DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowing [c] Unexplained rental expenses of Rs. 5,00,000/= [d] Unaccounted profit of. Rs.11,29,61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowing [c] Unexplained rental expenses of Rs. 5,00,000/= [d] Unaccounted profit of. Rs.11,29,61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowing [c] Unexplained rental expenses of Rs. 5,00,000/= [d] Unaccounted profit of. Rs.11,29,61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowing [c] Unexplained rental expenses of Rs. 5,00,000/= [d] Unaccounted profit of. Rs.11,29,61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

disallowing [c] Unexplained rental expenses of Rs. 5,00,000/= [d] Unaccounted profit of. Rs.11,29,61,022/= [e] Suppression of sale - Gas turbine Rs. 3,41,34,100/=. 2.3. Ld TPO, while passing the order u/s 92CA(3) has accepted the underlying transactions to be at Arms Length Pricing [ALP] and therefore not made any adjustment in relation

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

section 92CA(1) of the Act on account of determination of arm's length price of international transaction entered into by the assessee. 19. On appeal, the learned CIT(A) upheld the findings of the AO while relying upon his own decision for the AY 2003-04. 20. The assessee is now in appeal before us against the aforesaid findings

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

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

disallowed the claim of the assessee. 45. After considering submissions of the both the sides, we find that though the Hon’ble Gujarat High Court in the case of Gujarat State Road Transport Corporation (supra) has held that if the payment to PF and ESI are not being made within the due date prescribed under those Act, then deduction will

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

disallowed the claim of the assessee. 45. After considering submissions of the both the sides, we find that though the Hon’ble Gujarat High Court in the case of Gujarat State Road Transport Corporation (supra) has held that if the payment to PF and ESI are not being made within the due date prescribed under those Act, then deduction will

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

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

disallowance of expenses incurred by the assessee on behalf of its subsidiary firm 'Intas Pharmaceuticals from Rs 39,62,30,463/- to Rs 12,12,20,435 /- without properly appreciating the facts of the case and the material brought on record. 3. The Ld.CIT(A) has erred in law and on facts in allowing the deduction

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

3) r.w.s. 144C of the Income Tax Act, 1961 (The Act') in pursuance of the directions issued by the Learned Dispute Resolution Panel ('Ld. DRP') is illegal and bad in law. 1.1 That the Ld. DRP erred on facts and in law in confirming the additions/ disallowances proposed in the draft assessment order passed by the assessing officer, without judiciously

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

3) r.w.s. 144C of the Income Tax Act, 1961 (The Act') in pursuance of the directions issued by the Learned Dispute Resolution Panel ('Ld. DRP') is illegal and bad in law. 1.1 That the Ld. DRP erred on facts and in law in confirming the additions/ disallowances proposed in the draft assessment order passed by the assessing officer, without judiciously

MASTEK LIMITED,,AHMEDABAD vs. THE DY.CIT, (OSD) - 1, CIRCLE-4,, AHMEDABAD

Bench: Shri Pramod Kumar & Ms Madhumita Roysl. Ita No(S) Appeal(S) By Asset. Nos Year(S) Appellant Vs. Respondent Appellant Respondent 1. 1188/Ahd/2015 2009-10 M/S Mastek Ltd., D.C.I.T., (Osd)-1,Circle-4, 804/805Ahmedabad House, Opp. C.N. Vidyalaya, Nr. Ambawadi Circle, Ambawadi, Ahmedabad -380 006 Pan:Aaacm9908Q 2. 1852/Ahd/2015 2009-10 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad. Ahmedabad 3. It(Tp) 172/Ahd/2016 2010-11 M/S. Mastek Ltd. J.C.I.T., Ahmedabad Range-4, Ahmedabad 4. It(Tp) 514/Ahd/2016 2010-11 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad Ahmedabad Assessee By : Shri S. N. Soparkar & Parin Shah, A.Rs. Revenue By : Shri Krishna Murari, Cit- D.R.

disallowance in question. We thus direct the Assessing Officer to frame consequential computation as per law. Assessee's instant substantive ground is taken as partly accepted for statistical purposes in the above terms. In that view of the matter we find no justification to deviate from the stand taken by the Co-ordinate Bench. Hence, we direct