THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

145(3) of the Act which empowers the A.O. to deduce the correctpeak profit of the business. (2) The Id. CIT(A) erred in law and on facts in deleting the addition of Rs.1,80,69,095/- made by the A.O. by invoking the provisions of section 69C of the Act. (3) It is, therefore, prayed that the order

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

145(3) of the Act which empowers the A.O. to deduce the correctpeak profit of the business. (2) The Id. CIT(A) erred in law and on facts in deleting the addition of Rs.1,80,69,095/- made by the A.O. by invoking the provisions of section 69C of the Act. (3) It is, therefore, prayed that the order

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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, CIRCLE-2(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

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 DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

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 DY. CIT, CIRCLE-1(1)(2),, AHMEDABAD vs. JMC PROJECTS (INDIA) LIMITED,, AHMEDABAD

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

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

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

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

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

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

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 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

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

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

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

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

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

MUKESHKUMAR CHANDULAL DALWADI,ANAND vs. THE ACIT, CIRCLE-1(3) NOW CIRCLE-1(1)(1), VADODARA

In the result, the appeal of the assessee is allowed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2017-2018 Mukeshkumar Chandulal Acit, Cir.1(3), Now Dalwadi, Akshar Trading Vs. Cir.1(1)(1), Vadodara. A/66/3, Shastri Gunj Station Road, Petland/Anand Gujarat 388 450. Pan : Ajcpd 6980 H (Applicant) (Responent) : Shri B.T. Thakkar, Ca Assessee By Revenue By : Ms.Urvashi Mandhan, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 01/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 04/09/2025

transferred to the National Faceless Appeal Centre and finally assigned to the office of Addl./JCIT (A)-1, Gurugram. 3 2.5 Before the CIT(A), the assessee contended that the addition of Rs.8,41,374/- was made merely on surmises, without rejection of books of account, and in absence of any specific defect in accounting or stock valuation