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(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

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

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

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(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

M/S. ATUL LTD.,,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

The appeal of the assessee is partly allowed in the above terms for statistical purpose

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarit(Tp)A No.446/Ahd/2015 Assessment Year : 2010-11 M/S.Atul Limited Dcit, Cir.1(1)(2) Atul House Vs Ahmedabad. Gi Patel Marg Ahmedabad 380 014. Pan : Aabca 2390 M

method and there is no dispute in this regard. To arrive at the ALP, on one hand the assessee wanted five type of adjustment in the sale price fetched by the assessee from the transaction with it's AEs, but on the other hand the TPO has allowed three adjustments i.e. (i) adjustment of 5% towards marketing & financial risk

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LTD.( ERSTWHILE LUK INDIA PVT. LTD)), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 8) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 3. Before us, at the outset, the Counsel for the assessee submitted that he shall not be pressing for Ground No. 1 of the assessee

SCHAEFFLER INDIA LIMITED,VADODARA, GUJARAT vs. ASSISTANT DIRECTOR OF INCOME TAX,CPC, BANGALORE (JAO-DEPUTY COMMISSIONER OF INCOME TAX CIRCLE1(1)(1), VADODARA, GUJARAT

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 8) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 3. Before us, at the outset, the Counsel for the assessee submitted that he shall not be pressing for Ground No. 1 of the assessee

SCHAEFFLER INDIA LTD.(A SUCCESSOR OF LUK INDIA PVT. LTD)),VADODARA vs. THE ACIT, CIRCLE-1(1)(1) (EARLIER ACIT, CIRCLE-1, HOSUR), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

penalty proceedings u/s 271(1)(c) of the Act. 8) Your Appellant craves the right to add to or alter, amend, substitute, delete or modify all or any of the above grounds of appeal.” 3. Before us, at the outset, the Counsel for the assessee submitted that he shall not be pressing for Ground No. 1 of the assessee

SHELL ENERGY INDIA PRIVATE LIMITED,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

penalty proceedings against the Appellant under section 271(l)(c) of the Act. Each of the above grounds is independent and without prejudice to the other grounds of appeal F referred by the Appellant. The Appellant prays for leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time

THE ACIT, CIRCLE-4(1)(1), AHMEDABAD vs. M/S. SHELL ENERGY INDIA PVT. LTD. (FORMERLY KNOWN AS M/S. HAZIRA LNG. PVT. LTD.), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

penalty proceedings against the Appellant under section 271(l)(c) of the Act. Each of the above grounds is independent and without prejudice to the other grounds of appeal F referred by the Appellant. The Appellant prays for leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any time before or at, the time