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:

X of the Income Tax Act It is submitted that it be so held now and such order may please he quashed or suitably modified. 2. The learned Deputy Commissioner of Income Tax (Transfer Pricing Officer)-2. Ahmedabad (the TPO) has erred in determining attributable profits to Permanent Establishment ("PE") of the assessee while TPO's authorization us. 92CA

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer 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

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

X of the Act. 13. We have carefully considered the rival submissions, perused the orders of the authorities below, and duly examined the material available on record. 14. The issue relates to the transfer 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

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)

24-06-2025 Date of pronouncement : 25-06-2025 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee as against the final assessment order dated 11-09-2024 passed by the Assessment Unit, arising out of the order passed under section 144C(5) of the Income Tax Act, 1961 (hereinafter referred

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

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

X in general are special provisions dealing with computation of income in an international transaction. Those provisions will prevail over the general provisions. GeneraliaSpecialibus Non Derogant (general provisions must yield to the specific provisions). Generally speaking, the sections in the Act do not overlap one another and each section deals with the matter specified therein and goes no further

SOPHOS TECHNOLOGIES PRIVATE LIMITED,AHMEDABAD vs. THE DCIT, CIRCLE-4(1)(1), AHMEDABAD

In the result the appeal filed by the assessee is allowed

X Rasta, Gujarat College Road, Ellisbridge, Ahmedabad-380006, Gujarat, India PAN: AACCC7727M (Respondent) (Appellant) Assessee Represented: Shri DhaneshBafna, Shri Amol Mahajan & Ms. Nidhi Agarwal, A.Rs. Revenue Represented: Shri Alpesh Parmar, CIT- DR Date of hearing : 08-01-2026 Date of pronouncement : 29-01-2026 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- This appeal is filed by the Assessee

JT. CTI (OSD), CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

24)(x) r.w.s.36(l)(va) of the I.T. Act. Nirma Limited Vs. DCIT (Five Appeals) 3 3) In law and in facts and circumstances of the Appellant's case, the learned CIT(A) has grossly erred in confirming disallowance of depreciation on goodwill for Rs.17,27,50,337/- 4) In law and in facts and circumstances of the Appellant

M/S. NIRMA LIMITED,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

24)(x) r.w.s.36(l)(va) of the I.T. Act. Nirma Limited Vs. DCIT (Five Appeals) 3 3) In law and in facts and circumstances of the Appellant's case, the learned CIT(A) has grossly erred in confirming disallowance of depreciation on goodwill for Rs.17,27,50,337/- 4) In law and in facts and circumstances of the Appellant

THE DCIT, CIR-3(1)(1), AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

24)(x) r.w.s.36(l)(va) of the I.T. Act. Nirma Limited Vs. DCIT (Five Appeals) 3 3) In law and in facts and circumstances of the Appellant's case, the learned CIT(A) has grossly erred in confirming disallowance of depreciation on goodwill for Rs.17,27,50,337/- 4) In law and in facts and circumstances of the Appellant

NIRMA LIMITED,,AHMEDABAD vs. DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

24)(x) r.w.s.36(l)(va) of the I.T. Act. Nirma Limited Vs. DCIT (Five Appeals) 3 3) In law and in facts and circumstances of the Appellant's case, the learned CIT(A) has grossly erred in confirming disallowance of depreciation on goodwill for Rs.17,27,50,337/- 4) In law and in facts and circumstances of the Appellant

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

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

2(24)(x) of the Act relating to the late payment of PF/ESIC payment. The Assessing Officer assessed the income at Rs.61,61,15,800/-. The Assessing Officer also calculated MAT under Section 115JB of the Act thereby making addition of Rs.6,66,11,675/-. Disallowance under Section 14A of the Act and ITA Nos.345 & 383/Ahd/2020 Assessment Years

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

In the result, appeal of the Revenue is partly allowed for statistical purpose and the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

2(24)(x) of the Act relating to the late payment of PF/ESIC payment. The Assessing Officer assessed the income at Rs.61,61,15,800/-. The Assessing Officer also calculated MAT under Section 115JB of the Act thereby making addition of Rs.6,66,11,675/-. Disallowance under Section 14A of the Act and ITA Nos.345 & 383/Ahd/2020 Assessment Years

SHRI MUKESH RASIKLAL SHAH,,AHMEDABAD vs. THE ACIT, CIRCLE-9, NOW CIRCLE-4(2),, AHMEDABAD

In the result, the appeals filed by the assessee are hereby dismissed

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

x) of the l.T. Act, 1961. (v) In the instant case, the assessee held the amount of Rs.2,47,943/- and Rs.19,36,095/- pertaining to A.Yrs. 1992-93 and 1993-94 respectively illegally for number of years and instead of refunding the ill-gotten amount to Govt. account, the assessee chose to invest the money further as mentioned supra