PARULBEN VIJAYKUMAR PATEL,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-3(3)(1), AHMEDABAD

In the result, the appeal of the assessee is allowed

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

NARAYANBHAI SHIVABHAI PATEL,MEHSANA vs. THE ITO, WARD-1, MEHSANA

In the result, the appeal of the assessee is allowed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2020-21

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 7.2 It is found that the assessee had disclosed all the material facts and explanation

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

270A or section 271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

270A or section 271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

270A or section 271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

270A or section 271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

270A or section 271 or section 271BA if any person in respect of an international transaction or specified domestic transaction, - (i) fails to keep and maintain any such information and document as required by sub-section (1) or sub-section (2) of section 920, (ii) fails to report such transaction which he is required to do so, or (iii) maintains

MILACRON INDIA PRIVATE LIMITED,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1), AHMEDABAD

The appeal of the assessee is allowed

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2021-22 Milacron India Pvt.Ltd. The Dcit, Cir.2(1)(1) Plot No.93/2 & 91/4 Vs Ahmedabad. Phase-1,Gidc Vatva, Ahmedabad. Pan : Aabcc 0881 D

Transfer Pricing Officer (TPO) for determination of the Arm’s Length Price (ALP) of the international transactions reported in Form 3CEB. The TPO, vide order dated 18.10.2023 passed under section 92CA(3), proposed an upward adjustment of Rs.23,22,513/- to the total income of the assessee in respect of notional interest on outstanding receivables from Associated Enterprises (AEs) amounting

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

9. It is also relevant to refer to decision of the Hon'ble Mumbai\nITAT in the case of Cadbury Schweppes Overseas Ltd vide ITA No.\n921/Mum/2014 wherein it is held as under-\n4. We have considered the rival contentions of both the parties\nand perused the order of the authorities below There is no\ndispute That

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

9. It is also relevant to refer to decision of the Hon'ble Mumbai\nITAT in the case of Cadbury Schweppes Overseas Ltd vide ITA No.\n921/Mum/2014 wherein it is held as under-\n\n4. We have considered the rival contentions of both the parties\nand perused the order of the authorities below There is no\ndispute That

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

270A of the Act.” 3. The assessee-company is a partnership firm engaged in the business of trading of Raw Cashew Nuts. The assessee filed the return of income on 15.02.2022 declaring a business loss of Rs. 1,77,96,363/-. The return was processed under Section 143(1) of the Income Tax Act, 1961 ('the Act'). During

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

In the result, appeal filed by the assessee is partly allowed for statistical purposes

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

Transfer Pricing Officer (TPO) has erred in law and on facts in exceeding the jurisdiction by passing the TP Order under Section 92CA(3) of the Income-tax Act, 1961 (the Act) beyond the mandatorily prescribed time limit as per Section 92CA(3A) read with Section 153(4) of the Act, thereby making the TP Order barred by limitation

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

9. That the AO erred in law while making & DRP erred in upholding the downward adjustment in respect of repayment of unsecured Loan based upon the adjustment made by the TPO/ DRP, without appreciating that it was beyond the TPOs jurisdiction to make such adjustment owing to combined reading of Section 92(3), Section 92BA and Section 80IA

BOCK COMPRESSORS INDIA PRIVATE,BENGALURU vs. THE DY. CIT, CIRCLE - 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2020-21

Transfer Pricing Study Report using Resale Price Method (RPM) accordance with Section 920 and Section 920 of the Act read with Rule 10B, 10C and 10D of the Income-tax Rules, 1962 (the “Rules”) without providing the cogent reason. 3. The ld. AO., Ld. TPO and Ld. DRP erred in law and on facts in not appreciating that goods sold

SANDEEP MOHANRAJ SINGHI,AHMEDABAD vs. ACIT, CIRCLE4(2), AHMEDABAD, AHMEDABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2018-19

9)(a) of the Act by AO is unjustified.” Facts of the case 13. Ground nos.1 to 5 pertain to denial of exemption under Section 11 & 12 of the Act by invoking provisions of Section 13(1)(c) of the Act read with Section 13(3) of the Act. The Assessing Officer had denied the exemption under Section

ACIT (EXEMPTION) CIRCLE 1 AHMEDABAD, AHMEDABAD vs. DR K R SHROFF FOUNDATION, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

9)(a) of the Act by AO is\nunjustified.\"\n\nFacts of the case\n\n13. Ground nos.1 to 5 pertain to denial of exemption under Section 11\n& 12 of the Act by invoking provisions of Section 13(1)(c) of the Act read\nwith Section 13(3) of the Act. The Assessing Officer had denied the\nexemption under

DR K R SHROFF FOUNDATION,AHMEDABAD vs. THE DY. CIT, CIRCLE-1, EXMP, AHMEDABAD

In the result, appeal of the assessee is partly allowed\n\n29

9)(a) of the Act by AO is\nunjustified.\"\n\nFacts of the case\n\n13.\nGround nos.1 to 5 pertain to denial of exemption under Section 11\n& 12 of the Act by invoking provisions of Section 13(1)(c) of the Act read\nwith Section 13(3) of the Act. The Assessing Officer had denied the\nexemption under