THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. ABHILASHA PHARMA PVT. LTD., AHMEDABAD

In the result, the appeal filed by the Revenue is hereby dismissed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year : 2015-16 Abhilasha Pharma Pvt Ltd., The Dcit, Vs 11, Chaudhari Co-Op. Circle 1(1)(1), Housing Society Ltd., Ahmedabad Paldigam, Paldi, Ahmedabad-380007 Pan : Aafca 5539 E अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar Revenue By : Dr. Darsi Sumar Ratnam, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 02/05/2024 घोषणा क" तारीख /Date Of Pronouncement : 10/05/2024 आदेश/O R D E R आदेश आदेश आदेश Per T.R. Senthil Kumar:

transfer of goods or services referred to in section 80- 1A(8): (3) any business transacted between the assessee and other person as referred to in section 80-1A(10); (4) any transaction, referred to in any other section under Chapter VI-A or section 10AA, to which section 80-1A(8) or section

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

In the result, both the appeals filed by the Assessee as well as Revenue are partly allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2012-13

price and hence it takes into account the impact of outstanding trade receivable on profitability. (e) That in the facts and circumstances of the case and in law, the learned CIT(A) wholly erred while confirming upward adjustment carried out by AO/TPO by re-characterization of outstanding trade receivables as unsecured loans advanced by the appellant company

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

In the result, both the appeals filed by the Assessee as well as Revenue are partly allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2012-13

price and hence it takes into account the impact of outstanding trade receivable on profitability. (e) That in the facts and circumstances of the case and in law, the learned CIT(A) wholly erred while confirming upward adjustment carried out by AO/TPO by re-characterization of outstanding trade receivables as unsecured loans advanced by the appellant company

THE ACIT, ANAND CIRCLE,, ANAND vs. M/S. CHHOTABHAI JETHABHAI PATEL & CO.,, KHEDA

In the result, the appeal of the revenue is dismissed

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

transfer pricing is concerned with determination of Arms Length Price of the specified domestic transaction carried out by the assessee. 6. The ld. Authorized Representative submitted that the specified domestic transaction was omitted from the statute w.e.f. 01-04-2017 and therefore the CIT(A) has rightly deleted the said addition towards upward adjustment referred

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

transfer pricing on account of capital account transaction being the acquisition of shares. Merely, there was a delay in the allotment of shares by the AE to the assessee, such delay cannot change the character of the transaction as loan. We note that the Delhi bench of ITAT in the case of Bharti Airtel Limited vs. ACIT reported

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

114/- on the advances of Rs.92,615 on the ground that the assessee has not proved the business expediency of giving such advances to staff members and suppliers. Ld Counsel submitted that the AO made notional interest at 12% on the advance of Rs.92,615/=. Breakup of this amount is in Balance sheet at page 16 of the Paper Book

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

114/- on the advances of Rs.92,615 on the ground that the assessee has not proved the business expediency of giving such advances to staff members and suppliers. Ld Counsel submitted that the AO made notional interest at 12% on the advance of Rs.92,615/=. Breakup of this amount is in Balance sheet at page 16 of the Paper Book

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

114/- on the advances of Rs.92,615 on the ground that the assessee has not proved the business expediency of giving such advances to staff members and suppliers. Ld Counsel submitted that the AO made notional interest at 12% on the advance of Rs.92,615/=. Breakup of this amount is in Balance sheet at page 16 of the Paper Book

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

114/- on the advances of Rs.92,615 on the ground that the assessee has not proved the business expediency of giving such advances to staff members and suppliers. Ld Counsel submitted that the AO made notional interest at 12% on the advance of Rs.92,615/=. Breakup of this amount is in Balance sheet at page 16 of the Paper Book

SMT. RITABEN SAKETKUMAR TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

114/- on the advances of Rs.92,615 on the ground that the assessee has not proved the business expediency of giving such advances to staff members and suppliers. Ld Counsel submitted that the AO made notional interest at 12% on the advance of Rs.92,615/=. Breakup of this amount is in Balance sheet at page 16 of the Paper Book