THE VARDHMAN STAMPINGS PVT. LTD.,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD

In the result, both the appeals of the assessee are allowed

17 of 2013),]\nshall not be deemed to be a speculative transaction.\nThe eligible transaction is defined as under:\nExplanation l.—For the purposes of clause (d), the expressions—\n(i) \"eligible transaction\" means any transaction, —\n(A) carried out electronically on screen-based systems through a stock broker\nor sub-broker or such other intermediary registered under section

THE VARDHMAN STAMPINGS PVT. LTD.,,AHMEDABAD vs. THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(2),, AHMEDABAD

In the result, both the appeals of the assessee are allowed

17 of 2013),]\nshall not be deemed to be a speculative transaction.\nThe eligible transaction is defined as under:\nExplanation l.—For the purposes of clause (d), the expressions—\n(i) \"eligible transaction\" means any transaction, —\n(A) carried out electronically on screen-based systems through a stock broker\nor sub-broker or such other intermediary registered under section

ASANDAS & SONS PRIVATE LIMITED,MEHSANA vs. THE DY.CIT, CIRCLE- GANDHINAGAR, GANDHINAGAR

In the result the appeal filed by the assessee is allowed for statistical purpose

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

5. Per contra arguments Ld. CIT-DR Shri Prathviraj Meena appearing for the Revenue are summarized as follows: The assessee had originally selected CUP and cannot now be  permitted to change it merely because the result is unfavorable.  The quality differences were not evident on invoices and  therefore comparability could not be conclusively challenged.  The AE was not a mere

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:

17. Learned CIT(A) further observed that the transfer pricing addition was incorrectly made by selecting functionally incomparable transactions by observing as follows:- “10. I have perused the above submission of the appellant company. The appellant has pointed out various shortcomings in -application of filter while selecting comparable companies and also emphasized that the comparable transactions selected

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

D capital 192,71 192,52 0.19 0.19 0.09 expenditure R&O revenue 5409.10 370742 1101,3.8 1492,86 746.42 208.42 104.21 expenditure Total 5,601.81 3900.34 1701.47 746.43 208.61 104.305 4. Without prejudice to Ground No. 3 above, in the facts and circumstances of the case, the learned C1T(A) further erred in stating amount of disallowance towards weighted

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)

5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. I.T.A No. 359/Ahd/2022 A.Y. 2018-19 7 M/s. Altera Digital Health (India) LLP (Formerly known as Allscripts (India) LLP) vs. DCIT 6. Before us, the counsel for the assessee with respect to Ground Numbers 2 to 9 relating

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 u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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 u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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 u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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 u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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 u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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

17,72,240/- under normal provisions and book profit of Rs.724,71,13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from

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

17,72,240/- under normal provisions and book profit of Rs.724,71,13,583/- under section 115JB of the Act. The return of income was selected for scrutiny under the Computer Aided Scrutiny Selection (CASS) and notice under section 143(2) of the Act was duly issued. Subsequently, notices under section 142(1) along with detailed questionnaires were issued from

THE DCITBHARUCH RANGE,, BHARUCH vs. HEUBACH COLOUR PVT.LTD.,, ANKLESHWAR

In the result, Ground Number 3 of the Department’s appeal is dismissed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

5% for trademarks) were not justified. Based on the OECD Transfer Pricing Guidelines, Ld. CIT(Appeals) considered it more appropriate to apply a royalty rate of 3.5% for technical know-how and 3% for trademarks. Looking into the assessee’s set of facts, we are of the view that Ld. CIT(Appeals) has adopted a well-reasoned approach, while passing