THE DY.COMMISSIONER OF INCOME TAX CIRCLE-2(3),, SURAT vs. M/S. RAJ ENTERPRISES,, SURAT

Bench: Shri Pawan Singh & Dr Arjun Lal Saini

transfer as defined in section 2(47) of the Act to the case of assessee for whom the plots of land Raj Enterprises (AY 2009-10 & 2010-11) are stock in trade. The provisions of section 2(47) apply to capital asset only and the action of the Assessing Officer is liable to be quashed which is inconsistent to provision

M/S. VIPUL PARK,TAPI vs. THE DCIT,CENT.CIR.-2, SURAT

In the result, appeal of the assessee is allowed

Bench: Shri Pawan Singh, Hon'Ble & Dr.Arjun Lal Saini, Hon'Ble(Virtual Hearing) आ.अ.सं./I.T.A No.1195/Ahd/2013 "नधा"रण वष"/Assessment Year: 2009-10 M/S.Vipul Park, Vs. The Deputy Commissioner Of Andhar Wadi Road, Income Tax, Central Circle-2, Vyara, Dist. Tapi – 394 650. Surat. [Pan: Aalfm 3438 P] अपीलाथ" / Appellant ""यथ"/Respondent

4) In any other case, the from shall be accompanied by a copy of the agreement, approval or permission, as the case may be, to carry on the activity signed or issued by the Central Government or the State Government or the local authority for carrying on the eligible business.]….” Hence, it is clear that the assessee has failed

M/S. MITSU PRIVATE LIMITED,,VAPI vs. THE ACIT, VAPI CIRCLE,, VAPI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

253 ITR 749 [2002] 121 Taxman 43 (Guj), we find no fault in the findings of Ld. CIT (A). Accordingly, same is upheld. Consequently, this ground is dismissed. 68. Ground No. 3 states that Ld. CIT (A) has erred in holding that expenditure incurred of Rs.1,43,200 on registration of trademark and reviewing the draft technology agreement was revenue

THE ASSTT. COMMISSIONER OF INCOME TAX, VAPI CIRCLE,, VAPI vs. M/S. MITSU LIMITED,, DAMAN

In the result, the appeal of the Revenue is dismissed

Bench: Shri Sandip Gosain & Shri O. P. Meenav. ""यथ"/Respondent आ.अ.सं././././I "नधा"र अपीलाथ" Appellant S .T.A No. ण N वष"/A Y: 1 1671/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2006 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 2 1371/Ah 2002- Assistant V. M/S. Mitsu Limited, D/2006 03 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q Co.No.1 2002- M/S. Mitsu Limited, V. Assistant 3 84/Ahd/ 03 304/2, Iind Phase, Commissioner Of 2006 Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 4 1672/Ah 2003- M/S. Mitsu Limited, V. Assistant D/2006 04 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 5 1764/Ah 2003- Assistant V. M/S. Mitsu Limited, D/2006 04 Commissioner Of 304/2, Iind Phase, Income Tax-Vapi Gidc, Vapi 396195 Circle, Vapi Pan: Aaccm 2764 Q 6 1000/Ah 2002- M/S. Mitsu Limited, V. Assistant D/2016 03 304/2, Iind Phase, Commissioner Of Gidc, Vapi 396195 Income Tax-Vapi Pan: Aaccm 2764 Q Circle, Vapi 7 3510/Ah 2000- Assistant V. M/S. Mitsu Limited, D/2016 01 Commissioner Of Page 2 Of 83 Mitsu Ltd. V. Acit- Vapi/I.T.A. No.1671-1371,Co-184,1672-1764,1614 &1000/Ahd/2006/A.Y.02-03,03-04,06-07.02-03 Income Tax-Vapi 304/2, Iind Phase, Circle, Vapi Gidc, Vapi 396195 Pan: Aaccm 2764 Q

253 ITR 749 [2002] 121 Taxman 43 (Guj), we find no fault in the findings of Ld. CIT (A). Accordingly, same is upheld. Consequently, this ground is dismissed. 68. Ground No. 3 states that Ld. CIT (A) has erred in holding that expenditure incurred of Rs.1,43,200 on registration of trademark and reviewing the draft technology agreement was revenue

SHHLOK TRITON ASSOCIATES ,SURAT vs. PR. COMMISSIONER OF INCOME TAX, SURAT

In the result, the appeal of the appellant is allowed

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.638/Srt/2024 Assessment Year:(2014-15) (Hybrid Hearing) M/S Shhlok Triton Associates, Vs. Pcit – 1, F.P. No. 388, Paikee Udhna Surat Darwaja, Ring Road, Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aclfs6819A (Appellant) (Respondent) Appellant By Shri P. M. Jagasheth, Ca Respondent By Shri Mukesh Jain, Cit (Dr) Date Of Hearing 18/06/2025 Date Of Pronouncement 19/08/2025

253(3) of the Act. The assessee has filed an application giving reasons for delay in filing the appeal before the Tribunal. The assessee submitted that the delay in filing appeal was due to unavoidable medical exigency. The assessee was ITA No.638/SRT/2024/AY 2014-15 Shhlok Triton Associates undergoing treatment for chest pain and heart condition and was admitted to Asian

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

4. The Assessing Officer after referring the provision of section 36(1)(viia) noted that as per this provision, the deduction is allowable @ 7.5% of gross total income before claiming deduction under section 36(1)(viia) and 10% of aggregate average advance made by the rural branches of such bank computed in the prescribed manner. The deduction as computed would

M/S. BAYER VAPI PVT. LTD., (FORMERLY KNOWN AS BILAG INDUSTRIES PVT.LTD.,),VAPI vs. THE ADDL.CIT., VAPI RANGE,, VAPI

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

Bench: Shri Amarjit Singh & Shri O.P. Meena, Accoutant Member आ.अ.सं/.I.T.A No.2912/Ahd/2015 िनधा"रण वष"/Assessment Year:2010-11 बनाम M/S. Bayer Vapi Private Limited) Addl. Cit Range- (Formerly M/S. Bilag Industries Vs. Vapi, Range Vapi Pvt. Ltd.), 306/3,Phase-Ii, Shivam Commercial Complex Gidc-1, Vapi Gujarat. National Highway No 8 Vapi Pan: Aabcb 2100 L अपीलाथ" Appellant ""यथ"/Respondent

4. Manufacturing and 16,18,00,600 process Know How 5. Registration and 1,83,14,986 commercial rights. 6. Others 1,58,428 16,80,000 Total 7,19,85,974 27,50,38,000 116. The assessee company was asked to explain the basis for ascribing to each of the assets acquired by it since the value