DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

ITA 2006/AHD/2025Status: DisposedITAT Ahmedabad24 February 2026AY 2013-14Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)16 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the royalty payments were at arm's length, following previous ITAT decisions in the assessee's own case. It also upheld the deletion of the addition on account of royalty payment and the allowance of deduction under Section 80IA(4), finding no contrary material from the Revenue.

What were the facts?

The Revenue appealed against the deletion of transfer pricing adjustments on royalty payments and the allowance of deduction under Section 80IA(4). The assessee had paid royalty to an associated enterprise for technical know-how, and claimed deduction for participation in a micro-irrigation project.

What were the issues?

Whether the royalty payment to an associated enterprise was at arm's length and whether the assessee was eligible for deduction under Section 80IA(4) for its participation in a government project.

Which sections of the Income-tax Act were involved?

Section 92C,Section 92B,Section 80IA(4)

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Income Tax Appellate Tribunal, AHMEDABAD “D” BENCH

Before: DR. BRR Kumar & Shri T. R. Senthil Kumar

PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER

These two appeals are filed by the Revenue as against two separate appellate orders both dated 11-08-2025 passed by the Commissioner of Income Tax (Appeals)-13, Ahmedabad arising out of the assessment orders passed under section 143(3) r.w.s. 92CA of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2012-13 and 2013-14 respectively. Since common issues are involved in both the appeals, for the sake of convenience, the same are disposed of by this common order.

I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 2 DCIT vs. Netafim Irrigation

The order continues below.

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