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

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

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)

143(3) r.w.s. 92CA of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2012-13 and 2013-14 respectively. Since common issues are involved in both the appeals, for the sake of convenience, the same are disposed of by this common order. I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 2

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)

143(3) r.w.s. 92CA of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2012-13 and 2013-14 respectively. Since common issues are involved in both the appeals, for the sake of convenience, the same are disposed of by this common order. I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 2

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

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

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleआयकर अपील सं./I.T.A. No. 581/Ahd/2017 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ M/S. Tbea Shenyang Deputy Commissioner Of Transformer Group Income Tax Vs. Company Limited International Taxation, National Highway No.-8, Vadodara Villae : Miyagam, Karja, Vadodara, Gujarat - 390007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadct4557F (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Arpit Jain, Ar ""यथ" क" ओर से/Respondent By : Shri Mahesh Shah, Cit. Dr 24/04/2025 Date Of Hearing Date Of Pronouncement 22/07/2025 O R D E R Per Smt. Annapurna Gupta, Am:

Section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2012-13. 2. The brief background of the case which has led to present appeal before us is that the assessee is a permanent establishment (PE) i.e. project office for the enterprise – M/s. ITA No. 581/Ahd/2017

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

143(2) read with Section 129 of the Act was issued on 03.06.2015 and served to the assessee. Thereafter, notices under Section 142(1) of the Act were issued on various dates. In response to the above notices, the Ld. AR of the assessee (Chartered Accountant) attended the proceedings and submitted the details called for. The Assessing Officer observed that

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 order that appellant has failed to maintain documents specified in Section 92D r.w.r 10D relating to such purchase transactions, and (iii) the TPO has nowhere mentioned that which documents as envisaged in Section 92D are not maintained by appellant which leads to levy of penalty u/s 271AA of the Act (iv) Even TPO has nowhere mentioned that there

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 order that appellant has failed to maintain documents specified in Section 92D r.w.r 10D relating to such purchase transactions, and (iii) the TPO has nowhere mentioned that which documents as envisaged in Section 92D are not maintained by appellant which leads to levy of penalty u/s 271AA of the Act (iv) Even TPO has nowhere mentioned that there

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 order that appellant has failed to maintain documents specified in Section 92D r.w.r 10D relating to such purchase transactions, and (iii) the TPO has nowhere mentioned that which documents as envisaged in Section 92D are not maintained by appellant which leads to levy of penalty u/s 271AA of the Act (iv) Even TPO has nowhere mentioned that there

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 order that appellant has failed to maintain documents specified in Section 92D r.w.r 10D relating to such purchase transactions, and (iii) the TPO has nowhere mentioned that which documents as envisaged in Section 92D are not maintained by appellant which leads to levy of penalty u/s 271AA of the Act (iv) Even TPO has nowhere mentioned that there

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 order that appellant has failed to maintain documents specified in Section 92D r.w.r 10D relating to such purchase transactions, and (iii) the TPO has nowhere mentioned that which documents as envisaged in Section 92D are not maintained by appellant which leads to levy of penalty u/s 271AA of the Act (iv) Even TPO has nowhere mentioned that there

ALTERA DIGITAL HEALTH (INDIA) LLP (FORMERLY KNOWN AS ALLSCRIPTS (INDIA) LLP),VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, Ground Number 11 of the assessee’s appeal is allowed for statistical purposes

Bench: Smt. Annapurna Gupta (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

transfer pricing adjustment of Rs. 3,94,09,319/-. The returned income of Rs. 70,15,57,590/- was therefore enhanced by the said amount and assessed at Rs. 74,09,66,910/- under section 143(3) read with section 144C(13) of the Act. 5. The assessee is in appeal before us against the order passed by CIT(Appeals

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 adjustment without satisfying the\nconditions stipulated in Explanation 7 to section 271(l)(c) of the Act.\n11. The learned CIT(A) erred in fact and in law in confirming the action of the\nlearned AO in levying penalty without appreciating the fact that the Arm's Length Price\n(\"ALP\") was computed by the Appellant in good

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 order that\nappellant has failed to maintain documents specified in Section\n92D r.w.r 10D relating to such purchase transactions, and\n(iii) the TPO has nowhere mentioned that which documents as\nenvisaged in Section 92D are not maintained by appellant which\nleads to levy of penalty u/s 271AA of the Act\n(iv) Even TPO has nowhere mentioned

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 (TP) risk parameters, as the assessee had international transactions with its Associated Enterprises (AEs) amounting to Rs.76,89,45,119/-. Accordingly, notice under Section 143(2

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 order that\nappellant has failed to maintain documents specified in Section\n92D r.w.r 10D relating to such purchase transactions, and\n(iii) the TPO has nowhere mentioned that which documents as\nenvisaged in Section 92D are not maintained by appellant which\nleads to levy of penalty u/s 271AA of the Act\n(iv) Even TPO has nowhere mentioned

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

In the result, appeal of the assessee is partly allowed

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

2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2018-19 on 26.10.2018 declaring income of Rs. Nil. The case was selected for complete scrutiny under CASS. The assessment was completed under Section 143(3) of the Act on 06.06.2022 at a total income of Rs.6

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

2 of 24\ndated 31.03.2025, for the Assessment Year (A.Y.) 2018-19 in the\nproceedings under Section 143(3) read with Section 147 of the Income\nTax Act, 1961 (hereinafter referred to as ‘the Act').\n\n2.\nThe brief facts of the case are that the assessee had filed its return\nof income

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(3) read with