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276 results for “transfer pricing”+ Business Incomeclear

Sorted by relevance

Mumbai2,155 Delhi1,879 Chennai472 Hyderabad406 Bangalore406 Ahmedabad276 Jaipur227 Kolkata223 Chandigarh166 Pune153 Indore126 Cochin123 Rajkot95 Surat81 Visakhapatnam67 Nagpur47 Raipur44 Lucknow39 Cuttack36 Amritsar28 Guwahati26 Jodhpur23 Agra21 Dehradun12 Patna9 Jabalpur8 Varanasi7 Panaji7 Allahabad5 Ranchi4

Key Topics

Section 143(3)88 Addition to Income67 Disallowance49 Section 26348 Section 92C46 Section 3741 Section 271A23 Transfer Pricing23 Deduction

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

Business Income [as per Return of income] Rs. 14,81,24,50,439/- Add: Additions / disallowances as discussed above 1. Transfer pricing

Showing 1–20 of 276 · Page 1 of 14

...

23

Section 132(4)22

Survey u/s 133A18

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

ITA 2005/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2012-13

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

Section 143(3)Section 80ISection 92BSection 92C

business and that the TPO's determination of ALP at NIL, without following the prescribed methodology or rejecting the appellant's transfer pricing documentation, is not sustainable in law. Alternatively, I also take note of the appellant's alternative submission that the royalty payment forms part of the overall I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 5 DCIT

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

ITA 2006/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2013-14

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

Section 143(3)Section 80ISection 92BSection 92C

business and that the TPO's determination of ALP at NIL, without following the prescribed methodology or rejecting the appellant's transfer pricing documentation, is not sustainable in law. Alternatively, I also take note of the appellant's alternative submission that the royalty payment forms part of the overall I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 5 DCIT

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

ITA 581/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad22 Jul 2025AY 2012-13

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:

For Appellant: Shri Arpit Jain, ARFor Respondent: Shri Mahesh Shah, CIT. DR

Section 143(3)Section 9Section 92C

income from the transaction is offered for tax in India. Accordingly, I hold that on this count also the transfer pricing addition is unsustainable and is hereby deleted.” 17. Learned CIT(A) further observed that the transfer pricing addition was incorrectly made by selecting functionally incomparable transactions by observing as follows:- “10. I have perused the above submission

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

ITA 1334/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

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

ITA 1646/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

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

ITA 1336/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2011-12

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

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

ITA 1335/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

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

ITA 1644/AHD/2017[2009-10]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2009-10

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

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

ITA 1645/AHD/2017[2010-11]Status: DisposedITAT Ahmedabad31 Jan 2024AY 2010-11

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Dr. Darsi Suman Ratnam, CI

transfer pricing regulations is to prevent shifting out of profits by manipulating prices charged or paid in international transactions, thereby eroding the Country's tax base." Sec.92 of the Act lays down that any income arising from an international transaction shall be computed having regard to the arm's length price. The charge to tax under

DCIT (EXMP) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 20/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R

Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

business undertaking" whether the profit arising there from can be subjected to tax by invoking section 11(4) of the IT Act? This section says that in respect of such an undertaking where a claim is made that the income arising there from not to be included in the total income, then this section must not be applied This section

DCIT(EXEMPTION) CIRCLE-1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 23/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2020-21

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R

Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

business undertaking" whether the profit arising there from can be subjected to tax by invoking section 11(4) of the IT Act? This section says that in respect of such an undertaking where a claim is made that the income arising there from not to be included in the total income, then this section must not be applied This section

DCIT(E), CIRCLE-1, AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 21/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R

Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

business undertaking" whether the profit arising there from can be subjected to tax by invoking section 11(4) of the IT Act? This section says that in respect of such an undertaking where a claim is made that the income arising there from not to be included in the total income, then this section must not be applied This section

DCIT (EXMP) CIRCLE-1 AHMEDABAD, AHMEDABAD vs. GUJARAT STATE BOARD OF SCHOOL TEXT BOOK, GANDHINAGAR

In the result, both the M

ITA 22/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad30 Sept 2024AY 2018-19

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand V. Mahadeokar (Accountant Member)

For Appellant: Shri M.K. Patel, A.RFor Respondent: Shri Prithviraj Meena, CIT-D.R

Section 11Section 11(1)(a)Section 11(4)Section 12ASection 143(3)

business undertaking" whether the profit arising there from can be subjected to tax by invoking section 11(4) of the IT Act? This section says that in respect of such an undertaking where a claim is made that the income arising there from not to be included in the total income, then this section must not be applied This section

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

ITA 359/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2018-19

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

income of Rs. 70,15,57,590/- was therefore enhanced by the said amount and assessed at Rs. 74,09,66,910/- under section 143(3) read with section 144C(13) of the Act. 5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. I.T.A No. 359/Ahd/2022

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

ITA 1854/AHD/2024[2021-22]Status: DisposedITAT Ahmedabad25 Jun 2025AY 2021-22

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

Section 144C(5)Section 920

income at Rs.39,95,80,674/= and demanded tax thereon. 3. Aggrieved against the Final Assessment order the assessee is in appeal before us raising the following Grounds of Appeal : I.T.A No. 1854/Ahd/2024 A.Y. 2021-22 Page No 3 Asandas & Sons Pvt. Ltd. Vs. DCIT Ground No. 1-Upward transfer pricing adjustment

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

ITA 322/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

business premises of the assessee was also covered. Consequently, in response to 153A notice, the assessee filed its Return of Income as admitted in the original return. Since there were Transfer Pricing

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

ITA 324/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2019-20

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

business premises of the assessee was also covered. Consequently, in response to 153A notice, the assessee filed its Return of Income as admitted in the original return. Since there were Transfer Pricing

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

ITA 319/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2014-15

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

business premises of the assessee was also covered. Consequently, in response to 153A notice, the assessee filed its Return of Income as admitted in the original return. Since there were Transfer Pricing

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

ITA 321/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Jan 2025AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 132Section 143Section 143(3)Section 271ASection 92CSection 92D

business premises of the assessee was also covered. Consequently, in response to 153A notice, the assessee filed its Return of Income as admitted in the original return. Since there were Transfer Pricing