SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

u/s. 271(1)(c), vide order dated 25/07/2019. 4. The assessee has taken the following grounds of appeal:- I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 3 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,AHMEDABAD vs. THE DCIT, INTL. TAXN.-1,, AHMEDABAD

The appeal of the assessee is allowed and CO filed by the Department is being dismissed for assessment year 2010-11

u/s. 271(1)(c), vide order dated 25/07/2019. 4. The assessee has taken the following grounds of appeal:- I.T.A Nos.1389 to1392/Ahd/2019 & CO Nos. 16 to 19/Ahd/2022 Page No. 3 Shell Global Solutions International B.V. vs. DCIT & ACIT(IT) vs. Shell Global Solutions International B.V. “Shell Global Solutions International B.V. ('Appellant') craves leave to prefer appeal against the order dated

DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri P.M. Jagtap, Vice- & Shri Siddhartha Nautiyalassessment Year : 2009-10 Dcit, M/S. Adani Enterprises Ltd., Circle 1(1)(1), Vs Adani House, Nr. Mithakhali Ahmedabad Six Roads, Navrangpura, Ahmedabad - 380009 Pan : Aabca 2804 L अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Mohd. Usman, Cit-Dr Assessee By : Shri Vartik Choksi, Ar & Shri Biren Shah, Ar सुनवाई क" तार"ख/Date Of Hearing : 11/05/2022 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2022

u/s. 271(1)(c) of the Act were also initiated on this issue. The Ld. CIT(A) also confirmed the addition made by the A.O. on this issue. From the above facts, it is clear that the assessee had furnished concealment of income in respect of above issues. Had the assessee's case not been selected for scrutiny, the assessee

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

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

TP upward adjustment on corporate guarantee 2,388,000 Disallowances of weighted deduction on 4 Trademark and overseas product registration 10,658,244 Disallowances of weighted deduction on 5 corporate advertisement 14,433 Disallowances of weighted deduction on 6 expenses not approved by DSIR 163,725,000 ITA No. 928 & 921/Ahd/2017 [Sun Pharma Laboratories

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

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

TP upward adjustment on corporate guarantee 2,388,000 Disallowances of weighted deduction on 4 Trademark and overseas product registration 10,658,244 Disallowances of weighted deduction on 5 corporate advertisement 14,433 Disallowances of weighted deduction on 6 expenses not approved by DSIR 163,725,000 ITA No. 928 & 921/Ahd/2017 [Sun Pharma Laboratories

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,(OSD)-1, CIRCLE-4,, AHMEDABAD vs. MIDVALLEY HEALTHCARE SERVICES PVT.LTD.,, AHMEDABAD

In the result, the CO of the assessee is partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

TP order cannot be sustained. Hence, the addition made by the AO is hereby deleted and the deduction as claimed by the appellant u/s.10B is allowed accordingly. 2.12. Now, I am dealing with the alternate contention of the assessing officer in not allowing deduction of S.10B of the Act on the ground that the appellant has not obtained ratification from

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

penalty proceedings u/s.271(1)(c) r.w. Explanation-7 are hereby initiated.” 24. Being aggrieved by the order of Ld.CIT (A), the Assessee is in appeal before us. 25. The Ld. AR before us submitted that in the identical facts and circumstances in the own case of the assessee in ITA No. 1666/AHD/2016 the impugned addition was deleted

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1),, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

penalty proceedings u/s.271(1)(c) r.w. Explanation-7 are hereby initiated.” 24. Being aggrieved by the order of Ld.CIT (A), the Assessee is in appeal before us. 25. The Ld. AR before us submitted that in the identical facts and circumstances in the own case of the assessee in ITA No. 1666/AHD/2016 the impugned addition was deleted

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCEL-1,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

penalty proceedings u/s.271(1)(c) r.w. Explanation-7 are hereby initiated.” 24. Being aggrieved by the order of Ld.CIT (A), the Assessee is in appeal before us. 25. The Ld. AR before us submitted that in the identical facts and circumstances in the own case of the assessee in ITA No. 1666/AHD/2016 the impugned addition was deleted

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

penalty proceedings u/s.271(1)(c) r.w. Explanation-7 are hereby initiated.” 24. Being aggrieved by the order of Ld.CIT (A), the Assessee is in appeal before us. 25. The Ld. AR before us submitted that in the identical facts and circumstances in the own case of the assessee in ITA No. 1666/AHD/2016 the impugned addition was deleted

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 13) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 5. At the outset, the Counsel for the assessee submitted that in respect of Grounds 6 to 9 of the assessee’s appeal (Refund of excess