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)

transfer pricing officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G

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)

transfer pricing officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G

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)

transfer pricing officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G

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)

transfer pricing officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G

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)

transfer pricing officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G

DCIT, CIRCLE-1(1)(1), AHMEDABAD, AHMEDABAD vs. ATUL LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaassessment Year: 2016-17

transfer pricing study report. The assessee had made only part compliance to the requirements of the TPO and all the details as requisitioned were not furnished. Therefore, a notice under Section 271G

DEPUTY COMMISSIONER OF INCOME -TAX, AHMEDABAD vs. PRIYA BLUE RECYCLING LLP, GUJARAT

In the result, the appeal of the Department is dismissed

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

prices of the transactions. Additionally, the TPO did not initiate any penalty proceedings under sections 271AA or 271G for the non-submission of required documents during the transfer

THE DCIT CIRCLE-1(1)(2), AHMEDABAD vs. M/S. DISHMAN PHARMACEUTICALS & CHEMICAL LTD(FORMERLY AS M/S.DISHMAN CARBOGEN AMCIS LTD), AHMEDABAD

In the result, appeal of the Revenue is dismissed

Bench: Shri P.M. Jagtap & Ms. Suchitra Kambleassessment Year: 2014-15

Section 271G could not be imposed. Besides this, the Transfer Pricing Officer vide notice dated 10.08.2017 under Section 92D(3) had asked

M/S. ITT CORPORATION INDIA PVT. LTD.,,BARODA vs. THE DY.CIT, CIRCLE-1(2),, BARODA

In the result, the appeal is allowed

section 271G was imposed by the Transfer Pricing Officer, vide his order dated 25.06.2012, whereas until the amendment was made

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

DEPUTY COMMISSIONER OF INCOME -TAX,CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DEPUTY COMMISSIONER OF INCOME -TAX,CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DEPUTY COMMISSIONER OF INCOME -TAX,CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MAHARASTRA

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MAHARASTRA

In the result, the appeal of the Revenue is dismissed

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinha

transfer prices to align them with arm's length prices determined under these rules and consequent adjustment made to the total income for tax purposes; (m) any other information, data or document, including information or data relating to the associated enterprise, which may be relevant for determination of the arm's length price. 15. It is, thus, found that

DCIT, CENTRAL CIRCLE-1(1), AHMEDABAD vs. BEST OASIS LIMITED , MUMBAI

In the result, the appeal of the Revenue is dismissed

transfer prices to align them with\narm's length prices determined under these rules and consequent adjustment\nmade to the total income for tax purposes;\n(m) any other information, data or document, including information or data relating\nto the associated enterprise, which may be relevant for determination of the\narm's length price.\n\n15.\nIt is, thus, found