INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

1(ii) - Transfer Pricing Adjustment on Notional Interest on Outstanding Receivables from AEs – Rs.14,64,47,827/-. 9. The next issue arising for our consideration pertains to the transfer pricing adjustment made by imputing notional interest on delayed realization of export proceeds from AEs, resulting in an addition of Rs.14,64,47,827/-. 10. During the year under consideration

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

1(ii) - Transfer Pricing Adjustment on Notional Interest on Outstanding Receivables from AEs – Rs.14,64,47,827/-. 9. The next issue arising for our consideration pertains to the transfer pricing adjustment made by imputing notional interest on delayed realization of export proceeds from AEs, resulting in an addition of Rs.14,64,47,827/-. 10. During the year under consideration

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

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

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 on lease of plot and land for sale but if the entire expenditure and the profit earned there from was exclusively used

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 on lease of plot and land for sale but if the entire expenditure and the profit earned there from was exclusively used

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 on lease of plot and land for sale but if the entire expenditure and the profit earned there from was exclusively used

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 on lease of plot and land for sale but if the entire expenditure and the profit earned there from was exclusively used

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

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

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

11. We have heard the rival contentions and perused the material on record. We observe that during the course of assessment, the Assessing Officer has dealt with the contents of the seized documents relating to undisclosed consideration on the sale of land amounting to Rs. 1,89,43,840/- and has observed that the relevant seized material (Annexure