THE TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD
In the result, the appeal of the Revenue is dismissed
ITA 1634/AHD/2012[2008-09]Status: DisposedITAT Ahmedabad15 May 2019AY 2008-09
Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.
For Appellant: Shri S. N. Soparkar & Parin Shah, A.RFor Respondent: Shri Ramesh Chandra Panday, CIT-D.R
Section 35Section 80Section 92C
disallowed by the tax authority of Canada.
Subsequently, the Canadian court held that Canadian subsidiary benefitted from the better financing conditions of the parent company due to explicit guarantee. The court also held in the same case even in the absence of a formal guarantee subsidiary would have benefitted from the implicit group support.
Accordingly, TPO held since the case
