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29 results for “transfer pricing”+ Section 195(2)clear

Sorted by relevance

Delhi290Mumbai288Chennai94Bangalore94Jaipur54Hyderabad34Ahmedabad29Chandigarh25Rajkot21Kolkata14Pune13Lucknow12Nagpur9Cochin9Indore8Raipur8Cuttack6Varanasi5Visakhapatnam5Agra3Allahabad3Surat2Jabalpur2Jodhpur1Guwahati1

Key Topics

Section 3738Section 143(3)26Disallowance21Limitation/Time-bar16Addition to Income15Section 92C13Penalty13Section 23412Section 271(1)(c)

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

ITA 162/AHD/2021[2016-17]Status: DisposedITAT Ahmedabad30 May 2024AY 2016-17

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 144C(13)Section 153Section 92BSection 92C

Transfer Pricing Order due date: Number of Days in 30 March 2013 (At least sixty days before the Number of Days in 28 period of limitation referred to in February 2013 section 153 of the Act) Number of days in 2 January 2013 Total Number of 60 days ITA No. 162/Ahd/2021 (Zydus Lifesciences Ltd. vs. DCIT

Showing 1–20 of 29 · Page 1 of 2

12
Transfer Pricing11
Section 144C10
Section 115J9

INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

ITA 222/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad21 May 2025AY 2015-16

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

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144CSection 14ASection 35Section 36(1)(iii)Section 37Section 92C

pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period of 180 days, resulting in an upward adjustment of Rs.14,64,47,827/-. It is not disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM

THE ACIT, CIRCLE-2(1)(1), AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS LTD., AHMEDABAD

Accordingly, this ground raised by the Revenue is dismissed

ITA 281/AHD/2021[2015-16]Status: DisposedITAT Ahmedabad21 May 2025AY 2015-16

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

Section 115JSection 142(1)Section 143(2)Section 143(3)Section 144CSection 14ASection 35Section 36(1)(iii)Section 37Section 92C

pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period of 180 days, resulting in an upward adjustment of Rs.14,64,47,827/-. It is not disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(1) (1) AHMEDABAD, VEJALPUR AHMEDABAD vs. INDUCTOTHERM (INDIA) PRIVATE LIMITED, AHMEDABAD

Appeal are dismissed

ITA 598/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad21 Oct 2024AY 2016-17

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

For Appellant: Ms. Chandni Shah, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 143(2)Section 143(3)Section 144C(3)Section 14ASection 195Section 40Section 92C

2) of the Act was issued on 22.08.2017. During the course of assessment, the case was referred to the Transfer Pricing Officer (TPO) under Section 92CA(1) of the Act for determining the Arm’s Length Price (ALP) of the international transactions. The TPO, in his order dated 30.10.2018, made an upward adjustment of Rs.2,67,13,481/-, primarily

ATUL LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal is partly allowed

ITA 38/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad08 May 2025AY 2017-18

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

For Appellant: Shri Bandish Soparkar, AR
Section 115JSection 143(3)Section 144CSection 144C(13)Section 144C(5)Section 14ASection 35Section 40Section 9(1)(vii)Section 92C

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

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

195 of the Act from the payments of commission made to nonresident agents towards the services rendered by them. 18) Whether on the facts and the circumstances of the case and in law, the Id. CIT(A) has erred in not considering all the facts of the instant case and rulings delivered by Hon'ble Authority for Advance Rulings (Income

DCIT, CIRCLE-2(1)(1), AHMEDABAD vs. ELITECORE TECHNOLOGIES PRIVATE LIMITED, AHMEDABAD

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

ITA 1728/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad12 Jul 2024AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokar, Accountnat Member आयकर अपील सं /Ita No.1728/Ahd/2019 "नधा"रण वष" /Assessment Year : 2011-12 The Dy.Cit Elitecore Technologies Pvt.Ltd. Circle-2(1)(1) बनाम/ (Now Merged With Sterlite Ahmedabad Technolgies Limited) V/S. 904, Silicon Tower, B/H. Pariseema Building Off. C.G. Road Ahmedabad, Gujarat-380 009 "थायी लेखा सं./Pan: Aaace 6815G (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Atul Pandey, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 27/06/2024 घोषणा क" तार"ख /Date Of Pronouncement: 12/07/2024 आदेश/O R D E R Per Shri Makarand V. Mahadeokar, Am: This Appeal Is Filed By The Revenue As Against The Order Passed By The Ld.Commissioner Of Income-Tax(Appeals)-10, Ahmedabad [Hereinafter Referred To As “The Ld.Cit(A)”], Dated 04/09/2019, Arising Out Of The Assessment Order Passed By The Assessing Officer (Ao) Under Section 143(3) Dcit Vs. Elitecore Technologies Pvt.Ltd. Asst. Year : 2011-12

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri Atul Pandey, Sr.DR
Section 143(2)Section 143(3)Section 195Section 250Section 40Section 92C

price. The Prime Lending Rate's comprehensiveness negates the necessity for further adjustments. (v) That, the Assessee’s method of calculating interest has been consistently applied in previous and subsequent financial years without challenge, underscoring its reliability and appropriateness. (vi) That, the Ld.CIT(A) has thoroughly addressed and resolved the issues raised, aligning with the principles of fair benchmarking

M/S. BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-1, AHMEDABAD

In the result, the appeals being IT(SS)A No

ITA 318/AHD/2022[2009-10]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2009-10

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

For Appellant: Shri S.S. Nagar, ARFor Respondent: Shri Kamlesh Makwana, CIT-DR and Shri B.P. Srivastava, Sr.DR
Section 115JSection 132(1)Section 139(1)Section 139(5)Section 142(1)Section 143(2)Section 143(3)Section 153ASection 153A(1)(a)Section 153A(1)(b)

transfer other than from P&L, without prejudice to above the Ld. AR further submitted that it is not necessary that the General Reserves are always created out of accumulated profits. General Reserves can be created in many ways including following transactions; general reserves can arise out of revaluation of certain assets due to amalgamation. The Ld. AR relied upon

TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. ACIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

ITA 1172/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad26 Feb 2024AY 2015-16

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Vartik Choksi, With Shri DhrunalBhatt, ARsFor Respondent: Shri Ritesh Parmar, CIT-DR
Section 143(3)Section 14ASection 35Section 43BSection 80

2 per cent. We observe that in the instant facts, the assessee has computed the ALP at LIBOR plus 2.5%. The Ld. CIT(Appeals) has upheld the order of the Ld. Assessing Officer on the Ground that the assessee has not given the comparable basis for arriving at the aforesaid rate. However, in our view, the Ld. CIT(Appeals

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-1,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 2390/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Transfer Pricing (TP) adjustment made to the international transactions undertaken by the assessee with its Associate Enterprise (AE). 7. Giving a brief background of the case, it was pointed out that the assessee-company, M/s. Shell Global Solutions International BV was incorporated in 1998 and engaged in coordinating operation of a number of Royal Dutch Shell entities world-wide

SHELL GLOBAL SOLUTIONS INTERNATIONAL B.V,,MUMBAI vs. THE ACIT, INTL. TAXN.-2, AHMEDABAD

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 1783/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

Transfer Pricing (TP) adjustment made to the international transactions undertaken by the assessee with its Associate Enterprise (AE). 7. Giving a brief background of the case, it was pointed out that the assessee-company, M/s. Shell Global Solutions International BV was incorporated in 1998 and engaged in coordinating operation of a number of Royal Dutch Shell entities world-wide

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 149/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 150/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 133/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 134/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 135/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 136/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.),VADODARA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2) NOW CIRCLE-1(1)(1), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 137/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 147/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LIMITED (EARLIER KNOWN AS FAG BEARINGS INDIA LTD.), VADODARA

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 148/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount of Rs. 7,03,66,305/-. 21. In appeal before Ld. CIT(A), the assessee submitted that the issue is covered in favour of the assessee by the case