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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G and\n271BA on ground that assessee had not maintained prescribed TP\ndocumentation and did not furnish information requisitioned by TPO\nOn basis of recommendation

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 officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G and\n271BA on ground that assessee had not maintained prescribed TP\ndocumentation and did not furnish information requisitioned by TPO\nOn basis of recommendation

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

transfer pricing study, and the AO’s reliance on product-level comparability under CPM was erroneous. Accordingly, ground numbers 1 to 4 of the Revenue are dismissed. Ground No.5 of the Revenue relating to addition made in the book profit u/s 115JB of the Act on account of disallowance u/s 14A of the Act r.w. Rule

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

Transfer Pricing Officer (TPO) has erred in law and on facts in exceeding the jurisdiction by passing the TP Order under Section 92CA(3) of the Income-tax Act, 1961 (the Act) beyond the mandatorily prescribed time limit as per Section 92CA(3A) read with Section 153(4) of the Act, thereby making the TP Order barred by limitation

DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ATUL LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2016-17

transfer pricing study report and such other documents as were required together with detail submission to justify the Arm's Length Price computed in respect of the international transactions. Therefore, sufficient accomplice were made with respect to notice uls.92D(3) of the IT Act. The other reasons mentioned by the Ld. TPO are general in nature and did not point

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

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

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

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

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

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

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

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

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

139, section 147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,— (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other

THE MODERN CONSTRUCTION CO. PVT. LTD.,AHMEDABAD vs. ITO, WARD-2(1)(4), AHMEDABAD

The appeal of the assessee is allowed for statistical\npurposes

139\nsection 147 section 148, section 149, section 151 and section 153,\nwhere the Assess Officer is satisfied that any money, bullion,\njewellery or other valuable article thing or books of account or\ndocuments seized or requisitioned belongs belong to a person other\nthan the person referred to in section 153A, then the books of account\nor documents or assets

THE UNITED BUILDERS CORPORATION ,,AHMEDABAD vs. DY.CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

The appeal of the assessee is allowed for statistical\npurposes

139\nsection 147 section 148, section 149, section 151 and section 153,\nwhere the Assess Officer is satisfied that any money, bullion,\njewellery or other valuable article thing or books of account or\ndocuments seized or requisitioned belongs belong to a person other\nthan the person referred to in section 153A, then the books of account\nor documents or assets

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD, HYDERABAD vs. MYTRAH VAYU (GUJARAT) PRIVATE LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

transfer pricing as per provisions of Section 92BA r.w.s. 40A(2)(b) of the Act. However, he stated that out of abundant caution, the assessee had reported the transaction in Form 3CEB. It was also contended that the assessee was eligible for claiming benefit of deduction of profits under 80IA of the Act though it had not claimed any benefit

LESSO BUILDTECH PRIVATE LIMITED,GURGAON vs. THE DY.CIT, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal filed by the Assessee is partly allowed

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Transfer Pricing upward adjustment of Rs.43,29,60,041/-. Thereafter the Assessing Officer passed draft assessment order u/s. 144C(1) vide order dated 18-09-2023 determining the income at Rs.14,38,41,948/- as follows: Sr. No. Description Amount (in Rs.) 1 Total loss as per Return of Income filed u/s. (-) 30,65,00,117/- 139

PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

139 of the Act, this fact is treated as the appellant has reported nil income. Meaning thereby, the appellant has misreported her income by concealing taxable income for which Id. AO had rightly initiated penalty proceedings and passed the penalty order. Thus, in view of the facts of the case, I am of the considered opinion that the appellant