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

6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee had made substantial additions to capital work

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

6 (Original) and Revised Ground No. 11 – Deletion of Disallowance of Interest under Section 36(1)(iii) amounting to Rs. 11,29,21,996/- 79. The Assessing Officer disallowed a sum of Rs.11,29,21,996/- under section 36(1)(iii) of the Act on the ground that the assessee had made substantial additions to capital work

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

1), AHMEDABAD IT(SS)A. No: 102/AHD/2017. HELD THAT - The provision of section 68 of the Act fastens the liability on the assessee to provide the identity of the lenders, establish the genuineness of the transactions and creditworthiness of the lenders. These liabilities on the assessee were imposed to justify the cash credit entries under section 68

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

1), AHMEDABAD IT(SS)A. No: 102/AHD/2017. HELD THAT - The provision of section 68 of the Act fastens the liability on the assessee to provide the identity of the lenders, establish the genuineness of the transactions and creditworthiness of the lenders. These liabilities on the assessee were imposed to justify the cash credit entries under section 68

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

1), AHMEDABAD IT(SS)A. No: 102/AHD/2017. HELD THAT - The provision of section 68 of the Act fastens the liability on the assessee to provide the identity of the lenders, establish the genuineness of the transactions and creditworthiness of the lenders. These liabilities on the assessee were imposed to justify the cash credit entries under section 68

AARK INFOSOFT PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2017-18 Vs. Aark Infosoft Private Limited, The Acit, 45, Shetrunjay, 2Nd Floor, Above Circle-1(1)(1), Central Bank Of India, Bhattha Ahmedabad Cross Road, Paldi, Ahmedabad Gujarat-380007 Pan : Aahca 9986 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Divyang Shah, Ar Revenue By : Shri Santosh Kumar, Sr. Dr सुनवाई क" तारीख/Date Of Hearing : 08.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 21.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: Present Appeal Has Been Filed By The Assessee Against Order Of The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As "Cit(A)" For Short] Dated 27.07.2023 Passed Under Section 250 Of The Income-Tax Act, 1961 [Hereinafter Referred To As "The Act" For Short], For The Assessment Year (Ay) 2017-18. 2. The Grounds Raised By The Assessee Are As Under:- “1. Whether On The Facts & Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Issuing A Notice U/S 143(2) Of The Act? 2. Whether On The Facts & In Circumstances Of The Case & In Law, Ld. Cit(A) Has Erred In Making Disallowance Of Employees' Contribution To Pf & Esic Of Rs.5,51,657/- U/S 36(1) (Va) Of The Act?

6. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making addition of Rs. 1,68,54,746/- on account of unsecured loan u/s 68 of the Act? 7. Whether on the facts and in circumstances of the case and in law, Ld. CIT(A) has erred in making addition

THE JT. CIT(EXEMPTION)(OSD), CIRCLE-2, AHMEDABAD vs. DIVYA JYOTI TRUST, SURAT

In the result, appeal of the Revenue is dismissed

Bench: S/Shri Waseem Ahmed & T.R. Senthil Kumarassessment Year : 2015-16 Jt.Cit (Exemptions)(Osd) Divya Jyoti Trust Cir.2, Ahmedabad. Vs Tejas Eye Hospital Suthar Faliyaat & Post – Mandvi Surat 394 610. Pan : Aabtd 3401 D अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan Jagirdar, Ar Revenue By : Shri Urjit Shah, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 17/02/2022 घोषणा क" तार"ख /Date Of Pronouncement: 25/02/2022 आदेश/O R D E R Per T.R. Senthil Kumar: This Appeal Is Filed By The Revenue Against Order Dated 7.6.2019 In Appeal No. Cit(A)-9/10321/Dcit(E), Cir.2-/17-18Passed By The Ld.Commissioner Of Income-Tax (Appeals)-9, Ahmedabad [For Short “Ld.Cit(A)] Relating To The Assessment Year 2015-16. 2. Revenue Has Raised The Following Grounds Of Appeal:

68,45,899/- and claimed the same as exempt under section 11(1)(d) of the Act. During the year, the trust has acquired fixed assets to the tune of Rs.2,51,85,640/- and claimed the same as application of income under section 11(1)(a) of the Act. The position of law, as of pre- amended

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)

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 is that the provisions of section 144C

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

6) there is no justification for applying Section 41(1) since CIT(A), ultimately in his appeal order is para 5.6 has applied the aforesaid Section. In para 5.20, it is held that the assessee has not established genuineness on the unsecured loans even though stated by the assessee that the unsecured loans carried forward from

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

6) Guard File\n\nTRUE COPY\nBy order\n\nAssistant Registrar\nIncome Tax Appellate Tribunal\nAhmedabad benches, Ahmedabad", "summary": { "facts": "The assessee, a public charitable trust, received shares as corpus donation and later sold them for Rs.538.40 Crores. The Assessing Officer (AO) treated this sale consideration as an unexplained cash credit under Section 68 of the Income

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

6 - Deduction of Rs.1,71,000/-under section 80GGB for the A.Y.\n2013-14\n76. Ground No. 4 of the Revenue's appeal relates to the action of the\nlearned CIT(A) in deleting the disallowance of Rs. 1,71,000/- claimed by the\nassessee as deduction under section 80GGB of the Income-tax Act, 1961, in\nrespect

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

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

6)\nGuard File\n\nTRUE COPY\n\nSd/-\n(NARENDRA PRASAD SINHA)\nAccountant Member\n\nBy order\n\nAssistant Registrar\nIncome Tax Appellate Tribunal\nAhmedabad benches, Ahmedabad", "summary": { "facts": "The assessee trust received shares as corpus donation and later sold them for Rs.538.40 Crores. The Assessing Officer (AO) added this amount to the income under Section 68, considering

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

6 of 24 Section 68 of the Act in respect of proceeds received by the assessee on sale of shares. He explained that the capital gain arising on sale of shares was duly disclosed by the assessee in its return and deduction under Section 11(1A) of the Act was claimed, as eligible to the assessee. He submitted

THY ACIT, CIRCLE-2(1)(2), , AHMEDABAD vs. M & B ENGINEERING LIMITED,, AHMEDABAD

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

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

68(i) all income accruing or arising, whether directly or indirectly, through or from any business connection69 in India, or through or from any property69 in India, or through or from any asset or source of income in India, 70[* * *] or through the transfer of a capital asset situate in India. 71[Explanation 1].—For the purposes of this clause

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

Appeals are partly allowed for\nstatistical reasons

6 - Deduction of Rs.1,71,000/-under section 80GGB for the A.Y.\n2013-14\n76.\nGround No. 4 of the Revenue's appeal relates to the action of the\nlearned CIT(A) in deleting the disallowance of Rs.1,71,000/- claimed by the\nassessee as deduction under section 80GGB of the Income-tax Act, 1961, in\nrespect

ITO WARD-4(1)(4),, AHMEDABAD vs. VALLEY COMTRADE PVT LTD ( EARLIER KNOWN AS JHAWAR COMTRADE PVT. LTD.,), AHMEDABAD

In the result appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Siddharatha Nautiyalआयकर अपील सं./Ita No. 2034/Ahd/2017 िनधा"रण वष"/Asstt. Year:2012-2013 I.T.O, M/S. Valley Comtrade Pvt. Ltd., Ward-4(1)(4), Vs. (Earlier Known As Jhawar Comtrade Ahmedabad. Pvt. Ltd.,) C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N & आयकर अपील सं./Ita No. 68/Srt/2017 िनधा"रण वष"/Asstt. Year:2012-2013 M/S. Valley Comtrade Pvt. Ltd., I.T.O, (Earlier Known As Jhawar Comtrade Vs. Ward-1(1)(3), Pvt. Ltd.,) Surat. C-205, Titanium Square, Near Parsoli Bmw Showroom, Thaltej Chokdi, Ahmedabad-380054. Pan: Aadcs3553N

68 of the Act and added the same to the total income of the assessee. 5. Aggrieved assessee preferred an appeal to the learned CIT-A. 6. The assessee besides reiterating its submission made during assessment proceeding further filed the assessment order of the investor companies framed under section 143(3) of the Act in the case

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

68,885 Total 4,25,93,802 4,83,37,429 2,82,74,504 Less: Business loss utilized in 69,41,861 - 6,4,1861 A.Y. 2005-06 Amount available for deduction 3,56,51,941 4,83,37,429 2,13,32,643 in A.Y. 2006-07 Lower of unabsorbed 3,56,51,941 depreciation on business loss

EAGLE STEEL INDUSTRIES PVT. LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(1),, AHMEDABAD

In the result, appeal filed by the Assessee is allowed

Bench: Shri P. K. Kedia & Shri Mahavir Prasad)

1. This appeal by the Assessee is directed against the order of the Ld. CIT(A)-2, Ahmedabad dated 25.08.2015 pertaining to A.Y. 2012-13 that the ld. CIT(A) 2 . A.Y. 2012-13 for confirming disallowance of Rs. 26,68,187/- by invoking provisions of section 40(a)(ia) of the Act. The facts of the case