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:

transferred in the controlled and uncontrolled transactions could materially affect the price even though the nature of the business activities undertaken may be sufficiently similar to generate the same overall profit margin.........” Consequently, for the application of CUP as the most appropriate method, the factors of comparability are required to be strictly met. On the facts of the case

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

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

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:

section 133(6) of the Act, which was not available in the public domain, stating that the information had been provided to the assessee for rebuttal. The assessee objected to this approach on the ground that that the TPO erred in re-characterizing its services as high- end KPO, rejecting the comparables selected by it, and relying on non-public

BOCK COMPRESSORS INDIA PRIVATE,BENGALURU vs. THE DY. CIT, CIRCLE - 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2020-21

Transfer Pricing Study Report using Resale Price Method (RPM) accordance with Section 920 and Section 920 of the Act read with Rule 10B, 10C and 10D of the Income-tax Rules, 1962 (the “Rules”) without providing the cogent reason. 3. The ld. AO., Ld. TPO and Ld. DRP erred in law and on facts in not appreciating that goods sold

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

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

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

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

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

M/S. ATUL LTD.,,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

The appeal of the assessee is partly allowed in the above terms for statistical purpose

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarit(Tp)A No.446/Ahd/2015 Assessment Year : 2010-11 M/S.Atul Limited Dcit, Cir.1(1)(2) Atul House Vs Ahmedabad. Gi Patel Marg Ahmedabad 380 014. Pan : Aabca 2390 M

Transfer Pricing Officer in his order passed u/s 92CA(3) of the Act and • the directions of the Dispute Resolution Panel on the objections raised by the assessee to the additions proposed by the AO in his draft assessment order in terms of section 144

ACIT, CIRCLE-1(1)(1), VADODARA vs. FARMSON PHARMACEUTICAL GUJARAT PRIVATE LIMITED, VADODARA

In the result, the appeal of the Revenue is dismissed

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2015-16

section 92E? (iii) Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) was justified in granting relief solely on jurisdictional grounds, without examining the merits of the ALP determination made by the TPO in accordance with the provision applicable for the relevant year? (iv) The appellant craves leaves to add, modify, amend

BHAVNA SHETALKUMAR PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee stands allowed

144 read with section\n147. On merits, the Assessing Officer treated the long-term capital gain\nof Rs.81,85,226 arising from sale of shares of Jackson Investments Ltd. as\nbogus, relying extensively on general findings of the Investigation Wing\nregarding penny stock accommodation entries. The Assessing Officer\nconcluded that the assessee had routed unaccounted income through\noperators and made

THE ACIT, ANAND CIRCLE,, ANAND vs. M/S. CHHOTABHAI JETHABHAI PATEL & CO.,, KHEDA

In the result, the appeal of the revenue is dismissed

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

transfer pricing is concerned with the determination of Arm's Length Price of the specified domestic transactions carried out by the assessee? 5. The appellant craves leave to add, modify, amend or alter any grounds of appeal at the time of, or before, the hearing of appeal. Relief claimed in appeal It is prayed that the Hon'ble ITAT, Ahmedabad

MAUNANG FARMS PVT.LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-2(1)(4),(NOW ACIT., CENTRAL CIRCLE-1(3),, AHMEDABAD

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

144 r.w.s.147 of the Act. Maunang Farms Pvt. Ltd. vs. ITO (Now ACIT) Asst.Year –2012-13 - 2– 2. The Ld. CIT(A) has erred in law and on facts in not considering the fact that reopening of the case of the appellant company under section 147 of the Act by the Ld.AO merely on the basis of borrowed satisfaction without

JIVABHAI MADHABHAI DESAI,AHMEDABAD vs. THE ITO, WARD-1(3)(2) PRESENT JURISDICTION THE ITO, WARD-1(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

price of the land while calculating the Long Term Capital Gain and learned CIT(A) erred in confirming such action of AO, such cost of acquisition and indexation thereof is requested to be granted.” 3. The brief facts of the case are that the assessee, who is an individual, did not file any return of income for the year under

VIJAY KANTILAL VORA,VADODARA vs. DCIT, CIRCLE-4(2)(1), VADODARA

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2011-12 Vijay Kantilal Vora The Dcit 201, Shrushti Flats, Vs Circle-4(2)(1), Opp. Geb Sub Station, Vadodara Gotri Road, Vadodara-390021 Pan: Aakpv3542 J अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sunil Talati, Ca Revenue By : Shri Sudhakar Verma, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 30/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals)- 4 Vadodara (Hereinafter Referred As “Ld. Cit(A)” Dated 30.1.2018, Relating To The Assessment Order Passed By The Assessing Officer (Hereinafter Referred As “Ao”) Under Section 144 R.W.S. 147 Of The Income Tax Act, 1961(Hereinafter Referred As “The Act” For The Assessment Year2011-12. 2. Assessee Has Taken Following Grounds Of Appeal: Vijay Kantilal Vora Vs. Dcit Asst. Year : 2011-12

144 r.w.s. 147 of the Act adding back the long-term capital gains of Rs. 2,09,01,660/- claimed as exempt u/s 10(38). The said addition was made u/s 68 of the Act. Vijay Kantilal Vora vs. DCIT Asst. Year : 2011-12 5. During the course of assessment u/s 147 it was identified that the assessee had sold

SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

144 r.w.s. 147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

144 r.w.s. 147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments

SAKETKUMAR RUGNATH TANNA,AHMEDABAD vs. THE DCIT, CENTRAL CIRCLE-2(2), AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

144 r.w.s. 147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments

THE ACIT, CENTRAL CIRCLE-2(2), AHMEDABAD vs. SMT. RITABEN SAKETKUMAR TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

144 r.w.s. 147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments

THE ITO WARD-5(3)(1) (PREVIOUSLY THE ACIT, CENTRAL CIRCLE-2(2)), AHMEDABAD vs. SHRI SAKETKUMAR RUGNATH TANNA LEGAL HEIR OF LATE SMT. INDUMATIBEN RUGNATH TANNA, AHMEDABAD

In the result the assessee appeal in ITA

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

144 r.w.s. 147 and 143[3] of the I.T.A Nos. 977 & 978 /Ahd/2019 & Ors. A.Ys. 2007-08 & 2014-15 Page No 3 Saketkumar R Tanna vs. ITO & 2 Others Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years as mentioned in the cause title. Since the issues involved in these appeals are abated/pending assessments