THE DCIT, CENTRAL CIRCLE-2,, BARODA vs. RUBAMIN LIMITED.,, BARODA

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

144C of the Act was completed determining the total income as Rs. 27,06,13,861/- making addition of Rs. 1.34 Crore including 29.70 lakhs on account of upward adjustment; Rs. 2.51 Crores on account of notional sales tax and other additions. The A.O. also initiated penalty proceedings u/s. 271(1)(c) of the Act on the ground that

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)

144C of the Act, it is apparent that except initiating penalty under section 271AA in the last line of assessment order, there is no discussion as to why such penalty has been initiated by the AO or which were the documents/information as required in Section 92D which was not furnished by appellant during transfer pricing proceedings. In the present case

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)

144C of the Act, it is apparent that except initiating penalty under section 271AA in the last line of assessment order, there is no discussion as to why such penalty has been initiated by the AO or which were the documents/information as required in Section 92D which was not furnished by appellant during transfer pricing proceedings. In the present case

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)

144C of the Act, it is apparent that except initiating penalty under section 271AA in the last line of assessment order, there is no discussion as to why such penalty has been initiated by the AO or which were the documents/information as required in Section 92D which was not furnished by appellant during transfer pricing proceedings. In the present case

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)

144C of the Act, it is apparent that except initiating penalty under section 271AA in the last line of assessment order, there is no discussion as to why such penalty has been initiated by the AO or which were the documents/information as required in Section 92D which was not furnished by appellant during transfer pricing proceedings. In the present case

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)

144C of the Act, it is apparent that except initiating penalty under section 271AA in the last line of assessment order, there is no discussion as to why such penalty has been initiated by the AO or which were the documents/information as required in Section 92D which was not furnished by appellant during transfer pricing proceedings. In the present case

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

144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill

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

144C of the Act, vide assessment order dated 28.01.2019, determining the total income of the assessee at Rs.430,72,97,310/-. The AO made following additions/disallowances: ITA No.281 and 222/Ahd/2021 3 Sr. Particulars of Addition/Disallowance Amount (Rs.) No. 1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

M/S. SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

SHELL INTERNATIONAL B.V., ,AHMEDABAD vs. THE ACIT, INTL. TAXN.-1, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INT.TAXA.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

SHELL INTERNATIONAL B.V., ,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

M/S. SHELL INTERNATIONAL B.V.,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed

M/S. SHELL INTERNATIONAL B.V.,,MUMBAI vs. THE DY. CIT, INTL. TAXN.-1,, AHMEDABAD

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

u/s 195 and there was no question of advance tax payment by assessee and thus, no interest under Section 234B could be levied upon assessee. ITA Nos. 2788/Ahd/2017 & 09 others Shell International BV vs. DCIT(International Taxation) & 09 others Asst. Years –2009-10 to 2018-19 47. In the result, Ground No. 7 of the assessee’s appeal is allowed