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)

Transfer Pricing Report. In part-5 of its report Id. TPO referred that "in view of the fact that these replica transactions of Cadbury India Ltd., where ALP is determined of these very transaction. As such the ALP determined by assessee is not being disturbed. Further, we have seen that assessee filed Form 3CEB, Royally Agreements entered into with

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)

Transfer Pricing Report. In part-5 of its report Id. TPO referred that "in view of the fact that these replica transactions of Cadbury India Ltd., where ALP is determined of these very transaction. As such the ALP determined by assessee is not being disturbed. Further, we have seen that assessee filed Form 3CEB, Royally Agreements entered into with

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)

Transfer Pricing Report. In part-5 of its report Id. TPO referred that "in view of the fact that these replica transactions of Cadbury India Ltd., where ALP is determined of these very transaction. As such the ALP determined by assessee is not being disturbed. Further, we have seen that assessee filed Form 3CEB, Royally Agreements entered into with

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\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing\nReport. In part-5 of its report Id. TPO referred that \"in view of\nthe fact that these replica transactions of Cadbury India Ltd.,\nwhere ALP is determined of these very transaction. As such the\nALP determined by assessee is not being disturbed. Further, we\nhave seen that assessee filed Form 3CEB, Royally Agreements\nentered into with

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\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing\nReport. In part-5 of its report Id. TPO referred that \"in view of\nthe fact that these replica transactions of Cadbury India Ltd.,\nwhere ALP is determined of these very transaction. As such the\nALP determined by assessee is not being disturbed. Further, we\nhave seen that assessee filed Form 3CEB, Royally Agreements\nentered into with

ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

transferred from Jurisdictional A.O. to Central Circle without obtaining the consent of the assessee U/s. 127 of the Act. Therefore, the order of A.O. is without Jurisdiction. 2. Learned CIT(A) has erred in confirming the proceedings of A.O. in re- opening the assessment U/s. 147. Though the assessment is based on incriminating material found during Search at Robin Goenka

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

transferred from Jurisdictional A.O. to Central Circle without obtaining the consent of the assessee U/s. 127 of the Act. Therefore, the order of A.O. is without Jurisdiction. 2. Learned CIT(A) has erred in confirming the proceedings of A.O. in re- opening the assessment U/s. 147. Though the assessment is based on incriminating material found during Search at Robin Goenka

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

transferred from Jurisdictional A.O. to Central Circle without obtaining the consent of the assessee U/s. 127 of the Act. Therefore, the order of A.O. is without Jurisdiction. 2. Learned CIT(A) has erred in confirming the proceedings of A.O. in re- opening the assessment U/s. 147. Though the assessment is based on incriminating material found during Search at Robin Goenka

ASSTT. COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(2), AHMEDABAD, AHMEDABAD vs. SAI KRUPA DEVELOPERS, AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

transferred from Jurisdictional A.O. to Central Circle without obtaining the consent of the assessee U/s. 127 of the Act. Therefore, the order of A.O. is without Jurisdiction. 2. Learned CIT(A) has erred in confirming the proceedings of A.O. in re- opening the assessment U/s. 147. Though the assessment is based on incriminating material found during Search at Robin Goenka

SAI KRUPA DEVELOPERS,AHMEDABAD vs. THE ACIT, CEN. CIR.1(2), AHMEDABAD

In the result, this ground of appeal 1 to 4 of the Department is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

transferred from Jurisdictional A.O. to Central Circle without obtaining the consent of the assessee U/s. 127 of the Act. Therefore, the order of A.O. is without Jurisdiction. 2. Learned CIT(A) has erred in confirming the proceedings of A.O. in re- opening the assessment U/s. 147. Though the assessment is based on incriminating material found during Search at Robin Goenka

M/S. SHRI RANG INFRASTRUCTURE PVT. LTD.,,GANDHINAGAR vs. DCIT, GANDHINAGAR CIRCLE, GANDHINAGAR

In the result, appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2013-14

price to the land owner in future. The Assessing Officer further observed that while computing the capital gain, the assessee also claimed to have paid Rs.4,11,00,000/- to Kalpesh K. Patel as the confirming party. The assessee was called upon the details vide notice dated 16.03.2016 and the assessee replied vide submissions dated 21.03.2016. The sale deed dated

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

127 ITR 513, 515 (MP); All India Lakshmi Commercial Bank Officers Union v. Union of India [1984] 150 ITR 1 (Delhi); CIT v. Ceanattu Firms [1986] 160 ITR 588, 591 (Ker.). Another aspect which is incidental to the proposition that if there is no exempt income earned, there can be no disallowance u/s.14A of the Act, is the revenue

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

127 ITR 513, 515 (MP); All India Lakshmi Commercial Bank Officers Union v. Union of India [1984] 150 ITR 1 (Delhi); CIT v. Ceanattu Firms [1986] 160 ITR 588, 591 (Ker.). Another aspect which is incidental to the proposition that if there is no exempt income earned, there can be no disallowance u/s.14A of the Act, is the revenue

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

127 ITR 513, 515 (MP); All India Lakshmi Commercial Bank Officers Union v. Union of India [1984] 150 ITR 1 (Delhi); CIT v. Ceanattu Firms [1986] 160 ITR 588, 591 (Ker.). Another aspect which is incidental to the proposition that if there is no exempt income earned, there can be no disallowance u/s.14A of the Act, is the revenue

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

127 ITR 513, 515 (MP); All India Lakshmi Commercial Bank Officers Union v. Union of India [1984] 150 ITR 1 (Delhi); CIT v. Ceanattu Firms [1986] 160 ITR 588, 591 (Ker.). Another aspect which is incidental to the proposition that if there is no exempt income earned, there can be no disallowance u/s.14A of the Act, is the revenue

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

Transfer Pricing Officer for determining Arms’ Length Price of the International Transaction undertaken by the assessee company and the TPO accepted the price at which International Transaction were recorded and no adverse inference was drawn by passing order dated 28-10-2019 under section 92CA(3) of the Act. Following the same, the Ld AO accepted the returned income filed

DR. SHRUTI RAMRAO SHUJOLE, DCIT CENTRAL CIRCLE-1(2), AHMEDABAD, AAYKAR BHAWAN ASHRAM ROAD AHMEDABAD vs. GSG ABODE LLP, NAVRANGPURA AHMEDABAD

127 of the Act was not issued to the appellant.\"\n3.1. The ground of appeal taken by the Revenue in the case of GSG Abode\nLLP in ITA No.665/Ahd/2024 for AY 2020-21 is reproduced as under:\n\"Whether, in the facts and on the circumstances of the case and in law, the Ld.\nCIT(A) is correct in deleting

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

In the result, the appeal filed by the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

127/- and additions made during the year to the tune of Rs.12,10,443/-. What transpires from the fact therefore is that the majority depreciation claimed by the assessee on office equipments at the rate of 15% related to the opening value of the block of asset coming over from past years, when these assets were acquired