BharatTax.net
SearchITATHigh CourtsSupreme CourtAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

87 results for “transfer pricing”+ Section 133(6)clear

Sorted by relevance

Mumbai562Delhi397Bangalore105Ahmedabad87Jaipur77Chennai72Cochin61Hyderabad55Indore44Kolkata43Surat39Chandigarh33Raipur30Pune27Rajkot22Agra19Guwahati19Visakhapatnam16Nagpur13Cuttack9Lucknow7Amritsar4Jodhpur4Dehradun1Varanasi1

Key Topics

Section 143(3)65Addition to Income63Disallowance47Section 3736Section 6830Section 14727Section 153A26Section 132(4)23Section 250

HARSHADKUMAR HARGOVANDAS PATEL,KALOL vs. THE ITO, WARD-4, MEHSANA

In the result, the appeal of the assessee is allowed for statistical\npurposes

ITA 125/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad15 Oct 2025AY 2013-14
For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri Abhijit, Sr. D.R
Section 143Section 143(3)Section 148Section 55A

133(6) nor\nany summons under section 131 was issued to cross-verify the transaction.\nInstead, the Assessing Officer disallowed the expenditure merely on the basis\nof conjecture and surmise. The Counsel submitted that both the Assessing\nOfficer and the CIT(A) failed to appreciate that the expenditure was\nsupported by records and confirmations and that the disallowance made

BUNDY INDIA LIMITED,,VADODARA vs. THE DY. CIT., CIRCLE-1(1),, BARODA

Showing 1–20 of 87 · Page 1 of 5

21
Penalty18
Section 271(1)(c)15
Survey u/s 133A15

In the result, Ground Number 6 of the assessee’s appeal is allowed for statistical purposes

ITA 1403/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2009-10

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1403/Ahd/2016 िनधा"रण वष" /Assessment Year : 2009-10 Bundy India Limited The Dy.Cit बनाम/ Plot No.2, Circle-1(1) V/S. Gidc Industrial Estate, Baroda Makarpura Vadodaria - 390 010 "थायी लेखा सं./Pan: Aaacb 3039 M (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shree Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shree Veerbadram Vislavath, Sr.DR
Section 133(6)Section 250Section 92CSection 92C(1)Section 92C(3)

transfer pricing adjustments sustained by the lower authorities aggregating to Rs. 1,77,85,368/- were unwarranted since the preconditions Bundy India Ltd. vs. DCIT Asst. Year : 2009-10 for invoking section 92C(3) read with section 92CA(3) of the Act were not satisfied, and the authorities below erred in law in making the adjustments without properly establishing that

THE ACIT, CIRCLE-4(1)(1), AHMEDABAD vs. M/S. SHELL ENERGY INDIA PVT. LTD. (FORMERLY KNOWN AS M/S. HAZIRA LNG. PVT. LTD.), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

ITA 558/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri (Dr.) Darsi Suman Ratnam, CIT-DR
Section 143(3)Section 144CSection 250Section 92D

Transfer Pricing Officer (TPO)/Assessing Officer(AO), being Rs.5,76,79,229/-.And the same stood confirmed by the ld.CIT(A). The ld.counsel for the assessee contended that vide Ground no.4 and 5 several aspects relating to the adjustment so made to the international transactions have been raised by the assessee. In ground no.4, he pointed out, the adjustment

SHELL ENERGY INDIA PRIVATE LIMITED,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

ITA 435/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad17 Oct 2024AY 2012-13

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri (Dr.) Darsi Suman Ratnam, CIT-DR
Section 143(3)Section 144CSection 250Section 92D

Transfer Pricing Officer (TPO)/Assessing Officer(AO), being Rs.5,76,79,229/-.And the same stood confirmed by the ld.CIT(A). The ld.counsel for the assessee contended that vide Ground no.4 and 5 several aspects relating to the adjustment so made to the international transactions have been raised by the assessee. In ground no.4, he pointed out, the adjustment

THE DCIT, CENTRAL CIRCLE-1(4), AHMEDABAD vs. M/S. AWAS DEVELOPERS, AHMEDABAD

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

ITA 368/AHD/2020[2010-11]Status: DisposedITAT Ahmedabad13 Mar 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Tr Senthil Kumarआयकरअपीलसं./Ita No. 368/Ahd/2020 धििाधरणवरध/Asstt. Year: 2010-2011 The D.C.I.T, M/S Awas Developers, Central Circle-1(4), Vs. “Agam Buglows” Ahmedabad. Opp. Subhash Society, Sanand-Kalol Road, Ahmedabad.

For Appellant: Shri Aseem L Thakkar, ARFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 184Section 40ASection 68

price of the residential bungalow is Rs.21.50lacs as against which Rs.30.50lacs has been recovered from the client. The difference of Rs.9,00,000/- is the unaccounted receipt members each bungalow. Since there are 40 bungalows in the aforesaid scheme there is an undisclosed income of to the extent of Rs.3.60 lacs. The AO has also placed reliance on the statement

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. SANJAY PRATAPRAI MEHTA, BHAVNAGAR

In the result, appeal of the Department is dismissed

ITA 897/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad24 Apr 2024AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Sudhendu Das, CIT DRFor Respondent: Shri Tushar P Hemani, Sr. Advocate & Shri
Section 10(38)Section 271(1)(c)

133(6)/131 of the Act were issued to M/s Gold Line International Finvest Limited, but nothing emerged from this effort. The payment for the shares in question was made by Sh. Salasar Trading Company. Notice was issued to this entity as well, but when the notices were returned unserved, the AO did not take the matter any further

SWASTIK DEVELOPERS,AHMEDABAD vs. THE INCOME TAX OFFICER WARD 3(3)(5), AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 955/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Aug 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2017-2018 Swastik Developers The Ito, Ward-3(3)(5), 21, Swastik House Vs. Ahmedabad. B/H.Sardar Patel Stadium Ahmedabad. Pan : Acyfs 0641 R (Applicant) (Responent) : Shri Prashant Shrivastav, Ar Assessee By : Shri Hargovind Singh, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 06/08/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/08/2025

For Appellant: Shri Hargovind Singh, Sr.DR
Section 144BSection 147Section 148Section 148ASection 250Section 68Section 69

transferring the money to the firm. The partners’ returned incomes were 4 found to be disproportionately low vis-à-vis the capital introduced. The AO held that in the absence of satisfactory explanation, the investment of Rs.2,91,23,300/- remained unexplained under section 69, and the capital of Rs.1,37,40,714/- introduced by the remaining ten partners (except

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

In the result, appeal of the assessee is partly allowed

ITA 666/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad30 Jul 2024AY 2013-14

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

Section 129Section 142(1)Section 143(1)Section 143(2)Section 44A

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

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

ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Officer (Ld TPO) under the directions of Honourable Dispute Resolution Panel (Hon’ble DRP), erred in making an upward adjustment of Rs 2.22 61.539/- in relation to the international transaction of payment of Infrastructure Consultancy and support charges to Associated Enterprise (AE) The Appellant prays that the addition made by the Ld AO TPO in relation

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

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

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Officer (Ld TPO) under the directions of Honourable Dispute Resolution Panel (Hon’ble DRP), erred in making an upward adjustment of Rs 2.22 61.539/- in relation to the international transaction of payment of Infrastructure Consultancy and support charges to Associated Enterprise (AE) The Appellant prays that the addition made by the Ld AO TPO in relation

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2,, BHARUCH vs. M/S. HEUBACH COLOUR PVT. LTD.,, ANKLESHWAR

In the result, the appeal of the Revenue for assessment year 2010-11 is partly allowed for statistical purposes as indicated above

ITA 110/SRT/2017[2010-11]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2010-11

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

For Appellant: Sh. Milin Mehta, ARFor Respondent: Sh. Atul Pandey, Sr. D.R
Section 143(3)

133(6). The AO asked the assessee to submit documentary evidences to prove the services being actually rendered in lieu of sales commissions payment and benefit derived from it by the assessee. In response, the assessee provided the copy of agreement with both the parties Heubach GMBH and Darlington Enterprises Ltd and vouchers. The AO observed that the agreement gave

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2,, BHARUCH vs. M/S. HEUBACH COLOUR PVT. LTD.,, ANKLESHWAR

In the result, the appeal of the Revenue for assessment year 2010-11 is partly allowed for statistical purposes as indicated above

ITA 3367/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad10 Apr 2024AY 2009-10

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

For Appellant: Sh. Milin Mehta, ARFor Respondent: Sh. Atul Pandey, Sr. D.R
Section 143(3)

133(6). The AO asked the assessee to submit documentary evidences to prove the services being actually rendered in lieu of sales commissions payment and benefit derived from it by the assessee. In response, the assessee provided the copy of agreement with both the parties Heubach GMBH and Darlington Enterprises Ltd and vouchers. The AO observed that the agreement gave

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

In the result, appeal of the assessee is partly allowed

ITA 769/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2025AY 2015-16

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

Section 11Section 12ASection 143(3)Section 147Section 68

133(6) of the Act and it transpired that the source of fund for purchase of shares was capital infusion from its shareholder Components Agent Asia Holding Limited, Mauritius. The Assessing Officer also noticed that Arrow had filed its audit report only after initiation of enquiry proceedings in the case of the assessee. Considering the fact that there

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 136/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 148/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 134/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 149/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 135/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 147/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 133/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe