SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

section 92C of the Act. For the purpose of\nbenchmarking, the Assessee selected comparables by applying specific\nsearch filters, which were clearly specified in its transfer pricing study\nreport. The Profit Level Indicator (PLI) was calculated using the Profit\nBefore Depreciation

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

depreciation disallowance of Rs.68,00,471/-. (6) The CIT(A)has erred in law and in facts in deleting he addition of Rs.I,72,59,614/- made on account of unutilized CENVAT credits. (7) The CIT(A) has erred in law and in facts in adjustment of Rs. 1,15, I5,902/- u/s 1 I5JB of the Act on account

THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

depreciation disallowance of Rs.68,00,471/-. (6) The CIT(A)has erred in law and in facts in deleting he addition of Rs.I,72,59,614/- made on account of unutilized CENVAT credits. (7) The CIT(A) has erred in law and in facts in adjustment of Rs. 1,15, I5,902/- u/s 1 I5JB of the Act on account

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

depreciation disallowance of Rs.68,00,471/-. (6) The CIT(A)has erred in law and in facts in deleting he addition of Rs.I,72,59,614/- made on account of unutilized CENVAT credits. (7) The CIT(A) has erred in law and in facts in adjustment of Rs. 1,15, I5,902/- u/s 1 I5JB of the Act on account

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

depreciation disallowance of Rs.68,00,471/-. (6) The CIT(A)has erred in law and in facts in deleting he addition of Rs.I,72,59,614/- made on account of unutilized CENVAT credits. (7) The CIT(A) has erred in law and in facts in adjustment of Rs. 1,15, I5,902/- u/s 1 I5JB of the Act on account

KALPATARU POWER TRANSMISSION LTD.,,GANDHINAGAR vs. THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the assessee is dismissed

92C to the extent of Rs.2,52,319. 1.1 The learned CIT(A) has erred in confirming the order of the AO and TPO levying notional interest of Rs. 2,52,319 on short term advance made to its overseas subsidiaries being Kalpataru Power Transmission (Mauritius) Ltd and Kalpataru Power Transmission (Nigeria) Ltd. It is submitted that the learned

KALPATARU POWER TRANSMISSION LTD.,,GANDHINAGAR vs. THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR

Appeal of the assessee is dismissed

92C to the extent of Rs.2,52,319. 1.1 The learned CIT(A) has erred in confirming the order of the AO and TPO levying notional interest of Rs. 2,52,319 on short term advance made to its overseas subsidiaries being Kalpataru Power Transmission (Mauritius) Ltd and Kalpataru Power Transmission (Nigeria) Ltd. It is submitted that the learned

THE DY. CIT, GANDHINAGAR CIRCLE,, GANDHINAGAR vs. M/S. KALPARATRU POWER TRANSMISSION LIMITED,, GANDHINAGAR

Appeal of the assessee is dismissed

92C to the extent of Rs.2,52,319. 1.1 The learned CIT(A) has erred in confirming the order of the AO and TPO levying notional interest of Rs. 2,52,319 on short term advance made to its overseas subsidiaries being Kalpataru Power Transmission (Mauritius) Ltd and Kalpataru Power Transmission (Nigeria) Ltd. It is submitted that the learned

BUNDY INDIA LTD.,,BARODA vs. THE DCIT, CIRCLE-1(1),, BARODA

In the result, the appeal preferred by the assessee is allowed in part

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

section 92C(2) of the Act (prior to the amendment by Finance (No. 2) Act, 2009), the ld. AO / ΤΡΟ should apply 5% variation to the arm's length price of the international transaction between the Appellant and its AEs. ITA No.1764/Ahd/2013 (Bundy India Limited vs. DCIT) A.Y.– 2007-08- 6 – 8. The learned CIT(A) erred by upholding

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)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

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)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

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)

depreciation under Section 32(1)(iia) of the Act. These factual aspects were not disputed by the Ld. DR in the present Assessment Years as well. Thus, Ground No. 5 is allowed. 19. As regards to Ground Nos. 6 and 6.1, disallowance of weighted deduction under Section 35 (1)(ii) of the Act, the Ld. AR submitted that the assessee

M/S. TBEA SHENYANG TRASFORMER GROPUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

In the result, the appeal filed by the assessee is dismissed

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleआयकर अपील सं./I.T.A. No. 581/Ahd/2017 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ M/S. Tbea Shenyang Deputy Commissioner Of Transformer Group Income Tax Vs. Company Limited International Taxation, National Highway No.-8, Vadodara Villae : Miyagam, Karja, Vadodara, Gujarat - 390007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadct4557F (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Arpit Jain, Ar ""यथ" क" ओर से/Respondent By : Shri Mahesh Shah, Cit. Dr 24/04/2025 Date Of Hearing Date Of Pronouncement 22/07/2025 O R D E R Per Smt. Annapurna Gupta, Am:

section 92C, the most appropriate method shall be the method which is best suited to the facts and circumstances of each particular international transaction, and which provides the most reliable measure of an arm's length price in relation to the international transaction, as the case may be. (2) In selecting the most appropriate method as specified in sub-rule

ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

92C(2) of the Act and thus the Ld. TPO earned in disregarding the transfer pricing benchmarking analysis earned out by the Appellant in relation to the international transaction of the provision of software development services to its Associated Enterprises (AES) The Appellant prays that the Ld. TPO be directed to accept the transfer pricing benchmarking analysis conducted

SCHNEIDER ELECTRIC INFRASTRUCTURE LTD,VADODARA vs. THE ADD./JT. DCIT/ITO NATONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalassessment Year : 2017-18 Schneider Electric Infrastructure D.C.I.T, Limited, Vs Circle-2(1)(1), Milestone 87, Vadodara Halol Vadodara. Highway, Village Kotambi, Po Jaroad, Vadodara-391510 Pan : Aapcs 6078 Q

section 92C(2) of the Act. 6.29 The assessee also submitted that the proposed adjustments made by the TPO in TP order for purchase of raw materials and components, purchase of fixed assets, purchase of intangible assets and payment for trade mark fees are factually incorrect as the adjustment should be made only the cost attributable to license manufacturing segment

THE DCIT, CIRCLE-1(1)(1), VADODARA vs. GULBRANDSEN CHEMICALS PVT. LTD, VADODARA

In the result, the appeal filed by the revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 559/Ahd/2020 िनधा"रण वष"/Asstt. Years: 2011-12 D.C.I.T., Gulbrandsen Chemicals Pvt. Ltd, Circle-1(1)(1), Vs. On Coastal Highway, Vadodara. Mujpur, Tal. Padra, Vadodara.

92C(2) of Income Tax Act ?" 9. "Whether in facts and circumstances of the case and in law, the Ld. CIT(A) was justified in deleting the adjustment made by the TPO amounting Rs.1,76,49,394/- on account of benchmarking of sales promotion and marketing services availed by assessee claimed to have been paid by the assessee

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 92C of the Act. 16. In response, DR placed reliance on the observations made by the assessing officer in the assessment order. 17. We have heard the rival contentions and perused the material on record. We observe that the counsel for the assessee has made a specific claim to the effect that since the expenses in question had been

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Section 92C of the Act. 16. In response, DR placed reliance on the observations made by the assessing officer in the assessment order. 17. We have heard the rival contentions and perused the material on record. We observe that the counsel for the assessee has made a specific claim to the effect that since the expenses in question had been