GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

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

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

194C of the Act r.w.s. 40(a)(ia) of the Act. 16.7 From the preceding discussion we note that all the details of the laborers including the addresses and PAN were available with the authorities below. In case there is any doubt about the labour expenses claimed by the assessee, then the authorities below should have taken the confirmation from

GOLD FINCH JEWELLERY LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

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

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

194C of the Act r.w.s. 40(a)(ia) of the Act. 16.7 From the preceding discussion we note that all the details of the laborers including the addresses and PAN were available with the authorities below. In case there is any doubt about the labour expenses claimed by the assessee, then the authorities below should have taken the confirmation from

ELECTRONIC INSTRUMENTATION & CONTROL PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-4,, AHMEDABAD

In the result, these grounds of assessee’s appeal are partly allowed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

68,727/- as the income from manufacturing activities of the assessee disallowed Rs.12,18,000/- , the claim u/s. 80IB of the Act in the year under consideration. In appeal, the same has been confirmed by the Learned CIT(A). Hence, the instant appeal is before us. 5. The Learned Counsel appearing for the assessee vehemently argued that supervision work relating

M/S. BINORI INFRACON,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(2)(1), AHMEDABAD

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2017-18 M/S.Binori Infracon The Dy.Cit Old S.No.319/2, Block No.440 Vs Circle-3(2)(1) Binori Gracia Ahmedabad Opp. Sobo Centre, South Bopal Ahmedabad – 380 058 (Gujarat) Pan: Aaofb 4823 E अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan Shah, Advocate Revenue By : Shri Nitin Vishnu Kulkarni, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 12/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 14/06/2024

68,76,546/-. The return was processed under section 143(1) of the Act. The case was selected for scrutiny under the CASS, and a notice under section 143(2) of the Act was issued on 10-08-2018, which was duly served on the assessee. Subsequently, the case was transferred to another Assessing Officer (AO), who issued

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

194C of the Act, and the Assessee’s inability to demonstrate compliance, that the facts of the assessee’s case warranted disallowance under Section 40(a)(ia) of the Act. Ld. Assessing Officer observed that section 40(a)(ia) of the Act disallows ITA No. 931/Ahd/2015 & 448/Ahd/2016 Hagglunds Drives (India) Pvt. Ltd./ Bosch Rexroth (India

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

194C of the Act, and the Assessee’s inability to demonstrate compliance, that the facts of the assessee’s case warranted disallowance under Section 40(a)(ia) of the Act. Ld. Assessing Officer observed that section 40(a)(ia) of the Act disallows ITA No. 931/Ahd/2015 & 448/Ahd/2016 Hagglunds Drives (India) Pvt. Ltd./ Bosch Rexroth (India

THE DY. CIT, CIRCLE-1(2),, BARODA vs. M/S. DELOITTE HASKINS & SELLS, BARODA

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

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 2970/Ahd/2017 िनधा"रण वष"/Asstt. Year: 2014-2015 D.C.I.T., M/S Deloitee Haskins & Sells, Circle-1(2), Vs. 31-Nutan Bharat Society, Vadodara. Alkapuri, Baroda.

68,51,33,061/-. The assessee had not submitted any evidences as to what it had gained from DTTIPL. 2. On the facts and circumstances of the case and in law, the Ld.CIT(A) has erred in deleting the disallowance made u/s 40(a)(ia) of the Act to the tune of Rs. 1,07,83,531/- without considering

NARENDRASINH PRAVINSINH JADEJA,VADODARA vs. THE INCOME TAX OFFICER, WARD-1(2)(4), VADODARA

The appeal of the assessee is dismissed

Bench: Ms. Suchitra Kambleassessment Year 2011-12

Section 194C are not applicable. The Ld. AR further submitted that how the Assessing Officer arrived at the figure of Rs. 28,84,211/- is not enumerated in assessment order. The Ld. AR submitted that there is not requirement to show acceptance of loan or repayment of loan in return of income. Thus, the Ld. AR submitted that

THE DCITANAND CIRCLE,, ANAND vs. ELECON ENGINEERING CO.LTD.,, ANAND

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Roysr.No.

68,929/- (Rs. 1,34,95,379/- + 61,73,550/-) has escaped assessment for A.Y. 2006-07 within the meaning of section 147 of the I.T. Act, 1961. I, therefore, issue notice u/s. 148 of the Act for A.Y. 2006-07 to the assessee after obtaining necessary approval of the higher authority. 4.1 Regarding the reason

THE DCITANAND CIRCLE,, ANAND vs. ELECON ENGINEERING CO.LTD.,, ANAND

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Ms. Madhumita Roysr.No.

68,929/- (Rs. 1,34,95,379/- + 61,73,550/-) has escaped assessment for A.Y. 2006-07 within the meaning of section 147 of the I.T. Act, 1961. I, therefore, issue notice u/s. 148 of the Act for A.Y. 2006-07 to the assessee after obtaining necessary approval of the higher authority. 4.1 Regarding the reason

SHRI PRAFUL D. THAKKAR,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(2),, AHMEDABAD

In the result, assessee’s appeal is allowed

Bench: Shri Pramod Kumar, Hon’Ble&Smt. Madhumita Royआयकरअपीलसं.Ita No. 2026/Ahd/2015 "नधा"रणवष"/Asstt. Year: 2008-09 Sushilaben Prafulbhai Vs. Ito Thakkar, Ward-2(2) L/H Of Late Prafulbhai D. Ahmedabad. Thakkar, 40, Lad Society, B/H Akash Tower, Bodakdev, Ahmedabad- 380054

68,067/- under the head advertisement expenses and Rs. 91,888/- under the head interest expenses. Such payment made to three parties exceeded Rs. 50,000/-. According to the Ld. AO in terms of sec. 194C and sec. 194A TDS was required to be deducted on such payments but assessee deducted only on payment

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

194C which proves that the assessee is a contractor and not owner of the projects and the appellant was 'not owner of the projects’. The AO has held that the company is neither developing or operating or maintaining AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited

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

194C which proves that the assessee is a contractor and not owner of the projects and the appellant was 'not owner of the projects’. The AO has held that the company is neither developing or operating or maintaining AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited

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

194C which proves that the assessee is a contractor and not owner of the projects and the appellant was 'not owner of the projects’. The AO has held that the company is neither developing or operating or maintaining AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited

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

194C which proves that the assessee is a contractor and not owner of the projects and the appellant was 'not owner of the projects’. The AO has held that the company is neither developing or operating or maintaining AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited

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

194C which proves that the assessee is a contractor and not owner of the projects and the appellant was 'not owner of the projects’. The AO has held that the company is neither developing or operating or maintaining AYs2009-10, 2010-11, 2011-12, 2013-14, 2014-15 Ajay Engineering Infrastructure Pvt. Ltd. ITA No. 1650/Ahd/2017 Ajay Protech Private Limited

THE ACIT, CIRCLE-11,, AHMEDABAD vs. SHRI PRATAP BHAGWANJI THAKKAR,, AHMEDABAD

In the result the appeal ITA No

194C of the Act. On appeal the Ld. CIT(A) has restricted the addition to the amount of Rs. 66,547/- after providing relief in respect of those cases where the total amount paid were less than 20,000/- and Rs. 50,000/- respectively. We have heard the rival contention and perused the material on record on this issue. I.T.A

SAMIR SYNTHETICS MILLS,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(3),, AHMEDABAD

In the result, the ground no

Bench: Him.

section 194C of the Act and made disallowance of Rs. 1,83,297/- of payment made upto 31st Sep, 2009 to M/s. Naveen Trade Link Pv. Ltd. Accordingly, the assessing officer has made total disallowance of Rs. 7,34,456/- u/s. 40(a)(ia) of the Act. I.T.A No. 734/Ahd/2016 A.Y. 2010-11 Page No 5 Samir Synthetics Mills

SHRI ALTAFHUSEN M. SIDDIKI,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-9(4), AHMEDABAD

In the result, appeals filed by the assessee i

Bench: Shri Manish Borad & Shri Amarjit Singhआयकर अपील सं./ Ita No.577/Ahd/2012 "नधा"रण वष"/Assessment Year: 2008-09 & आयकर अपील सं./ Ita No.969/Ahd/2015 { "नधा"रण वष"/Assessment Year: 2010-11 Shri Altafhusen M. Siddiki, Prop Dcit, Circle-9 Of Sunmoon Roadways 6/D/1, Vs Ahmedabad Pursottam Estate, Nr. Cozy Hotel, Ranipur Patia, Sarkhej Road, Narol, Ahmedabad-382405 Pan No.Arsps3765P

68,442/- 3. Tata Motors Ltd. Rs.1,12,716/- Total Rs.16,47,203/- 43. The tax was not deducted on the above payments we have dealt similar issue in the case of assessee for A.Y. 2008-09 and have set aside the issue to the file of Ld. AO for conducting necessary verification with the assistance of the assessee