M/S. BODAL CHEMICALS LIMITED,AHMEDABAD vs. THE DY.CIT., CENTRAL CIRCLE-1(1),, AHMEDABAD

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

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

35(1)(ii) and all supporting documents such as approval, CBDT circular, recognition certificates and gazette notification were available. The Assessing Officer disallowed the deduction by relying upon CBDT letter dated 14.12.2018 and an RTI reply stating that the trust was never recognised and further made the addition by invoking section 68

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

35 59. The Revenue contends that depreciation on goodwill is not allowable as there was no goodwill recorded in the books of the amalgamating company and the same was created only in the books of the amalgamated company. We find this contention devoid of merit. As held by the Hon’ble Supreme Court in Smifs Securities

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

35 59. The Revenue contends that depreciation on goodwill is not allowable as there was no goodwill recorded in the books of the amalgamating company and the same was created only in the books of the amalgamated company. We find this contention devoid of merit. As held by the Hon’ble Supreme Court in Smifs Securities

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

ii) International Air Transport Association v. Dy. CIT [2016] 68 taxmann.com 246 (Bombay); (iii) Zuari Cements Ltd. v. ACIT [Writ Petition No. 5557 of 2012, dated 21-2- 2013] (Andhra Pradesh)- Revenue‟s SLP dismissed by the Hon‟ble Apex Court in CC No. 16694/2013 on 27th September 2013 38. What culminates from the aforesaid two sets of parallel decisions

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.

section 80-IC of the Act. Both the parties before us relied on the order of authorities below as favorable to them. 45. We have heard the rival contentions of both the parties and perused the materials available on record. The controversy in the case on hand relates whether the donation paid by the assessee under section

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

section 80-IC of the Act. Both the parties before us relied on the order of authorities below as favorable to them. 45. We have heard the rival contentions of both the parties and perused the materials available on record. The controversy in the case on hand relates whether the donation paid by the assessee under section

THE TORRENT PHARMACEUTICALS,AHMEDABAD vs. THE ADDITIONAL CIT, 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.

section 80-IC of the Act. Both the parties before us relied on the order of authorities below as favorable to them. 45. We have heard the rival contentions of both the parties and perused the materials available on record. The controversy in the case on hand relates whether the donation paid by the assessee under section

THE ACIT, CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS, 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.

section 80-IC of the Act. Both the parties before us relied on the order of authorities below as favorable to them. 45. We have heard the rival contentions of both the parties and perused the materials available on record. The controversy in the case on hand relates whether the donation paid by the assessee under section

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

ii) Decision of ITAT Ahmedabad in the case of A.C.I.T, CENTRAL CIRCLE-1 (2), AHMEDABAD vs. M/S. REAL MARKETING PRIVATE LIMITED; NEMINATH TRADERS PVT. LTD. AND M/S. REAL MARKETING PRIVATE LIMITED vs ITO, WARD-5 (3), AHMEDABAD [2014] vide order dated 19.05.2023 2023 (5) TMI 1050 ITAT AHMEDABAD "Addition u/s 68-bogus credit of loan-expenses incurred for taking such

ACIT, CENTRAL CIRCLE-2, VADODARA, VADODARA vs. HK ISPAT PVT LTD, GODHRA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

ii) Decision of ITAT Ahmedabad in the case of A.C.I.T, CENTRAL CIRCLE-1 (2), AHMEDABAD vs. M/S. REAL MARKETING PRIVATE LIMITED; NEMINATH TRADERS PVT. LTD. AND M/S. REAL MARKETING PRIVATE LIMITED vs ITO, WARD-5 (3), AHMEDABAD [2014] vide order dated 19.05.2023 2023 (5) TMI 1050 ITAT AHMEDABAD "Addition u/s 68-bogus credit of loan-expenses incurred for taking such

H K ISPAT PVT. LTD.,PANCHMAHAL vs. THE DY.CIT, CENTRAL CIRCLE-2, VADODARA

In the result, all the appeals filed by the Revenue for AYs 2014–15 to 2021–

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra R. Kamblesn

ii) Decision of ITAT Ahmedabad in the case of A.C.I.T, CENTRAL CIRCLE-1 (2), AHMEDABAD vs. M/S. REAL MARKETING PRIVATE LIMITED; NEMINATH TRADERS PVT. LTD. AND M/S. REAL MARKETING PRIVATE LIMITED vs ITO, WARD-5 (3), AHMEDABAD [2014] vide order dated 19.05.2023 2023 (5) TMI 1050 ITAT AHMEDABAD "Addition u/s 68-bogus credit of loan-expenses incurred for taking such

PAWAN EDIFICE PVT. LTD.,VADODARA vs. THE DY.CIT, CIRCLE-2(1)(2), VADODARA

68,995/-\nTotal Own Funds (a + b)\n19,52,09,835/-\n20,76,83,195/-\n18. It was thus urged that, in view of the availability of substantial own\nfunds and the binding judicial precedents, the disallowance sustained by\nthe CIT(A) under section 14A ought to be deleted in full.\n19. With regard to the disallowance of administrative

DHARAMTAR MOTORS SERVICES PETROLEUM PRODUCT,,AHMEDABAD vs. THE ITO, WARD-6(1)(4),, AHMEDABAD

In the results, both the appeals of the assessee are allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita Nos. 1438 & 2534/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 M/S Dharamtar Motor Services Income Tax Officer, Petroleum Product, Vs. Ward 6(1)(4) C/O. Ketan H. Shah, Advocate 903, Ahmedabad. Sapphire Complex, C.G. Road, Navrangpura, Ahmedabad. Pan: Aabfd9182F

1. The AO has passed the order dated 27.03,2015, wherein, he has made addition in reference to credit entry appeared in two partners' account viz. (i) Chandrakant Shah, Rs.2,51,29,079/- and (ii) Nimesh C Shah, Rs.8,03,951/- making total addition of Rs.2,59,33,030/- by applying Section 68 of the Income Tax Act. Before

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

1.\nWhether on the facts and in circumstances of the case, Ld. CIT is\njustified in deleting the addition u/s.68 of the I.T. Act, 1961 of\nRs.5,38,40,00,000/- being sale consideration of E-Infochip Limited\nshares received from M/s. Arrow Electronics India Pvt. Ltd., Bangalore.”\n\nITA Nos.1205 & 769/Ahd/2025\n Assessment Years: 2018-19\nACIT

THE ACIT, (EXEMPTION) CIRCLE-1, AHMEDABAD vs. VYAKTI VIKAS KENDRA INDIA, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

ii) education, (iii) Medical relief (iv) preservation of monuments or places of objects of artistic or historic invents, (v) preservation of environment (including water soil forest and wild life). Ultimately, the Learned AO observed that as soon as the assessee’s case is hit by the amended provision of section 2(15) by virtue of sub Section

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

ii) education, (iii) Medical relief (iv) preservation of monuments or places of objects of artistic or historic invents, (v) preservation of environment (including water soil forest and wild life). Ultimately, the Learned AO observed that as soon as the assessee’s case is hit by the amended provision of section 2(15) by virtue of sub Section

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

ii) education, (iii) Medical relief (iv) preservation of monuments or places of objects of artistic or historic invents, (v) preservation of environment (including water soil forest and wild life). Ultimately, the Learned AO observed that as soon as the assessee’s case is hit by the amended provision of section 2(15) by virtue of sub Section

DCIT (EXEMPTION), CIRCLE-1, BANGLORE vs. VYAKTI VIKAS KENDRA INDIA,, AHMEDABAD

In the result revenue’s appeal is dismissed

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

ii) education, (iii) Medical relief (iv) preservation of monuments or places of objects of artistic or historic invents, (v) preservation of environment (including water soil forest and wild life). Ultimately, the Learned AO observed that as soon as the assessee’s case is hit by the amended provision of section 2(15) by virtue of sub Section