KHURANA ENGINEERING LTD.,,AHMEDABAD vs. THE ACIT.(OSD),CIRCLE-1,, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

price that such goods or services would ordinarily fetch in the open market.] (9) Where any amount of profits and gains of an 76[undertaking]or of an enterprise in the case of an assessee is claimed and allowed under this section for any assessment year, deduction to the extent of such profits and gains shall not be allowed under

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE JT. CIT, RANGE-4,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

THE DCIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

LAMBDA THERAPEUTIC RESEARCH LTD.,,AHMEDABAD vs. DCIT CIRCLE-2(1) (2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

4,00,89,104/- as observed by the AO in his order. 60.10 The learned CIT (A) also found that the assessee has filed the reconciliation statement between the income shown in the books of accounts viz a viz the amount of income reflected in form 26AS. Accordingly it was found that the income of the assessee has been spread

GULBRANDSEN CHEMICALS PVT.LTD.,BARODA vs. THE DY.CIT.,CIRCLE-1(1),, BARODA

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

253 26 2958800 MBTC 351036 371.41 465.18 93.77 32316646 DBTO 56852 351.84 409.27 57.43 3265010 Total Transfer Pricing Adjustment Rs.3,91,40,456/- 6. It was in this backdrop that the impugned ALP adjustment was made by the Assessing Officer. Aggrieved by the arm’s length price adjustment, assessee carried the matter in appeal before the CIT(A) but without

THE DCIT, CIRCLE-1(1),, BARODA vs. GULBRANDSEN CHEMICALS PVT.LTD.,, BARODA

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

253 26 2958800 MBTC 351036 371.41 465.18 93.77 32316646 DBTO 56852 351.84 409.27 57.43 3265010 Total Transfer Pricing Adjustment Rs.3,91,40,456/- 6. It was in this backdrop that the impugned ALP adjustment was made by the Assessing Officer. Aggrieved by the arm’s length price adjustment, assessee carried the matter in appeal before the CIT(A) but without

THE ADDL. CIT, RANGE-1,, AHMEDABAD vs. M/S. ADANI ENTERPRISES LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

ADANI ENTERPRISES LTD.,AHMEDABAD vs. THE ADDL. CIT,RANGE-1, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, AHMEDABAD vs. M/S. ADANI ENTERPRISES LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

ADANI ENTERPRISES LTD.,AHMEDABAD vs. THE ADDL. CIT,RANGE-1, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

THE DCIT, CIRCLE-1,, AHMEDABAD vs. ADANI ENTERPRISES LTD.,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

ADANI ENTERPRISES LTD.,,AHMEDABAD vs. THE ADDL.CIT.,RANGE-1,, AHMEDABAD

In the result, the appeal of the Assessing Officer for the assessment year 2010-11 is dismissed

section 14A(2). (B) On the facts and in the circumstances of the case, the learned C.I.T. (Appeals) erred in not deleting proportionate disallowance of interest expenditure U/s. 14A of the act on the ground that interest free funds available with appellant company in ITA Nos.: 1840/Ahd/12, 3321/Ahd/14 and 2305/Ahd/15 and 1918/Ahd/12,3480/Ahd/ 14 and 2531/Ahd/15 Assessment years

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

4. The aggrieved assessee preferred an appeal to ld. CIT (A) where it submitted that transaction of corporate guarantee given is not an international transaction. AYs :2007-08 & 2008-09 4.1 Assessee also submitted that loan was given to establish the commercial expediency as all the AEs were engaged in exclusively distributing the products manufactured by the assessee. Therefore

THE TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

4. The aggrieved assessee preferred an appeal to ld. CIT (A) where it submitted that transaction of corporate guarantee given is not an international transaction. AYs :2007-08 & 2008-09 4.1 Assessee also submitted that loan was given to establish the commercial expediency as all the AEs were engaged in exclusively distributing the products manufactured by the assessee. Therefore

THE ACIT, CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

4. The aggrieved assessee preferred an appeal to ld. CIT (A) where it submitted that transaction of corporate guarantee given is not an international transaction. AYs :2007-08 & 2008-09 4.1 Assessee also submitted that loan was given to establish the commercial expediency as all the AEs were engaged in exclusively distributing the products manufactured by the assessee. Therefore