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

house R and D Centre. This clam was made on the basis of recognition issued by the DSIR to erstwhile Celestial Biologicals Ltd. for the period of three years from 1.4.2013. The Co-ordinate Bench, in its order for A.Y. 2013–14, has already accepted such claims as allowable u/s 35(2AB), following the decision of the Hyderabad Bench

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

house R and D Centre. This clam was made on the basis of recognition issued by the DSIR to erstwhile Celestial Biologicals Ltd. for the period of three years from 1.4.2013. The Co-ordinate Bench, in its order for A.Y. 2013–14, has already accepted such claims as allowable u/s 35(2AB), following the decision of the Hyderabad Bench

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM LTD.,, AHMEDABAD

In the result, revenue’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non- resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

M/S. INOX INDIA LTD.,,BARODA vs. THE PR. CIT-1,, VADODARA

In the result, the appeal is allowed

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-4,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM PVT. LTD.,, AHMEDABAD

In the result, the appeal is dismissed

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax From The Payments Made To M/S. Urja International, Usa Which Proves That The

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

M/S. PANASONIC ENERGY INDIA CO.LTD,VADODARA vs. THE PR. CIT-2,, BARODA

In the result, the appeal is allowed

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

KARNAVATI ENGINEERING LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-4,, AHMEDABAD

In the result, the appeal is allowed in the terms indicated above

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax

35. In the light of the above legal position, what we need to decide at the outset is whether the amounts paid by the assessee to the non-resident agents could be termed as "consideration for the rendering of any managerial, technical and consultancy services". As we do so, it is useful to bear in mind the fact that even

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

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

house research & development and therefore, the same is not eligible for weighted deduction u/s. 35(2AB) of the Act. Similarly, capitalized interest on purchase of car is also not eligible for this benefit for same reasons because it is equal or similar to cost of car. Hence, this ground is rejected. Being aggrieved by the order of the learned