SHREE KHEDUT SAHAKARI KHAND UDYOG MANDLI LTD.,BARDOLI vs. INCOME TAX OFFICER, WARD-1, BARDOLI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

charitable trust. (vi) That the appellant could not prove that a higher price was paid by it to the farmers on account of higher yield or some other factors. Besides nowhere it has been claimed that at the time of supply of sugarcane by the farmers to the appellant, any agreement or contract 25 for payment of price higher than

SIGMA INSTITUTE OF TECHNOLOGY AND ENGINEERING,,VADODARA vs. THE PR.CIT, CENTRAL,, SURAT

Bench: Shri C.M.Garg & Shri O.P.Meenaआ.अ.सं./I.T.A No. 67/Ahd/2016/Srt िनधा"रण वष"/Assessment Year : Sigma Institute Of Technology & Vs. Pr. Commissioner Of Engineering , Income-Tax (Central), At Bakrol, Near Madhav Nagar, Surat. Ajwa-Nimeta Road, Tal. Waghodia, Dist. Vadodara-390010 Pan: Aajts7182G अपीलाथ" Appellant ""यथ"/Respondent

charitable purpose but for purpose of making profit only. The assessee trust does not fulfill the conditions laid down in section 13 of the Income-tax Act, 1961. The provisions of section 11 and 12 are also not applied to the assessee. 10. In view of the above position, I am satisfied that the activities of the assessee trust

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD.,, NAVSARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

SAHADARI KHAND UDYOG MANDAL LTD.,,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

ACIT, NA vs. ARI CIRCLE., NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,, NAVASARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

SAHAKARI KHAND UDYOG MANDAL LTD.,,GANDEVI vs. ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG, KAND UDYOG SAHAKARI MANDALI LTD., NAVSARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

SAHAKARI KHAND UDUOG MANDAL LTD.,NA vs. ARIVS.DCIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

Bench: Shri Dinesh Mohan Sinha & Shri Bijyananda Pruseth

section 40A(2) of the Act separately in respect of payments to non-members. According to the CIT-DR, this framework of analysis remains fully binding even after the shift from the SMP–5A regime to the FRP regime, because the core principle is that expenditure in the nature of profit distribution cannot be allowed as deduction, and only that

SANJAYKUMAR TIKAMCHAND BUCHA,SURAT vs. ACIT, CIRCLE-1(2), SURAT

In the result, the appeal of the assessee is partly allowed

Bench: Shri T. R Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.647/Srt/2024 Assessment Year: (2013-14) Shri Sanjaykumar Tikamchand Bucha, Vs. Acit, 521, Goodluck Market, Ring Road, Circle – 1(2), Surat, Gujarat - 395002 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abqpb9320F (Appellant) (Respondent) Appellant By Shri Mehul Shah, Ca Respondent By Shri Ashish Pophare, Cit -Dr Date Of Hearing 30/06/2025 Date Of Pronouncement 06/08/2025

Charitable Trust, (2022) 144 taxmann.com 54 (Mad.), (iii) Kantilal C. Shah vs. ACIT, (2011) 14 taxmann.com 108 (Ahd – Trib.), (iv) PCIT vs. Avinash Kumar Setia, (2017) 81 taxmann.com 476 (Delhi), (v) Thiru S. Shyam Kumar vs. ACIT, (2018) 99 taxmann.com 39 (Mad.) and (vi) Ravindra Kumar Verma vs. CIT, (2013) 30 taxmann.com 367 (All.). 4.1 With regard to the claim