SHELL ENERGY INDIA PRIVATE LIMITED,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed for statistical purposes and that of the Revenue is dismissed

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2012-13 Shell Energy India Pvt. Ltd. The Dcit, Cir.2(1)(1) Office No.2008, Westgage Vs Ahmedabad. Block-D, Makarba, Sg Highway Ahmedabad 380051. Pan : Aaach 9143 C Assessment Year : 2012-13 The Dcit, Cir.2(1)(1) Shell Energy India Pvt. Ltd. Ahmedabad. Vs (Formerly Known As M/S.Hqzira Lng P.Ltd.) Ahmedabad. Pan : Aaach 9143 C (Applicant) (Responent) Assessee By : Shri S.N. Soparkar, Sr.Advocate, Shri Vishal Kalra & Ss Tomar, Ars. Revenue By : Shri (Dr.) Darsi Suman Ratnam, Cit-Dr Shri Ashok Kumar Suthar, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 04/09/2024 घोषणा क" तारीख /Date Of Pronouncement: 17/10/2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Guptathese Are Cross-Appeals By The Assessee & The Revenue Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Ahmedabad Dated 23.09.2022 Passed Under Section 250 Of The Income Tax Act, 1961 (“The Act” For Short) For The Assessment Year 2012-13. Ita No.435 & 558/Ahd/2022

250 of the Income Tax Act, 1961 (“the Act” for short) for the assessment year 2012-13. ITA No.435 and 558/Ahd/2022 2 2. The ld.Sr.Advocate, Shri S.N. Soparkar, appearing for the assessee in the Department’s appeal mentioned at the outset itself that the issue raised in the said appeal stood covered in favour of the assessee by various decisions

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD, HYDERABAD vs. MYTRAH VAYU (GUJARAT) PRIVATE LIMITED, HYDERABAD

In the result, appeal filed by the Revenue is dismissed

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2014-15. ITA No.690/Ahd/2025 [ACIT vs. Mytrah Vayu (Gujarat) Private Limited] A.Y. 2014-15 - 2 – 2. The Ground No.1 of appeal raised by the Revenue as under: “1. Whether on the facts and in the circumstances of the case

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

In the result, the appeal of the Revenue is dismissed

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:-

250/- on account of weighted Deduction claim of the assessee u/s 35(2AB) in excess of that allowed by the DSIR in Form 3CL. 15) Whether on the facts and the circumstances of the case and in law, the ld CIT(A) has erred in deleting the disallowance of interest of Rs. 14,06,15,203/u/s.36

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

In the result, Revenue’s appeal is allowed in part

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

transfer pricing regulations. The Explanation to Section 92B of the Act defines ‘lending or guarantee’ as international transaction and by providing corporate guarantee the guarantor assumes certain risks for such provision, for which he ought to be compensated by way of sharing the benefit. The Ld. AR too fairly conceded that the corporate guarantee was an international transaction and adjustment

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

In the result, Revenue’s appeal is allowed in part

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

transfer pricing regulations. The Explanation to Section 92B of the Act defines ‘lending or guarantee’ as international transaction and by providing corporate guarantee the guarantor assumes certain risks for such provision, for which he ought to be compensated by way of sharing the benefit. The Ld. AR too fairly conceded that the corporate guarantee was an international transaction and adjustment

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

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ARVIND LIMITED, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

Section 250 of the Income- tax Act, 1961 [hereinafter referred to as "the Act" for short] dated 23.01.2024 for Assessment Year (AY) 2018-19. Since the issues are common and appeals are inter-connected, the same are being disposed of by this common order for the sake of convenience. ITA No. 349 & 466/Ahd/2024 Assessee : Arvind Limited Asst. Year

ARVIND LIMITED,AHMEDABAD vs. NFAC, DELHI PRESENT JURISDICTION THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamblearvind Limited, Dcit Vs. Naroda Road, Nfac, Delhi Ahmedabad-380025 (Dcit, Circle 1(1)(1), [Pan : Aabca 2398 D] Ahmedabad) Arvind Limited, Vs. Acit, Circle 1(1)(1), Naroda Road, Ahmedabad Ahmedabad-380025 [Pan : Aabca 2398 D]

Section 250 of the Income- tax Act, 1961 [hereinafter referred to as "the Act" for short] dated 23.01.2024 for Assessment Year (AY) 2018-19. Since the issues are common and appeals are inter-connected, the same are being disposed of by this common order for the sake of convenience. ITA No. 349 & 466/Ahd/2024 Assessee : Arvind Limited Asst. Year

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

In the result, the appeal is partly allowed

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

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

GALAXY DEVELOPERS,AHMEDABAD vs. THE ACIT., CIRCLE-7(2), AHMEDABAD

In the result, the Appeal of the assessee is allowed

250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act"] for the assessment year 2017-18, whereby the Ld. CIT(A) upheld the assessment order passed by the Assistant Commissioner of Income Tax, Circle-7(2), Ahmedabad [hereinafter referred to as “the AO”] under section 143(3) of the Act dated 23.12.2019.\nITA No.1445/Ahd/2024\n2\nFacts

JIVABHAI MADHABHAI DESAI,AHMEDABAD vs. THE ITO, WARD-1(3)(2) PRESENT JURISDICTION THE ITO, WARD-1(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

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

250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2012-13. 2. The Assessee has taken following grounds of appeal:- “1. The learned CIT(A) erred in law and on facts in confirming the addition made by Assessing Officer of Rs.1,18,33,400/- being the Jivabhai Madhabhai Desai

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

250/- under Section 271(1)(c) of the Act. The grounds of appeal are dismissed.” 39. Before us, the Counsel for the assessee submitted that the brother of the assessee, Shri Rohit Thakore was the co-owner of this property, wherein assessments were framed pursuant to the same search carried out on 21.09.2010. The Counsel for the assessee submitted that

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

250/- under Section 271(1)(c) of the Act. The grounds of appeal are dismissed.” 39. Before us, the Counsel for the assessee submitted that the brother of the assessee, Shri Rohit Thakore was the co-owner of this property, wherein assessments were framed pursuant to the same search carried out on 21.09.2010. The Counsel for the assessee submitted that

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

250/- under Section 271(1)(c) of the Act. The grounds of appeal are dismissed.” 39. Before us, the Counsel for the assessee submitted that the brother of the assessee, Shri Rohit Thakore was the co-owner of this property, wherein assessments were framed pursuant to the same search carried out on 21.09.2010. The Counsel for the assessee submitted that

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

250/- under Section 271(1)(c) of the Act. The grounds of appeal are dismissed.” 39. Before us, the Counsel for the assessee submitted that the brother of the assessee, Shri Rohit Thakore was the co-owner of this property, wherein assessments were framed pursuant to the same search carried out on 21.09.2010. The Counsel for the assessee submitted that

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

250/- under Section 271(1)(c) of the Act. The grounds of appeal are dismissed.” 39. Before us, the Counsel for the assessee submitted that the brother of the assessee, Shri Rohit Thakore was the co-owner of this property, wherein assessments were framed pursuant to the same search carried out on 21.09.2010. The Counsel for the assessee submitted that