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, 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

SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

u/s 271(l)(c) of Rs. 2,76,33,870.\n9. The learned CIT(A) erred in fact and in law in confirming the action of the\nlearned AO in levying penalty despite the fact that the Appellant has not furnished\ninaccurate particulars of income either in return of income or during the course of\nassessment proceedings.\n10. The learned

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

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

144C(13). 2.4 While concluding the assessment, the Assessing Officer has recorded satisfaction that the assessee furnished inaccurate particulars of income. Penalty proceedings under section 271(1)(c) were initiated. The order further notes initiation of penalty proceedings for non-reporting of an international transaction said to pertain to provision of on-shore services by the project office

CADILA HEALTHCARE LTD.,AHMEDABAD vs. DCIT, CIRCLE-1(1)(2), AHMEDABAD

In the result, appeal of the assessee is allowed

penalty proceedings u/s 271(1)(c) of the IT. Act in respect of each of the additions made by him in the assessment order u/s 143(3) r.w.s.144C(13) r.w.s. 254. The appellant prays that leave may be granted to add, amend or alter any of the grounds at any time before the final hearing of the appeal

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

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., ,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, 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

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

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

M/S. JOY GLOBAL (UK) LIMITED,(EARLIER KNOWS AS JOY MINING MACHINERY LIMITED OR 'JMML'),KOLKATTA vs. THE ACIT (INT. TAXN.)-2,, AHMEDABAD

In the result, we allow the Grounds of Appeal of the assessee

penalty proceedings u/s 271(1)(c) of the IT Act, 61 are also initiated for concealment of income on this issue for A.Y.2016-17. I.T.A No. 1483/Ahd/2019 A.Y. 2016-17 Page No 5 M/s. Jay Global (UK) Ltd. vs. ACIT (Int. Taxn. 5. This Draft Assessment order was carried to Dispute Resolution Panel (hereinafter referred to as “DRP”) by the assessee