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

In the result, both the M

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

transfer of land or plots but it was not the case that the profits so generated were not within the main provisions of section 11 of the IT Act, (emphasis supplied) Even the assessee has earned premium price

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

In the result, both the M

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

transfer of land or plots but it was not the case that the profits so generated were not within the main provisions of section 11 of the IT Act, (emphasis supplied) Even the assessee has earned premium price

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

In the result, both the M

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

transfer of land or plots but it was not the case that the profits so generated were not within the main provisions of section 11 of the IT Act, (emphasis supplied) Even the assessee has earned premium price

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

In the result, both the M

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

transfer of land or plots but it was not the case that the profits so generated were not within the main provisions of section 11 of the IT Act, (emphasis supplied) Even the assessee has earned premium price

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)

11 DCIT vs. Netafim Irrigation India Pvt. Ltd. settled by the Hon'ble Jurisdictional High Court as well as different Benches of the Tribunal that the Transfer Pricing Officer is duty bound to determine the arm's length price of international transaction by applying any one of the prescribed methods. This principle has been propounded by the Hon'ble Jurisdictional

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)

11 DCIT vs. Netafim Irrigation India Pvt. Ltd. settled by the Hon'ble Jurisdictional High Court as well as different Benches of the Tribunal that the Transfer Pricing Officer is duty bound to determine the arm's length price of international transaction by applying any one of the prescribed methods. This principle has been propounded by the Hon'ble Jurisdictional

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

11 and 12 of the Act as claimed by the\nassessee.\n\n3.\nAggrieved with the order of the Assessing Officer, the assessee had\nfiled an appeal before the First Appellate Authority which was decided by\nthe Ld. CIT(A) vide the impugned order and the appeal of the assessee\nwas partly allowed.\n\n4.\nNow, both the Revenue

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)

11. Ground Nos. 3 & 4 - Penalty Proceedings: As the transfer pricing adjustment is deleted, the penalty proceedings under section 270A

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

11 and 12 of the Act as claimed by the\nassessee.\n\n3. Aggrieved with the order of the Assessing Officer, the assessee had\nfiled an appeal before the First Appellate Authority which was decided by\nthe Ld. CIT(A) vide the impugned order and the appeal of the assessee\nwas partly allowed.\n\n4. Now, both the Revenue

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

price was offered to every seller (more than 500) which has not been disputed in any other case. In particular, in the case of Shri Pratul K. Shroff (PAN ACEPS6613J), the trustee of the appellant trust, who also transferred his personal holding of 1,20,26,804 number of equity shares of “e-Infochips Ltd.” and realized Rs.809

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)

section 92C of the Act. Consequently, no transfer pricing adjustment survives. 9. In the result, the addition of Rs. 3,94,09,319/- made on account of transfer pricing adjustment is directed to be deleted. I.T.A No. 359/Ahd/2022 A.Y. 2018-19 14 M/s. Altera Digital Health (India) LLP (Formerly known as Allscripts (India) LLP) vs. DCIT 10. The appeal

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:

Section 9 of the IT Act row. Article 9 of the India-China DTAA, the PE should have been adequately compensated for such activities in accordance with the transfer pricing provisions contained in the Chapter-X of the IT Act. In this context, various bid related documents submitted by the assessee were perused. From the perusal of such documents

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

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

section 271(1)(c) was levied\nvide order dated 25.03.2015. In relation to the Transfer Pricing adjustment,\nthe assessee had entered into international transactions with associated\nenterprises amounting to Rs. 1,61,33,11