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)

section 92C, the arm's length price in relation to an international transaction or a specified domestic transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:- comparable uncontrolled price method, by which,- (i) the price charged or paid for property transferred or services provided in a comparable uncontrolled transaction

SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

transfer pricing adjustments can be levied only if it is proven that the\nprice charged was not determined in accordance with section 92C of the\nAct and not done in good faith and with due diligence. In this case, the AO\nfailed to make any reference to Explanation 7 in the penalty order or record\nany findings suggesting non-compliance

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 proceedings. In the present case, the TPO has not initiated any such penalty but the Assessing Officer has initiated the penalty as well as levied the penalty without bringing on record I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 6 Priya Blue Industries Pvt. Ltd. vs. DCIT material information which can justify such

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)

transfer pricing proceedings. In the present case, the TPO has not initiated any such penalty but the Assessing Officer has initiated the penalty as well as levied the penalty without bringing on record I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 6 Priya Blue Industries Pvt. Ltd. vs. DCIT material information which can justify such

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 proceedings. In the present case, the TPO has not initiated any such penalty but the Assessing Officer has initiated the penalty as well as levied the penalty without bringing on record I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 6 Priya Blue Industries Pvt. Ltd. vs. DCIT material information which can justify such

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 proceedings. In the present case, the TPO has not initiated any such penalty but the Assessing Officer has initiated the penalty as well as levied the penalty without bringing on record I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 6 Priya Blue Industries Pvt. Ltd. vs. DCIT material information which can justify such

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 proceedings. In the present case, the TPO has not initiated any such penalty but the Assessing Officer has initiated the penalty as well as levied the penalty without bringing on record I.T.A Nos. 317 to 324/Ahd/2024 A.Ys. 2012-13 to 2019-20 Page No 6 Priya Blue Industries Pvt. Ltd. vs. DCIT material information which can justify such

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary information. During the course of assessment proceedings, the Assessing Officer made a reference under section 92CA(1) to the Transfer Pricing

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2015-16 Acit, Cir.2(1)(1) M/S.Intas Pharmaceuticals Ltd Vejalpur Vs Corporate House Ahmedabad. S.G. Highway Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L Asstt.Year : 2015-16 M/S.Intas Pharmaceuticals Ltd Acit, Cir.2(1)(1) Corporate House Vs Vejalpur S.G. Highway Ahmedabad. Nr.Sola Bridge, Thaltej Ahmedabad 380 054. Pan : Aaaci 5120 L (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocae & Shri Parin Shah, Ar : Shri Ragnesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 28/04/2025 घोषणा क" तारीख /Date Of Pronouncement: 21/05/2025 आदेश आदेश/O R D E R आदेश आदेश

142(1) along with detailed questionnaires were issued from time to time, to which the assessee filed replies and furnished necessary information. During the course of assessment proceedings, the Assessing Officer made a reference under section 92CA(1) to the Transfer Pricing

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\nproceedings. In the present case, the TPO has not initiated any\nsuch penalty but the Assessing Officer has initiated the penalty\nas well as levied the penalty without bringing on record\nmaterial information which can justify such penalty. Even on\nperusal of penalty under Section 271AA of the Act, the AO himself\nhas mentioned that appellant has reported

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\nproceedings. In the present case, the TPO has not initiated any\nsuch penalty but the Assessing Officer has initiated the penalty\nas well as levied the penalty without bringing on record\n\nmaterial information which can justify such penalty. Even on\nperusal of penalty under Section 271AA of the Act, the AO himself\nhas mentioned that appellant

MILACRON INDIA PRIVATE LIMITED,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2021-22 Milacron India Pvt.Ltd. The Dcit, Cir.2(1)(1) Plot No.93/2 & 91/4 Vs Ahmedabad. Phase-1,Gidc Vatva, Ahmedabad. Pan : Aabcc 0881 D

Transfer Pricing Officer (TPO) for determination of the Arm’s Length Price (ALP) of the international transactions reported in Form 3CEB. The TPO, vide order dated 18.10.2023 passed under section 92CA(3), proposed an upward adjustment of Rs.23,22,513/- to the total income of the assessee in respect of notional interest on outstanding receivables from Associated Enterprises (AEs) amounting

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

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

142(1) were issued from time to time and various details were furnished on different dates. 2.2 The case was referred to the Transfer Pricing Officer [hereinafter referred to as “TPO”] for determination of the arm’s length price of the international transactions. The TPO, by order under section

PRIYA BLUE INDUSTRIES PVT.LTD.,BHAVNAGAR vs. THE DY.CIT., CENTRAL CIRCLE-1(1),, AHMEDABAD

In the result, appeal filed by the assessee is allowed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

142(1) of the Act was issued on 26.09.2021 wherein the assessee was requested to furnish Assessment Year-wise purchases from Best Oasis Limited which is a non-resident of India for A.Y. 2012-13 to 2019-20. In response to the same, the assessee filed reply vide letter dated 27.09.2021. M/s. Best Oasis Limited is a foreign company

SKAPS INDUSTRIES INDIA PVT. LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

price band provided in Section 92C of the Aet and accordingly there is no question of additions in ALP of international transaction. 10. Both lower authorities ought to have allowed deduction u/s.10B of the Act after adjustment of addition/disallowance made as per CBDT Circular No.37 of 2016. 11. Appellant craves leave to add, alter, amend or delete

HANNING MOTORS INDIA PRIVATE LIMITED,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

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

Transfer Pricing Officer [hereinafter referred to as “TPO"] under Section\n92CA of the Act.\nFacts of the Case:\n2. The assessee is engaged in the manufacture and sale of synchronous\ndrain pumps used in washing machines and dishwashers. The assessee filed\nits return of income on 28.11.2017, declaring a business loss of\nRs.21,48,541/-. The case was selected

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

142(1) were issued by the Assessing Officer to the assessee. Assessee is a joint venture entity between M/s. B.G. Shirke Construction and Technology Pvt. Ltd. and M/s. M.S. Khurana Engineering Ltd., industrial undertaking engaged in development, operation and maintenance of infrastructure facility. Assessee is an AOP. Under the consortium Agreement, M/s. B.G. Shirke Construction Technology

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

142(1) were issued by the Assessing Officer to the assessee. Assessee is a joint venture entity between M/s. B.G. Shirke Construction and Technology Pvt. Ltd. and M/s. M.S. Khurana Engineering Ltd., industrial undertaking engaged in development, operation and maintenance of infrastructure facility. Assessee is an AOP. Under the consortium Agreement, M/s. B.G. Shirke Construction Technology