd/2015 ("नधा"रण वष" / Assessment Year: 2011-12)

House Ahmedabad Mithakhali Six Roads Navrangpura, Ahmedabad- 380009 "थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAECP4640A .. (अपीलाथ" /Appellant) (""यथ" / Respondent) अपीलाथ" ओर से /Appellant by : Lalit P. Jain, Sr. DR ""यथ" क" ओर से / Respondent Mehul K Patel, AR by : सुनवाई क" तार"ख / Date of 17/12/2018 Hearing घोषणा क" तार"ख /Date of 15/02/2019 Pronouncement आदेश

THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. PRIYAL INTERNATIONAL PVT. LTD.,, AHMEDABAD

In the result, the appeal of the revenue is dismissed

section 14A of the Act. The CIT(A) granted relief to the assessee from such disallowance on the ground that the interest free funds at the disposal of the assessee is in excess of the corresponding investments yielding tax free income. On such facts, we do not see any reason to interfere with the aforesaid findings in view

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

properties are analysed and tested in the form of trial batch, pilot batch, scale up batch, exhibit batch etc. to achieve the complete R&D result. Considering the nature of the activity, it is clear that the analytical and testing expenditure are in form of research and development expenditure and are hence eligible for weighted deduction under section

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

properties are analysed and tested in the form of trial batch, pilot batch, scale up batch, exhibit batch etc. to achieve the complete R&D result. Considering the nature of the activity, it is clear that the analytical and testing expenditure are in form of research and development expenditure and are hence eligible for weighted deduction under section

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

properties are analysed and tested in the form of trial batch, pilot batch, scale up batch, exhibit batch etc. to achieve the complete R&D result. Considering the nature of the activity, it is clear that the analytical and testing expenditure are in form of research and development expenditure and are hence eligible for weighted deduction under section

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

properties are analysed and tested in the form of trial batch, pilot batch, scale up batch, exhibit batch etc. to achieve the complete R&D result. Considering the nature of the activity, it is clear that the analytical and testing expenditure are in form of research and development expenditure and are hence eligible for weighted deduction under section

THE ACIT CIRCLE-3(3), AHMEDABAD vs. SHRI CHANDRAKANT G PATEL, AHMEDABAD

Appeal of the Revenue is dismissed

properties and appellant has offered above income as taxable income vide letter dated 16/11/2016. It is matter of fact that notice u/s 142(1) of the Act was issued on appellant 02/12/2016 wherein it was asked to put justification for treating business profit as exempt but prior to such notice, appellant has already offered gain on sale of agricultural land

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

house research and development was eligible for weighted deduction under section 35(2AB). 7. Re: Disallowance on account of R&D expenses incurred by the Appellant alleged to have been incurred for products manufactured by partnership firms Sun Pharmaceutical Industries (SPI) and Sun Pharma Sikkim (SPS) debited in the books of the Appellant: 7.1 On the facts

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1),, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

house research and development was eligible for weighted deduction under section 35(2AB). 7. Re: Disallowance on account of R&D expenses incurred by the Appellant alleged to have been incurred for products manufactured by partnership firms Sun Pharmaceutical Industries (SPI) and Sun Pharma Sikkim (SPS) debited in the books of the Appellant: 7.1 On the facts

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

house research and development was eligible for weighted deduction under section 35(2AB). 7. Re: Disallowance on account of R&D expenses incurred by the Appellant alleged to have been incurred for products manufactured by partnership firms Sun Pharmaceutical Industries (SPI) and Sun Pharma Sikkim (SPS) debited in the books of the Appellant: 7.1 On the facts