THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

144C(13), determining total income at Rs.178,23,60,063/- as against the returned income of Rs.168,29,62,390/-, after making the following additions: i. disallowance of Rs.8,26,43,616/- under section 14A read with Rule 8D(2)(iii), which was also added back while computing book profits under section 115JB; ii. disallowance of Rs.1

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

1-4, 6, 8, 9 and Grounds 12-15. 80. Now we shall discuss ground number 5,7,10 and 11 of the assessee’s appeal for Assessment Year 2015-16, in which taxability of payments in respect of two new services received by the assessee has been discussed and the issue of levy of surcharge and cess

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

144C of the Income Tax Act, 1961 ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 2 ("the Act" for short). The Revenue has filed cross-objection in the assessee’s appeal for Asst.Year 2014-15 above. 2. It was common ground that the issues raised in both the set of appeals were identical. Therefore, both the appeals & CO were heard together

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

144C of the Income Tax Act, 1961 ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO 2 ("the Act" for short). The Revenue has filed cross-objection in the assessee’s appeal for Asst.Year 2014-15 above. 2. It was common ground that the issues raised in both the set of appeals were identical. Therefore, both the appeals & CO were heard together

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, CIRCLE-1(1)(2), AHMEDABAD

In the result, appeal of the assessee is allowed

Section 92C(2) of the Income-tax Act, 1961('the Act') and confirmed an upward TP adjustment amounting to INR 16,79,093 on account of liaison services provided by Zydus Japan to the Appellant. (b) That the learned Assessing Officer erred in law and on facts in making an addition of Rs.18

LESSO BUILDTECH PRIVATE LIMITED,GURGAON vs. THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is partly allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

144C(1) and the issue have not emanated from draft assessment order and not pertains to the findings of Assessing Officer. Therefore not adjudicated the adjustment made u/s. 143(1) of the Act. Pursuant to the DRP order, the Assessing Officer passed the final assessment order determining the total income of Rs. (-) 28,91,18,057/-. 5. Aggrieved against

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

1% of total contract costs as per para 2.6 of Section 2 of Appendix C to the production sharing contract has been accepted by the Revenue. It is pertinent to note that overhead charges that are financial, legal charges for manuals, journals, periodicals relating to oil industry and employee relation services are not included in Head Office expenses

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

1% of total contract costs as per para 2.6 of Section 2 of Appendix C to the production sharing contract has been accepted by the Revenue. It is pertinent to note that overhead charges that are financial, legal charges for manuals, journals, periodicals relating to oil industry and employee relation services are not included in Head Office expenses

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

1% of total contract costs as per para 2.6 of Section 2 of Appendix C to the production sharing contract has been accepted by the Revenue. It is pertinent to note that overhead charges that are financial, legal charges for manuals, journals, periodicals relating to oil industry and employee relation services are not included in Head Office expenses