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39 results for “transfer pricing”+ Section 145clear

Sorted by relevance

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Key Topics

Section 143(3)50Addition to Income34Section 8027Section 153A26Disallowance19Section 25015Section 6910Section 379Deduction7

HAGGLUNDS DRIVES (INDIA) PVT. LTD. ( NOW MERGED IN BOSCH REXROTH (INDIA) LTD.),,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(2),, AHMEDABAD

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

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Adjustment of Rs.23,51,667/- . No substantial question of law arises. ITA No. 931/Ahd/2015 & 448/Ahd/2016 Hagglunds Drives (India) Pvt. Ltd./ Bosch Rexroth (India) Pvt. Ltd. vs. DCIT&ITO Asst. Year –2010-11 & 2011-12 8. In view of the above and for the reasons stated above, we concur with the orders passed by the learned

BOSCH REXROTH (INDIA) PVT. LTD.,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-1(1)(3), AHMEDABAD

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

Showing 1–20 of 39 · Page 1 of 2

Section 143(2)6
Natural Justice6
Section 685
ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

Transfer Pricing Adjustment of Rs.23,51,667/- . No substantial question of law arises. ITA No. 931/Ahd/2015 & 448/Ahd/2016 Hagglunds Drives (India) Pvt. Ltd./ Bosch Rexroth (India) Pvt. Ltd. vs. DCIT&ITO Asst. Year –2010-11 & 2011-12 8. In view of the above and for the reasons stated above, we concur with the orders passed by the learned

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

ITA 828/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

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

ITA 829/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

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

ITA 2498/AHD/2013[2010-11]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2010-11

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

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

ITA 830/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Nov 2024AY 2011-12

Bench: Us & That These Four

For Appellant: S/Sh. D.M. Rindani and Sh. Chintan Shah, RRsFor Respondent: Sh. Ashok Kumar Suthar, Sr. DR
Section 143(2)Section 143(3)Section 80

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

GFL LIMITED (EARLIER KNOWN AS GUJARAT FLUOROCHEMICALS LTD.),VADODARA vs. THE PR. CIT-1, VADODARA

In the result, the appeal of the assessee is allowed

ITA 210/AHD/2022[2016-17]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2016-17

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokar

For Appellant: Shri S. N. Soparkar, Sr. AdvocateFor Respondent: Shri Pushpendra Singh Chaudhary, CIT-DR
Section 115JSection 143(3)Section 144C(3)Section 263Section 80ISection 92C

145,84,66,706/-. The case was selected for scrutiny under CASS and the assessment under section 143(3) read with section 144C(3) was completed, determining total income at ₹66,41,77,803/- under normal rate, ₹24,31,020/- under special rate, and book profit under section 115JB at ₹148,81,42,146/-. 4. Upon examination of the revised

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

ITA 446/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad26 Apr 2024AY 2010-11

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

For Appellant: Shri S.N. Soparkar, Sr.Advocate &For Respondent: Dr.Darsi Suman Ratnam, CIT-DR
Section 143(3)Section 144Section 92C

transfer pricing adjustment made to the international transactions entered into by the assessee with its AE in terms of provisions of section 92CA of the Act. The said grounds read as under: “1. Ld. AO/ TPO/ DRP erred in law and on facts in determining upward adjustment of Rs. 1, 60, 31, 0507- in respect of international transaction without

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

ITA 275/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt
Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

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 LIMITED,VADODARA, GUJARAT vs. ASSISTANT DIRECTOR OF INCOME TAX,CPC, BANGALORE (JAO-DEPUTY COMMISSIONER OF INCOME TAX CIRCLE1(1)(1), VADODARA, GUJARAT

ITA 692/AHD/2024[2019-20]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2019-20

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt
Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

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

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

ITA 299/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad27 Nov 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Shri Prathvi Raj Meena, CIT D.R. & Smt
Section 143(3)Section 144CSection 234Section 271(1)(c)Section 37

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

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

ITA 1747/AHD/2016[2010-11]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2010-11

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

ITA 2036/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2008-09

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

ITA 2353/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2008-09

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT.,(OSD)-I,RANGE-4,, AHMEDABAD

ITA 2815/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2007-08

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

THE ACIT,(OSD)-I,RANGE-4,, AHMEDABAD vs. JMC PROJECTS (INDIA) LTD.,, AHMEDABAD

ITA 3269/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2007-08

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

ITA 2603/AHD/2013[2007-08]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2007-08

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LTD.,,AHMEDABAD vs. THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

ITA 2604/AHD/2013[2008-09]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2008-09

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

ITA 1746/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2009-10

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification

JMC PROJECTS (INDIA) LIMITED,,AHMEDABAD vs. THE DY. CIT, CENTRAL CIRCLE-1(1),, AHMEDABAD

ITA 1748/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad22 Nov 2024AY 2011-12

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

For Appellant: Shri S.N. Soparkar, Sr. Advocate &For Respondent: Shri R.N. Dsouza, CIT-DR
Section 143(3)Section 153A

Transfer (BOT) project and it was purely execution of contract against the running bills raised by the assessee. The DR further stated that the assessee company is not planning the project but is carrying out part of activities and raising the detailed RA bills to the developer and getting the payment for the same on supervision and certification