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
ITA 1783/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16
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
Section 143(3)Section 144C
249/- to the international transaction entered by the assessee with its AE, HLPL and SIMPL. The upward adjustment proposed by the TPO are tabulated in his order as under:
ITA No.2390/Ahd/2018 & 1783/Ahd/2019 with CO
6
10. The assessee objected to the proposed upward adjustment to the DRP, who noted that this issue was under consideration before the DRP consistently