आयकर अपीलीय अिधकरण अहमदाबाद (cid:586)ायपीठ “ A”, अहमदाबाद । , IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD ]]

BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI MAKARAND V. MAHADEOKAR, ACCOUNTANT MEMBER आयकर अपील सं /ITA Nos. 1412 & 1413/Ahd/2019 िनधा१रण वष१ Assessment Years: (2015-2016 & 2016-17)

/

Nirma Limited, The Deputy Commissioner Nirma House, बनाम of Income Tax, /

Ashram Road, v/s. Circle 3(1)(1), Ahmedabad-380009. Ahmedabad.

(Gujarat)

(cid:830)थायी लेखा सं./PAN : AAACN5350K आयकर अपील सं /ITA Nos.1436-1437/Ahd/2019 िनधा१रण वष१ Assessment Years : (2015-16 & 2016-17)

/

The Assistant Commissioner of Nirma Limited, Income Tax, बनाम/ Nirma House, Circle 3(1)(1), v/s. Ashram Road, Ahmedabad. Ahmedabad-380009.

(Gujarat)

(cid:830)थायी लेखा सं./PAN: AAACN5350K AND C.O Nos.11-12/Ahd/2020 In आयकर अपील सं /ITA Nos.1436-1437/Ahd/2019 िनधा१रण वष१ Assessment Years : (2015-16 & 2016-17)

/

Nirma Limited, The Deputy Commissioner of Nirma House, बनाम/ Income Tax/The Assistant Ashram Road, v/s. Commissioner of Income Tax, Ahmedabad-380009. Circle 3(1)(1), (Gujarat) Ahmedabad.

(cid:830)थायी लेखा सं./PAN: AAACN5350K अपीलाथ(cid:334) (Appellant) (cid:366)(cid:797) यथ(cid:334) (Respondent)

/ /

Assessee by : Shri Bandish Soparkar, with Shri Hemanshu Shah, ARs Revenue by : Shri Alpesh Parmar, CIT-DR सुनवाई की तारीख Date of Hearing : 20/08/2025 /

घोषणा की तारीख Date of Pronouncement: 28/08/2025 /

आदेश O R D E R /

PER MAKARAND V. MAHADEOKAR, AM:

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These are a set of appeals by the Revenue and by the assessee, together with cross-objections filed by the assessee, directed against the separate orders passed by the Commissioner of Income Tax (Appeals)-9, Ahmedabad [hereinafter referred to as “CIT(A)”] dated 03.07.2019 for Assessment Year 2015–16 and dated 08.07.2019 for Assessment Year 2016–17. The appeals arise from the assessment orders framed under section 143(3) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] by the Deputy/Assistant Commissioner of Income Tax, Circle 3(1)(1), Ahmedabad [hereinafter referred to as “the Assessing Officer /

AO”].

Facts in Brief

2. The assessee company, M/s Nirma Limited, is a public limited company engaged in the business of manufacturing and marketing a wide range of consumer and industrial products. Its principal consumer products include detergent powder, detergent cakes, toilet soaps and shampoos sold under the brand names “Nirma” and “Nima”. In addition, the company manufactures intermediate industrial products such as sulphuric acid, Alpha Olephine Sulphonate (AOS), glycerine, acid slurry, fatty acid etc. The assessee has also diversified into large-scale industrial projects, namely the Soda Ash Project at Kala Talav, Bhavnagar and the Linear Alkyl Benzene (LAB) Project at Alindra, Baroda, both of which commenced production in F.Y. 1999–2000. The products from these units are partly consumed captively for the manufacture of soaps and detergents and partly sold to outside parties. The assessee also operates wind farm projects at Dhank, Bhavnagar District, Gujarat. Further, the Board for Industrial and Financial Reconstruction (BIFR) sanctioned a Modified Rehabilitation Scheme providing for amalgamation of Saurashtra Chemicals Ltd. (SCL) with the assessee, effective from 01.04.2011. SCL was engaged in manufacturing soda ash, sodium bicarbonate and bromine at its Birlasagar facility at Porbandar, besides operating five salt works near Jamnagar and limestone mines near Porbandar for captive use. Subsequently, by order dated 20.04.2015, the Hon’ble Gujarat High Court sanctioned a Composite Scheme of Arrangement under sections 391 and 394 of the Companies Act, 1956, whereby several associate and subsidiary companies were amalgamated with the assessee with effect from 01.04.2014. In the same scheme, the Healthcare Division of the assessee was demerged and transferred to Aculife Healthcare Pvt. Ltd. with effect from 01.10.2014.

3. For the Assessment Year 2015–16, the assessee filed its original return of inc