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)

transfer pricing benchmarking analysis conducted by the Appellant be accepted and consequently the TP adjustment be deleted. 5. On the facts and in the circumstances of the case, and in law, the Ld. AO/Ld. TPO, following the directions of Ld. DRP, has erred in applying an arbitrary turn over filter of 10 times lesser and 10 times higher than

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

Transfer Pricing adjustment of Rs.9,09,30,135 made by the TPO essentially represents additional profit attributable to Indian PE and therefore, the TPO and consequently the AO have clearly erred in making such adjustment. It be so held now. 3. The TPO, the Learned Dispute Resolution Panel ("the DRP") and consequently the AO have erred in facts as well

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

In the result the appeal filed by the assessee is allowed

Transfer Pricing Officer for determining Arms’ Length Price of the International Transaction undertaken by the assessee company and the TPO accepted the price at which International Transaction were recorded and no adverse inference was drawn by passing order dated 28-10-2019 under section 92CA(3) of the Act. Following the same, the Ld AO accepted the returned income filed

HAZIRA PORT PRIVATE LIMITED,AHMEDABAD vs. DY.COMMISSIONER OF INCOME TAX, CICLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed on the above terms

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment on Repayment of Unsecured Loan 8. The Ld. AO/ TPO/ DRP have erred in making a downward adjustment of INR 12,63,95,034 in relation to accrued interest on repayment of unsecured loans. While making the aforementioned adjustment, on the facts and circumstances of the case and in law, the AO/ TPO/ DRP have erred

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

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

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

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

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LTD.( ERSTWHILE LUK INDIA PVT. LTD)), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

SCHAEFFLER INDIA LIMITED,VADODARA, GUJARAT vs. ASSISTANT DIRECTOR OF INCOME TAX,CPC, BANGALORE (JAO-DEPUTY COMMISSIONER OF INCOME TAX CIRCLE1(1)(1), VADODARA, GUJARAT

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

SCHAEFFLER INDIA LTD.(A SUCCESSOR OF LUK INDIA PVT. LTD)),VADODARA vs. THE ACIT, CIRCLE-1(1)(1) (EARLIER ACIT, CIRCLE-1, HOSUR), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

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

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in ITA Nos. 133 to 137/Ahd/2023 & ITA Nos. 147 to 150/Ahd/2023 Schaeffler India Ltd.(Earlier known as Fag Bearings India Ltd.) vs. ACIT Asst. Years –2010-11 to 2014-15 & 2010-11 to 2013-14 respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe

BHAVNA SHETALKUMAR PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee stands allowed

234C is unjustified.\n11.\nThe assessee also filed following additional grounds of appeal:\n1. The order passed by AO is required to be quashed as AO proceeded with\nassessment without issuance of notice u/s 143(2) of the Act which is mandatory\nrequirements.\n12.\nOn the additional ground relating to the alleged non issuance of\nnotice under section

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

234C of the Act is mandatory. 5) In law and in facts and circumstances of the Appellant's case, the learned CIT(A) has grossly erred in dismissing appellant's ground regarding initiation of penalty proceedings u/s.271(l)(c) of Income-tax Act. Asst.Year 2014-15 1) In law and in facts and circumstances of the Appellant's case