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

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

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

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

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

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