STYRENIX PERFORMANCE MATERIALS LIMITED (FORMERLY KNOWN AS INEOS STYROLUTION INDIA LIMITED),VADODARA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(1)(1), VADODARA, VADODARA

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ITA 2178/AHD/2024Status: DisposedITAT Ahmedabad26 May 2026AY 2021-2214 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the transfer pricing adjustment of Rs. 17,11,13,551/- made by the AO/TPO for intra-group services was unsustainable in law. This decision was based on previous rulings in the assessee's own case, affirmed by the Gujarat High Court.

What were the facts?

The assessee company, engaged in manufacturing and trading engineering thermoplastics, filed its return for AY 2021-22. The case was selected for scrutiny, and a reference was made to the TPO regarding international transactions with associated enterprises.

What were the issues?

The primary issues involved the validity of assessment proceedings, timeliness of the assessment order, and the correctness of transfer pricing adjustments for intra-group services.

Which sections of the Income-tax Act were involved?

Section 92C,Section 92D,Section 144B,Section 153,Section 270A,Section 36(1)(va),Section 234A,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “D” BENCH, AHMEDABAD

Before: DR. BRR KUMAR & SHRI SIDDHARTHA NAUTIYAL

For Appellant: Ms. Amrin Patha, AR
For Respondent: Shri Sher Singh, CIT-DR
Pronounced: 26.05.2026

आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT 4. आयकर आयु�(अपील) / The CIT(A)- 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt.Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad

1.

Date of dictation 15.05.2026 (Hon’ble Member dictated on his dragon software) 2. Date on which the typed draft is placed before the Dictating Member 15.05.2026 3. Other Member………………… 4. Date on which the approved draft comes to the Sr.P.S./P.S 18.05.2026 5. Date on which the fair order is placed before the Dictating Member for pronouncement 26.05.2026 6. Date on which the fair order comes back to the Sr.P.S./P.S 26.05.2026 7. Date on which the file goes to the Bench Clerk 26.05.2026 8. Date on which the file goes to the Head Clerk…………………………………... 9. The date on which the file goes to the Assistant Registrar for signature on the order…………… 10. Date of Dispatch of the Order……………………………………

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