INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

92E, ‘international transaction’ means a transaction between two or more associated enterprises, either or both of whom are non-resident, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2,, BHARUCH vs. M/S. HEUBACH COLOUR PVT. LTD.,, ANKLESHWAR

In the result, the appeal of the Revenue for assessment year 2010-11 is partly allowed for statistical purposes as indicated above

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

92E relating to international transactions. The ld. CIT(A) observed that the TPO has examined this international transaction, and passed an order dated 14.12.2012 under section 5 AY:2009-10 AY:2010-11 Heubach Colour Private Limited 92CA(3) of the Act without any adjustment. Thus, the ld. CIT(A) observed that this fact clearly establishes that the payment

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2,, BHARUCH vs. M/S. HEUBACH COLOUR PVT. LTD.,, ANKLESHWAR

In the result, the appeal of the Revenue for assessment year 2010-11 is partly allowed for statistical purposes as indicated above

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

92E relating to international transactions. The ld. CIT(A) observed that the TPO has examined this international transaction, and passed an order dated 14.12.2012 under section 5 AY:2009-10 AY:2010-11 Heubach Colour Private Limited 92CA(3) of the Act without any adjustment. Thus, the ld. CIT(A) observed that this fact clearly establishes that the payment

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

depreciation thereon under the provisions of the Act. 11.3 Without prejudice to the above, hedging charges amounting to Rs. 10,00,30,513/- incurred towards investment made by the Company in overseas subsidiary companies should be adjusted to the cost of acquisition of such investment. 12. Re: Double taxation of Income from Capital gains and other sources.: 12.1 The Assessing

AIA ENGINEERING LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

THE DCIT, CIRCLE-1,, AHMEDABAD vs. AIA ENGINEERING LTD.,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92 B defines the expression 'international transaction

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

92E. During assessment-proceeding, the Ld. AO made a reference to the Transfer Pricing Officer [“Ld. TPO”] u/s 92CA for determining the Arm’s Length Price [“ALP”] of the “international transactions” done by assessee. In the course of proceeding before Ld. TPO, the assessee submitted the details of international-transactions with the supportive documents including the Page

THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD vs. M/S. GUJARAT MICROWAX LTD.,, AHMEDABAD

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

92E. During assessment-proceeding, the Ld. AO made a reference to the Transfer Pricing Officer [“Ld. TPO”] u/s 92CA for determining the Arm’s Length Price [“ALP”] of the “international transactions” done by assessee. In the course of proceeding before Ld. TPO, the assessee submitted the details of international-transactions with the supportive documents including the Page