THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM LTD.,, AHMEDABAD

In the result, revenue’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-4,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

house / real estate agent / broker, who will be involved in merely identifying the right property for the prospective buyer / seller and once he completes the deal, he gets the commission. Thus, by no stretch of imagination, it cannot be said that the transaction partakes the character of "fees for technical services" as explained in the context of Section 9(1

M/S. INOX INDIA LTD.,,BARODA vs. THE PR. CIT-1,, VADODARA

In the result, the appeal is allowed

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM PVT. LTD.,, AHMEDABAD

In the result, the appeal is dismissed

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax From The Payments Made To M/S. Urja International, Usa Which Proves That The

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

M/S. PANASONIC ENERGY INDIA CO.LTD,VADODARA vs. THE PR. CIT-2,, BARODA

In the result, the appeal is allowed

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to M/s. Panasonic Energy Inddia Co Ltd vs. Pri. CIT Assessment year: 2009-10 Page 11 of 24 non-resident agents, for the services rendered

KARNAVATI ENGINEERING LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-4,, AHMEDABAD

In the result, the appeal is allowed in the terms indicated above

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax

66 taxmann.com 321 (Madras)], wherein Their Lordships have, inter alia, observed as follows: 5. The main contention of the learned counsel for the assessee/respondent is that the agency commission/sales commission paid by the assessee to non-resident agents, for the services rendered by them, outside India, in procuring export orders for the assessee, would not attract or partake the character

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

66 (Del)], where it was held that once working capital adjustment is made under TNMM, no separate addition for outstanding receivables is justified. The Bench rejected the reliance placed by the Revenue on the earlier ITAT rulings (such as Bechtel India Pvt. Ltd. and Ameriprise India Pvt. Ltd.) which were rendered prior to Kusum Healthcare’s decision. It was specifically

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

66 (Del)], where it was held that once working capital adjustment is made under TNMM, no separate addition for outstanding receivables is justified. The Bench rejected the reliance placed by the Revenue on the earlier ITAT rulings (such as Bechtel India Pvt. Ltd. and Ameriprise India Pvt. Ltd.) which were rendered prior to Kusum Healthcare’s decision. It was specifically

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1) of the Act, the details whereupon were duly filed by the assessee through electronic media on e-proceeding. The assessee had shown total turnover of Rs.65,54,16,69,939/-, on which, net profit before tax has been declared at Rs.24,33,45,21,094/-. The assessee has shown income from house property, capital gain and other