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)

Transfer Pricing Officer has to determine the arm's length price of an international transaction by applying a prescribed method. Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys

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)

Transfer Pricing Officer has to determine the arm's length price of an international transaction by applying a prescribed method. Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys

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)

transfer pricing adjustment is deleted, the penalty proceedings under section 270A and 271AA become infructuous and unsustainable. 12. In light

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

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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

12. From the above, it is clear that lending or borrowing money between two associated enterprises comes within the ambit of international transaction and whether the same is at arm’s length price has to be considered. The question of rate interest on the borrowing loan is an integral part of arm’s length price of determination in this context

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:

12 – 17. Ground Nos. 1, 2 & 3, it was common ground pertained to the challenge raised by the assessee to the invocation of transfer pricing provision in the present case as provided in chapter X of the Income Tax Act. The said grounds read as under: “1. The order passed by the learned Deputy Commissioner of Income Tat International Taxation

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

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 as well

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

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 as well

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

12 of the Act as claimed by the assessee. 3. Aggrieved with the order of the Assessing Officer, the assessee had filed an appeal before the First Appellate Authority which was decided by the Ld. CIT(A) vide the impugned order and the appeal of the assessee was partly allowed. 4. Now, both the Revenue as well as the assessee

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)

12,90,414/- and AO has levied penalty under Section 271AA of the Act for Rs.5,36,25,808/- on these purchase transactions on the ground that appellant has failed to maintain the documents specified in Section 92D r.w.r. 10D. Similar penalty has been levied for all the remaining years. The appellant has raised similar line of arguments which

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)

12,90,414/- and AO has levied penalty under Section 271AA of the Act for Rs.5,36,25,808/- on these purchase transactions on the ground that appellant has failed to maintain the documents specified in Section 92D r.w.r. 10D. Similar penalty has been levied for all the remaining years. The appellant has raised similar line of arguments which

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)

12,90,414/- and AO has levied penalty under Section 271AA of the Act for Rs.5,36,25,808/- on these purchase transactions on the ground that appellant has failed to maintain the documents specified in Section 92D r.w.r. 10D. Similar penalty has been levied for all the remaining years. The appellant has raised similar line of arguments which

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)

12,90,414/- and AO has levied penalty under Section 271AA of the Act for Rs.5,36,25,808/- on these purchase transactions on the ground that appellant has failed to maintain the documents specified in Section 92D r.w.r. 10D. Similar penalty has been levied for all the remaining years. The appellant has raised similar line of arguments which

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)

12,90,414/- and AO has levied penalty under Section 271AA of the Act for Rs.5,36,25,808/- on these purchase transactions on the ground that appellant has failed to maintain the documents specified in Section 92D r.w.r. 10D. Similar penalty has been levied for all the remaining years. The appellant has raised similar line of arguments which