IRM PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

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

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

194J and commission/brokerage of Rs. 45,17,539/- under section 194H during the financial year 2010–11 relevant to A.Y. 2011– 12, aggregating to Rs. 50,46,979/-. IRM Pvt. Ltd. vs. DCIT A.Y 2011-12 3 (ii) That cash expenditure exceeding Rs. 10,00,000/- in a single month was recorded in the NMS data. (iii) That information

SHREE HARI ENTERPRISE ,AHMEDABAD vs. THE PR. CIT, AHMEDABAD-1, AHMEDABAD

In the result, the appeal of the assessee is partly allowed in the\nfollowing terms:\n\ni) Issue No

sections": [ "263", "143(3)", "142(1)", "194-I", "194J", "40(a)(ia)", "68", "194A" ], "issues": "Whether the Pr.CIT was justified

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

194J and 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

194J and 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

EYLEX FILMS PRIVATE LIMITED,RANCHI vs. DCIT, CIRCLE2(1)(1), AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

68 of the Act. Consequently, the loan was treated as unexplained cash credit, leading to the addition of ₹48,75,427/- to the income of the assessee. The Ld. Assessing Officer observed that the assessee claimed expenses amounting to ₹10,62,20,155/-, excluding depreciation and film distribution expenses. However, the assessee failed to submit detailed information for verification despite

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

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

HBC LIFESCIENCES PRIVATE LIMITED,GANDHINAGAR vs. THE PR. CIT-3, AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 328/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2018-19) िनधा"रण वष" Hbc Lifesciences Private Principal Commissioner बनाम बनाम/ बनाम बनाम Limited Of Income Tax-3 Vs. B-218, Mayur House, Ahmedabad G.I.D.C., Electronic Estate Sector-25, Gandhinagar, Gujarat, 382016 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacch1407M (Appellant) .. (Respondent) Shri S. N. Soparkar, Sr. Advocate & अपीलाथ" ओर से /Appellant By : Shri Parin Shah, A.R. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr 20/06/2024 Date Of Hearing Date Of Pronouncement 05/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Principal Commissioner Of Income Tax-3, Ahmedabad, (In Short The ‘Pcit’) Dated 25.03.2023 In Exercise Of The Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act” In Short], For The Assessment Year 2018-19. 2. The Brief Facts Of The Case Are That The Return Of Income For A.Y. 2018-19 Was Filed By The Assessee On 30.10.2018 Declaring

68,02,443/- which can be held as payment to Doctors and liable for disallowance. This payment was explained and justified by the assessee on the basis of agreement with the respective Doctors for giving advisory information for the drugs effect on the patients coming to their clinic. This expenditure was explained to be of professional in nature

DY.COMMISSIONER OF INCOME TAX CIRCLE-1(3),, AHMEDABAD vs. KIFS PVT.LTD.,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

THE DY. CIT., CIRCLE-3,, AHMEDABAD vs. KHANDWALA INTEGRATED FINANCIAL SERVICES PVT. LTD, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

KIFS SECURITIES PVT. LTD.,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3), AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

KIFS SECURITIES PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-1(3),, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

KIFS SECURITIES LTD.,,AHMEDABAD vs. THE JT.CIT, RANGE- 3,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

THE ACIT, CIRCLE-3,, AHMEDABAD vs. KIFS SECURITIES LIMITED,, AHMEDABAD

In the result Ground No.9 of the revenue is allowed for

Bench: Hon'Ble Justice P.P.Bhatt & Hon'Ble Manish Borad

194J of the Act. The A.O was of the firm belief that the relevant provision applicable on the payments made by the assessee attract section 1941 of the Act. The A.O accordingly disallowed Rs. 7,49,455/- being VSAT charges and Rs. 72,500/- being lease line expenses. Assesse-e carried the matter before

THE DCIT, CIRCLE-1(3), AHMEDABAD vs. EDELWEISS FINANCIAL ADVISORS LTD., ( FORMERLY KNOWN ANAGRAM STOCK BROKING LTD.,), AHMEDABAD

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

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

Section 32 of the Act provides for depreciation in respect of buildings, machinery, plant or furniture owned by an assessee and used for the purposes of the business or profession. Under this section, for getting depreciation, the following two conditions should be satisfied: (i) The asset in question should be owned by the assessee; and (ii) The asset

M/S. EDELWEISS BROKING LTD. ( AMALGAMATING COMPANY EDELWEISS FINANCIAL ADVISORS LTD.),AHMEDABAD vs. THE JT. CIT, RANGE-3,, AHMEDABAD

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

Bench: Shri Justice P.P. Bhatt, Hon’Ble & Shri Waseem Ahmed

Section 32 of the Act provides for depreciation in respect of buildings, machinery, plant or furniture owned by an assessee and used for the purposes of the business or profession. Under this section, for getting depreciation, the following two conditions should be satisfied: (i) The asset in question should be owned by the assessee; and (ii) The asset