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

251 Section 35(2AB) 6 Capitalization of Interest to Capital Work-in- 11,29,21,996 Progress (CWIP) under Section 36(1)(iii) 7 Disallowance of Sales Promotion / Business 23,05,47,312 Promotion Expenses under Section 37 8 Disallowance of Commission Paid to Non- 23,71,88,037 Residents 3. Aggrieved by the assessment order, the assessee filed

D S TRADING,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed

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

transfer pricing report and assessee's argument appeared to be a desperate measure to somehow increase its NCPM - Whether if in order to avoid any sealing assessee decided to shift its office premise to a commercial area and in that process incurred aforesaid abnormal expenses, rejection of assessee's claim towards comparability adjustment on ground that its premises

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

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

transfer pricing on account of capital account transaction being the acquisition of shares. Merely, there was a delay in the allotment of shares by the AE to the assessee, such delay cannot change the character of the transaction as loan. We note that the Delhi bench of ITAT in the case of Bharti Airtel Limited vs. ACIT reported

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

transfer to the overseas supplier against receipt of original shipping documents, Shri Omprakash in his statement also confirmed that once they received the original shipping documents their person would give them the payment either in Sudan or in Dubai in USD or Dirham or in Sudanese pound or any other arrangement as per their convenience. Shri Omprakash also admitted that

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. SHRI SANJAY KISHANLAL BISHNOI,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Suchitra Kamble

transfer to the overseas supplier against receipt of original shipping documents, Shri Omprakash in his statement also confirmed that once they received the original shipping documents their person would give them the payment either in Sudan or in Dubai in USD or Dirham or in Sudanese pound or any other arrangement as per their convenience. Shri Omprakash also admitted that

J vs. INDUSTRIES PVT. LTD.,VADODARAVS.THE PR. CIT, VADODARA-1, VADODARA

In the result, the appeal of the assessee is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

transfer has to be done in prescribed manner i.e. FMV as per rule 11UAE shall be deemed as full value of consideration. Further, As per sub section 3 of section 50B of income tax Act Every assessee in the case of slump sale is required to furnish a report of accountant as defined in the explanation below sub section

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

price fixed by Govt. under Sugar (Control) order which was nothing but distribution of profit resulting in escapement of income, was without jurisdiction. In the case of Shree Sayan Vibhag Sahkari vs. Deputy Commissioner of Income-tax [2016] 69 taxmann.com 245 (Gujarat)[05-04-2016], the Gujarat High Court held that in absence of any failure on part of assessee

INCOME TAX WARD 4(2)(3) AHMEDABAD, AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

price fixed by Govt. under Sugar (Control) order which was nothing but distribution of profit resulting in escapement of income, was without jurisdiction. In the case of Shree Sayan Vibhag Sahkari vs. Deputy Commissioner of Income-tax [2016] 69 taxmann.com 245 (Gujarat)[05-04-2016], the Gujarat High Court held that in absence of any failure on part of assessee

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

price fixed by Govt. under Sugar (Control) order which was nothing but distribution of profit resulting in escapement of income, was without jurisdiction. In the case of Shree Sayan Vibhag Sahkari vs. Deputy Commissioner of Income-tax [2016] 69 taxmann.com 245 (Gujarat)[05-04-2016], the Gujarat High Court held that in absence of any failure on part of assessee

INCOME TAX WARD 4(2)(3) AHMEDABAD , AHMEDABAD vs. NIKULBHAI CHATURBHAI PATEL HUF, GANDHINAGAR

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

price fixed by Govt. under Sugar (Control) order which was nothing but distribution of profit resulting in escapement of income, was without jurisdiction. In the case of Shree Sayan Vibhag Sahkari vs. Deputy Commissioner of Income-tax [2016] 69 taxmann.com 245 (Gujarat)[05-04-2016], the Gujarat High Court held that in absence of any failure on part of assessee

NIKULBHAI CHATURBHAI PATEL, HUF,GANDHINAGAR vs. THE ITO, WARD-4(2)(3), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

price fixed by Govt. under Sugar (Control) order which was nothing but distribution of profit resulting in escapement of income, was without jurisdiction. In the case of Shree Sayan Vibhag Sahkari vs. Deputy Commissioner of Income-tax [2016] 69 taxmann.com 245 (Gujarat)[05-04-2016], the Gujarat High Court held that in absence of any failure on part of assessee