ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD
In the result, appeal filed by the assessee is partly allowed for statistical purposes
ITA 392/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad29 Jan 2026AY 2017-18
Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)
For Appellant: Shri Mukesh Patel, Shri Ajit KumarFor Respondent: Shri Prathvi Raj Meena, CIT.DR
Section 153(4)Section 153CSection 35Section 35(1)(i)Section 35(1)(iv)Section 92CSection 92C(2)
section 92C(2) of the Act.
6. That the learned AO / TPO / DRP has erred in law and on facts in rejecting consistent benchmarking approach followed by the Appellant, rejecting functionally comparable companies and arbitrarily cherry-picking companies for the purpose of benchmarking the transaction of sale of goods to Zydus USA.
7. That the learned AO/TPO/DRP has erred
