M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX EXEPTIONS, CIRCLE-1,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

BARODA CRICKET ASSOCIATION,,BARODA vs. THE DY.CIT, CIRCLE-5., BARODA

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

BARODA CRICKET ASSOCIATION,,BARODA vs. THE JT. CIT, RANGE-5,, BARODA

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

BARODA CRICKET ASSOCIATION,,BARODA vs. THE DY.CIT, CIRCLE-5., BARODA

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

SAURASHTRA CRICKET ASSOCIATION,,RAJKOT vs. THE DY. CIT (EXEMPTION), CIRCLE-2,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

SAURASHTRA CRICKET ASSOCIATION,,RAJKOT vs. THE DY. CIT (EXEMPTION), CIRCLE-2,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

GUJARAT CRICKET ASSOCIATION,AHMEDABAD vs. THE JT..DIRECTOR OF INCOME TAX(EXEMPTION),, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE JT.. DIRECTOR OF INCOME TAX (EXEMPTION),, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

M/S. GUJARAT CRICKET ASSOCIATION,,AHMEDABAD vs. THE JT.. DIRECTOR OF INCOME TAX (EXEMPTION),, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

SAURASHTRA CRICKET ASSOCIATION,,RAJKOT vs. THE DY. CIT (EXEMPTION), CIRCLE-2,, AHMEDABAD

In the result, ITA No. 2841/Ahd/17, i

transferred to SCAs as TV subsidy and IPL subvention as their share and not as corpus. It is the SCAs who have treated them in different fashion in their own financial statements. However, this does not mean that the nature of receipt changes. 10.8 Therefore, I am of the considered opinion that "receipts from BCCI on account of sale

MEGHMANI ORGANICS LTD.,,AHMEDABAD vs. THE DCIT.,CENT.CIRCLE-1(1),, AHMEDABAD

In the result, assessee’s appeal is allowed for statistical purpose

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

Section 92B. As for the postamendment law and the impact of amendment in the definition of 'international transaction', the matter was again decided in favour of the assessee by Bharti Airtel Ltd. decision (supra) on the peculiar facts of that case. The Meghmani Organics Ltd. vs. DCIT Asst.Year –2009-10 decisions like Everest Kento Cylinders Ltd. (supra) and Aditya Birla

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

transfer price of international transaction either at the time of setting them or by way of adjusting them subsequent to entering into the international transaction to align them to the arm's length price. This is a condition precedent for user of the multiple year financial data. Reliance is placed on the following decisions:- AZTEC Software

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

transfer price of international transaction either at the time of setting them or by way of adjusting them subsequent to entering into the international transaction to align them to the arm's length price. This is a condition precedent for user of the multiple year financial data. Reliance is placed on the following decisions:- AZTEC Software

MASTEK LIMITED,,AHMEDABAD vs. THE DY.CIT, (OSD) - 1, CIRCLE-4,, AHMEDABAD

Bench: Shri Pramod Kumar & Ms Madhumita Roysl. Ita No(S) Appeal(S) By Asset. Nos Year(S) Appellant Vs. Respondent Appellant Respondent 1. 1188/Ahd/2015 2009-10 M/S Mastek Ltd., D.C.I.T., (Osd)-1,Circle-4, 804/805Ahmedabad House, Opp. C.N. Vidyalaya, Nr. Ambawadi Circle, Ambawadi, Ahmedabad -380 006 Pan:Aaacm9908Q 2. 1852/Ahd/2015 2009-10 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad. Ahmedabad 3. It(Tp) 172/Ahd/2016 2010-11 M/S. Mastek Ltd. J.C.I.T., Ahmedabad Range-4, Ahmedabad 4. It(Tp) 514/Ahd/2016 2010-11 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad Ahmedabad Assessee By : Shri S. N. Soparkar & Parin Shah, A.Rs. Revenue By : Shri Krishna Murari, Cit- D.R.

price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92B defines the expression 'international transaction' as follows: '92B - Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either

ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. MASTEK LTD.,, AHMEDABAD

Bench: Shri Pramod Kumar & Ms Madhumita Roysl. Ita No(S) Appeal(S) By Asset. Nos Year(S) Appellant Vs. Respondent Appellant Respondent 1. 1188/Ahd/2015 2009-10 M/S Mastek Ltd., D.C.I.T., (Osd)-1,Circle-4, 804/805Ahmedabad House, Opp. C.N. Vidyalaya, Nr. Ambawadi Circle, Ambawadi, Ahmedabad -380 006 Pan:Aaacm9908Q 2. 1852/Ahd/2015 2009-10 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad. Ahmedabad 3. It(Tp) 172/Ahd/2016 2010-11 M/S. Mastek Ltd. J.C.I.T., Ahmedabad Range-4, Ahmedabad 4. It(Tp) 514/Ahd/2016 2010-11 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad Ahmedabad Assessee By : Shri S. N. Soparkar & Parin Shah, A.Rs. Revenue By : Shri Krishna Murari, Cit- D.R.

price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92B defines the expression 'international transaction' as follows: '92B - Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either

THE JT. CIT, RANGE-4, AHMEDABAD vs. M/S. MASTEK LTD.,, AHMEDABAD

Bench: Shri Pramod Kumar & Ms Madhumita Roysl. Ita No(S) Appeal(S) By Asset. Nos Year(S) Appellant Vs. Respondent Appellant Respondent 1. 1188/Ahd/2015 2009-10 M/S Mastek Ltd., D.C.I.T., (Osd)-1,Circle-4, 804/805Ahmedabad House, Opp. C.N. Vidyalaya, Nr. Ambawadi Circle, Ambawadi, Ahmedabad -380 006 Pan:Aaacm9908Q 2. 1852/Ahd/2015 2009-10 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad. Ahmedabad 3. It(Tp) 172/Ahd/2016 2010-11 M/S. Mastek Ltd. J.C.I.T., Ahmedabad Range-4, Ahmedabad 4. It(Tp) 514/Ahd/2016 2010-11 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad Ahmedabad Assessee By : Shri S. N. Soparkar & Parin Shah, A.Rs. Revenue By : Shri Krishna Murari, Cit- D.R.

price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92B defines the expression 'international transaction' as follows: '92B - Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either

MASTEK LIMITED,AHMEDABAD vs. THE JT.CIT, RANG4,, AHMEDABAD

Bench: Shri Pramod Kumar & Ms Madhumita Roysl. Ita No(S) Appeal(S) By Asset. Nos Year(S) Appellant Vs. Respondent Appellant Respondent 1. 1188/Ahd/2015 2009-10 M/S Mastek Ltd., D.C.I.T., (Osd)-1,Circle-4, 804/805Ahmedabad House, Opp. C.N. Vidyalaya, Nr. Ambawadi Circle, Ambawadi, Ahmedabad -380 006 Pan:Aaacm9908Q 2. 1852/Ahd/2015 2009-10 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad. Ahmedabad 3. It(Tp) 172/Ahd/2016 2010-11 M/S. Mastek Ltd. J.C.I.T., Ahmedabad Range-4, Ahmedabad 4. It(Tp) 514/Ahd/2016 2010-11 A.C.I.T., M/S. Mastek Ltd. Circle-2(1)(2), Ahmedabad Ahmedabad Assessee By : Shri S. N. Soparkar & Parin Shah, A.Rs. Revenue By : Shri Krishna Murari, Cit- D.R.

price adjustment, therefore, a transaction has to be an 'international transaction' first. The expression 'international transaction' is a defined expression. Section 92B defines the expression 'international transaction' as follows: '92B - Meaning of international transaction (1) For the purposes of this section and sections 92, 92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

Transfer Pricing documentation maintained by it in terms of Section 92D of the Act read with Rule 50D of the Income-tax Rules, 1962 ("Rules"): By rejecting (he approach adopted by the Appellant of undertaking a regional benchmarking in the TP report which is in line with the globally accepted TP principles and also accepted by CBDT

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. SHRI JIGAR JASHWANTLAL SHAH, AHMEDABAD

Appeal is dismissed

transfer in-as- I.T.A Nos. 1541 & 1643/Ahd/2017 A.Y. 2013-14 Page No. 15 Shri Jigar Jashwantlal Shah vs. ACIT & ACIT vs. Shri Jigar Jashwantlal Shah much as the consideration implies price, so that the word 'receipt' occurring in section 56(2