THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

u/s 92B and upheld the ALP of 0.50%, following the order in the case of the assessee for the earlier year. The Tribunal followed Everest Kento Cylinder Ltd. v. Asstt. CIT [2015] 56 taxmann.com 361 (Mum- Trib). It seems that the decision in Bharti Airtel Ltd. (supra) was not referred to in this case. (iv) Aditya Birla Mincas Worldwide

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

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

u/s 92B and upheld the ALP of 0.50%, following the order in the case of the assessee for the earlier year. The Tribunal followed Everest Kento Cylinder Ltd. v. Asstt. CIT [2015] 56 taxmann.com 361 (Mum- Trib). It seems that the decision in Bharti Airtel Ltd. (supra) was not referred to in this case. (iv) Aditya Birla Mincas Worldwide

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

u/s 92B and upheld the ALP of 0.50%, following the order in the case of the assessee for the earlier year. The Tribunal followed Everest Kento Cylinder Ltd. v. Asstt. CIT [2015] 56 taxmann.com 361 (Mum- Trib). It seems that the decision in Bharti Airtel Ltd. (supra) was not referred to in this case. (iv) Aditya Birla Mincas Worldwide

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

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

u/s 92B and upheld the ALP of 0.50%, following the order in the case of the assessee for the earlier year. The Tribunal followed Everest Kento Cylinder Ltd. v. Asstt. CIT [2015] 56 taxmann.com 361 (Mum- Trib). It seems that the decision in Bharti Airtel Ltd. (supra) was not referred to in this case. (iv) Aditya Birla Mincas Worldwide

ADANI ENTERPRISES LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD

Appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedasstt. Sr.No.

92C(3) of the IT Act. Further, the, cost of this service rendered by assesee is fixed at 3.43% of the guarantee issued based on the procedure detailed above. The assessee has pointed out that there are certain errors In the opening balance figure, of guarantees given by the assessee on behalf of the AEs. In light of the documents

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

92C(1) of the Act, ALP of the international transact is required to be determined using any of the profit based prescribed methods, being the Most Appropriate method (MAM) having regard to the nature of transaction or class of transactions. However, in order to determine the MAM for determining the ALP, it is first necessary to select the 'tested party

ATUL LIMITED,AHMEDABAD vs. THE ACIT.,RANGE-1,, AHMEDABAD

Appeal is dismissed

92C(2)]. 136. In the light of above general observations, we now proceed to consider various objections of the parties first being clubbing of international transactions for reference to the TPO. The taxpayer, before the learned CIT(A), had contended that clubbing of all transactions with mere mention of aggregate value of all I.T.A No. 1681/Ahd/2011 A.Y. 2005-06 Page

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

92C(1) of the Act, ALP of the international transact is required to be determined using any of the profit based prescribed methods, being the Most Appropriate method (MAM) having regard to the nature of transaction or class of transactions. However, in order to determine the MAM for determining the ALP, it is first necessary to select the 'tested party

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

92C(1) of the Act, ALP of the international transact is required to be determined using any of the profit based prescribed methods, being the Most Appropriate method (MAM) having regard to the nature of transaction or class of transactions. However, in order to determine the MAM for determining the ALP, it is first necessary to select the 'tested party