DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

additions made by the AO on Royalty payment by observing as follows: “… … 4.6. I have carefully examined the facts of the case, the submissions made by the appellant, the assessment order, and the transfer pricing order passed under section 92CA(3) of the Act. The primary issue under consideration pertains to the determination of the ALP of the royalty payment

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

additions made by the AO on Royalty payment by observing as follows: “… … 4.6. I have carefully examined the facts of the case, the submissions made by the appellant, the assessment order, and the transfer pricing order passed under section 92CA(3) of the Act. The primary issue under consideration pertains to the determination of the ALP of the royalty payment

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

In the result, the appeal filed by the assessee is dismissed

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleआयकर अपील सं./I.T.A. No. 581/Ahd/2017 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ M/S. Tbea Shenyang Deputy Commissioner Of Transformer Group Income Tax Vs. Company Limited International Taxation, National Highway No.-8, Vadodara Villae : Miyagam, Karja, Vadodara, Gujarat - 390007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadct4557F (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Arpit Jain, Ar ""यथ" क" ओर से/Respondent By : Shri Mahesh Shah, Cit. Dr 24/04/2025 Date Of Hearing Date Of Pronouncement 22/07/2025 O R D E R Per Smt. Annapurna Gupta, Am:

income from the transaction is offered for tax in India. Accordingly, I hold that on this count also the transfer pricing addition

ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

addition proposed by the Learned Assessing Officer (Ld. AG) Learned Transfer Pricing Officer (Ld. TPO) of INR 3.354.09.319/- to the income

ASANDAS & SONS PRIVATE LIMITED,MEHSANA vs. THE DY.CIT, CIRCLE- GANDHINAGAR, GANDHINAGAR

In the result the appeal filed by the assessee is allowed for statistical purpose

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

income arising from an international transaction shall be computed having regard to the arm's length price. Section 92C dealing with computation of ALP provides through sub-section (1) that the ALP shall be determined by any of the following methods, being the most appropriate method, having regard to the nature of transaction or class of transaction or class

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

Transfer Pricing Officer for determining Arms’ Length Price of the International Transaction undertaken by the assessee company and the TPO accepted the price at which International Transaction were recorded and no adverse inference was drawn by passing order dated 28-10-2019 under section 92CA(3) of the Act. Following the same, the Ld AO accepted the returned income filed

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

addition of expense of Rs 39,62,30,463/- incurred by the assessee to earn exempt income u/s 10(2A) on behalf of Intas Pharma (IP) to the Book Profits u/s 115JB of the Act. 5. On the facts and in the circumstances of the case, the Ld. CIT(A) ought to have upheld the order of the Assessing Officer

THE DCITBHARUCH RANGE,, BHARUCH vs. HEUBACH COLOUR PVT.LTD.,, ANKLESHWAR

In the result, Ground Number 3 of the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

income of the assessee contrary to the stand taken by the Transfer Pricing Officer and the Assessing Officer. (iii) the Ld.CIT(A) erred in law and facts of the case, in scaling down the upward adjustment of Rs.32,83,64,753/- made by the Transfer Pricing Officer to Rs.17,88,08,043/- on sale of finished goods at Rs.66

AXIS BANK LIMITED,AHMEDABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD

The appeal of the assessee is partly allowed for statistical purposes

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2018-19 Axis Bank Limited, Vs. Assistant Commissioner Of “Trishul”, 3Rd Floor, Opp. Income-Tax, Samartheshwar Temple, Nr. Law Circle 1(1)(1), Garden, Ellisbridge, Ahmedabad Ahmedabad-380006 Pan : Aaacu 2414 K अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Tushar Hemani, Sr. Advocate & Shri Parimalsinh B. Parmar, Ar Revenue By : Dr. Darsi Suman Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.11.2023/03.04.2024 घोषणा क" तारीख /Date Of Pronouncement: 10.04.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: By Way Of This Appeal, The Assessee-Appellant Has Challenged Correctness Of The Order Dated 28Th July, 2022 Passed By The Assessing Officer Under Section 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act” For Short], For The Assessment Year (Ay) 2018-19. 2. Ground No.1 Raised By The Assessee Reads As Under:- “1. Disallowance In Respect Of Annual Technical Fees (Tax Effect - Rs. 16,84,276) 1.1 The Learned Drp Has Erred In Upholding Addition Made By Ao In Respect Of Treating Annual Technical Services (Ats) Fees Paid To Infosys Limited To The Extent Of Rs. 48.66 Lacs As Prior Period Expense. 1.2. It Is Submitted That The Expenditure Relates To Amount Payable To Infosys & No Part Of The Amount Was Claimed As Expenditure At Any Time In The 2 Axis Bank Limited Vs. Acit Ay : 2018-19

TRANSFER PRICING: When Tribunal in separate orders accepted commission on corporate guarantee provided to AEs charged at 0.20 per cent to be at arm's length then following consistent view, addition made on account of adjustment to commission charged on corporate guarantee should be deleted. 42. Our attention was specifically invited to the decision of the Tata International Ltd. (supra

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

income as a loss. During assessment, transfer pricing adjustments and disallowance for additional depreciation were made. Consequently, penalty proceedings under

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)

Income-tax Act. 1961- Transfer pricing Maintenance and keeping of information and document-Assessment year 2003-04-Assessee was a company engaged in business of manufacturing and distributing non- pharmaceutical healthcare products It had entered into an international transactions with its associated enterprises (AE) - During course of assessment proceedings, it was observed that assessee had total international transaction

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), 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)

Income-tax Act. 1961- Transfer pricing Maintenance and keeping of information and document-Assessment year 2003-04-Assessee was a company engaged in business of manufacturing and distributing non- pharmaceutical healthcare products It had entered into an international transactions with its associated enterprises (AE) - During course of assessment proceedings, it was observed that assessee had total international transaction

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)

Income-tax Act. 1961- Transfer pricing Maintenance and keeping of information and document-Assessment year 2003-04-Assessee was a company engaged in business of manufacturing and distributing non- pharmaceutical healthcare products It had entered into an international transactions with its associated enterprises (AE) - During course of assessment proceedings, it was observed that assessee had total international transaction

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)

Income-tax Act. 1961- Transfer pricing Maintenance and keeping of information and document-Assessment year 2003-04-Assessee was a company engaged in business of manufacturing and distributing non- pharmaceutical healthcare products It had entered into an international transactions with its associated enterprises (AE) - During course of assessment proceedings, it was observed that assessee had total international transaction