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

143(2) of the Act was duly issued. Subsequently, notices under section 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

143(2) of the Act was duly issued. Subsequently, notices under section 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

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

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

143(3) read with section 144C(3)\nof the Income Tax Act, 1961 (Act), was finalized on 29.05.2013,\ndetermining the assessed loss at Rs. (-)2,00,59,396/-. The assessee is\nengaged in manufacturing and trading in needle roller bearings and engine\ncomponents. During the course of assessment proceedings, two main\ndisallowances were made in the assessment order: a Transfer

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)

1), India Pvt. Ltd. Vadodara Vs Plot No. 268, 270, 271 B, GIDC, Manjusar, Savli, Vadodara, Gujarat 391775. (Appellant) PAN: AAACE4738J Revenue Represented: Shri Kamlesh Makwana, CIT-DR Assessee Represented: Shri Dhinal Shah, A.R. Date of hearing : 09-02-2026 Date of pronouncement : 24-02-2026 आदेश/ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER These two appeals are filed

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)

1), India Pvt. Ltd. Vadodara Vs Plot No. 268, 270, 271 B, GIDC, Manjusar, Savli, Vadodara, Gujarat 391775. (Appellant) PAN: AAACE4738J Revenue Represented: Shri Kamlesh Makwana, CIT-DR Assessee Represented: Shri Dhinal Shah, A.R. Date of hearing : 09-02-2026 Date of pronouncement : 24-02-2026 आदेश/ORDER PER: T.R. SENTHIL KUMAR, JUDICIAL MEMBER These two appeals are filed

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2017-18 Atul Limited Acit, Cir.1(1)(1) Atul House, Gi Patel Mark Vs Ahmedabad. Mithila Society, Ahmedabad. Pan : Aabca 2390 M (Applicant) (Responent) Assessee By : Shri Bandish Soparkar, Ar : Shri Prathvi Raj Meena, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 01/05/2025 घोषणा क" तारीख /Date Of Pronouncement: 08/05/2025 आदेश/O R D E R आदेश आदेश आदेश

Transfer Pricing Officer (TPO), Ahmedabad, under section 92CA(1) in respect of specified domestic transactions including inter-unit sale of electricity 3 and steam. The TPO passed an order dated 30.01.2021 under section 92CA(3) proposing an adjustment of Rs.37,77,80,391/-. The Assessing Officer thereafter issued the draft assessment order dated 24.09.2021 under section 143

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

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

143(3) of the Act on\n06.06.2022 at a total income of Rs.6,15,26,94,300/-. In the course of\nassessment, the Assessing Officer had made an addition of Rs.538.40\nCrores under Section 68 of the Act in respect of sale consideration of\nshares of e-infochips Limited. Further, the Assessing Officer had also\ndenied exemption under Section

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LTD.( ERSTWHILE LUK INDIA PVT. LTD)), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

SCHAEFFLER INDIA LTD.(A SUCCESSOR OF LUK INDIA PVT. LTD)),VADODARA vs. THE ACIT, CIRCLE-1(1)(1) (EARLIER ACIT, CIRCLE-1, HOSUR), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after