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

section 192 of the Act. But the assessee has claimed such expenses without deducting the TDS. Thus the impugned expenses cannot be allowed under section 40(a)(ia) of the Act. The ld. DR vehemently supported the order of the lower authorities. 17. We have heard the rival contentions of both the parties and perused the material available

THE DCIT, CIRCLE-11,, AHMEDABAD vs. SHRI UMANG HIRALAL THAKKAR, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

68,61,112/- claimed by the appellant u/s. 801B(10) of the I.T. Act, 1961 being an amounts for the deductions claimed of Rs.6,20,64,195/- in Swaminarayan Enterprise, Rs.3,89,76,532/- in Ghanshyam Enterprise and Rs.3,58,20,384/- in Neelkanth Enterprise as per Form No.10CCB certified by The Chartered Accountant. I.T.A Nos. 760 & 796/Ahd/2011

SHRI UMANG H. THAKKAR,AHMEDABAD vs. THE DY.CIT.,WARD-7(2),, AHMEDABAD

In the result, appeal filed by the revenue is dismissed and appeal filed by assessee is partly allowed for statistical purposes

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

68,61,112/- claimed by the appellant u/s. 801B(10) of the I.T. Act, 1961 being an amounts for the deductions claimed of Rs.6,20,64,195/- in Swaminarayan Enterprise, Rs.3,89,76,532/- in Ghanshyam Enterprise and Rs.3,58,20,384/- in Neelkanth Enterprise as per Form No.10CCB certified by The Chartered Accountant. I.T.A Nos. 760 & 796/Ahd/2011

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE(INT.TAXN.)-1, AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

JOSHI TECHNOLOGIES INTERNATIONAL INC INDIA PROJECTS,AHMEDABAD vs. THE ACIT (INT. TAXA-1), AHMEDABAD

In the result, all the three appeals filed by the assessee are partly allowed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

801B(9) of Rs. 11,73,87,247/-. The statutory notices were issued and after verification of Form No. 3CEB, the Assessing Officer was noticed that the assessee company had entered into international transactions with its associated enterprises. After obtaining approval, the matter was referred to TPO for examining the TP Risk Parameter. The order u/s. 92CA

SUN PHARMACEUTICAL INDUSTRIES,MUMBAI vs. JCIT 20(3), MUMBAI

In the result appeal of the Revenue is hereby dismissed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

section 80IA(10) of the Act for Rs. 1,25,288/- after invoking the provision of section 80IE(6) of the Act. 16. At the outset we note that the learned AR for the assessee before us submitted that he has been instructed by the assessee not to press the impugned ground of appeal due to smallness

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE JT. CIT, RANGE-4,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

THE DCIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LTD.,,AHMEDABAD vs. DCIT CIRCLE-2(1) (2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

801B (8A) of the Act. 5. The Ld CIT(A) has erred in deleting the addition of Rs 2,33,374/- as rent advance not returned back without appreciating the fact that the assessee had failed to deductTDS on such, rent advances in terms of Section 194 I of the Act and therefore, the said amount was disallowable

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

68 taxmann.com 322, held that AE’s are accepted as tested party being the least complex for comparability analysis of international transaction of the assessee. The relevant extract of the order is reproduced as under: “18. We have carefully considered the rival contentions. We have also perused the relevant paragraphs of the several documents relied upon before

M/S. SAGAR PROJECTS,BARODA vs. THE DY.CIT, CENTRAL CIRCLE-2,, BARODA

Appeals of the assessees are allowed for statistical purposes

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

801B(10) amounting to Rs.3,74,191/- as claimed. 2. Your appellant craves the liberty to add, alter, amend or delete any or all of the above ground(s) of appeal. 4. Facts of the case are that assessee is engaged in the business of construction and developer. A search action u/s.132 of the Act was conducted in Darshanam Group