DCIT, CIRCLE-1(1)(1),, AHMEDABAD vs. ADANI ENTERPRISES LTD., AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

transfer pricing analysis is to compute the income arising from an international transaction, having regard to its arm's length price. The 'international transaction' in question, relates to import of raw materials by the assessee from its associated enterprises. Therefore, what is expected of the TPO is to consider the transactions of import of raw materials by the assessee from

THE DCIT, CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

transfer pricing analysis is to compute the income arising from an international transaction, having regard to its arm's length price. The 'international transaction' in question, relates to import of raw materials by the assessee from its associated enterprises. Therefore, what is expected of the TPO is to consider the transactions of import of raw materials by the assessee from

THE DCIT CIRCLE-1(1)(1), AHMEDABAD vs. M/S. ADANI ENTERPRISE LTD, AHMEDABAD

In the result appeal of the Revenue is hereby partly allowed

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

transfer pricing analysis is to compute the income arising from an international transaction, having regard to its arm's length price. The 'international transaction' in question, relates to import of raw materials by the assessee from its associated enterprises. Therefore, what is expected of the TPO is to consider the transactions of import of raw materials by the assessee from

THE DCIT, CIRCLE-1,, AHMEDABAD vs. AIA ENGINEERING LTD.,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

price, under the scheme of the international transfer pricing set out in the Income Tax Act, 1961, can only be done in respect of an 'international transaction'. Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price

AIA ENGINEERING LTD.,,AHMEDABAD vs. THE DY.CIT.,CIRCLE-1,, AHMEDABAD

In the result, ITA Appeals 1766/Ahd/12, 2342/Ahd/15, 2343/Ahd/2015,

price, under the scheme of the international transfer pricing set out in the Income Tax Act, 1961, can only be done in respect of an 'international transaction'. Section 92(1) provides that, "(a)ny income arising from an international transaction shall be computed having regard to the arm's length price". In order to attract the arm's length price

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

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

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

SKAPS INDUSTRIES INDIA PVT. LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-8,, AHMEDABAD

In the result, appeal of the assessee is partly allowed for statistical purpose

Bench: Ms. Suchitra Kamble & Shri Waseem Ahmedassessment Year: 2010-11

Transfer Pricing Officer (TPO) made upward adjustment of Rs.2,42,26,184/- and added the same to the total income of the assessee. The Assessing Officer also made disallowance of Rs.2,94,465/- under Section 14A read with Rule 8D. The Assessing Officer also disallowed Rs.59,38,487/- in respect of preliminary pre- operative expenditure written off. The Assessing Officer

NIRMA CHEMICAL WORKS PVT.LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

NIRMA CHEMICALS WORKS PVT.LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

NIRMA CHEMICALS WORKS PVT.LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-5,, AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

THE ACIT, CIRCLE-5,, AHMEDABAD vs. NIRMA CHEMICALS WORKS PVT.LTD., AHMEDABAD

In the result appeal of the revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

transferred and in the process several dispute arose which gone upto apex court. ITA Nos.1054/Ahd/2012 and 6 others A.Y. 2006-07 27 (d) Similar loss was also claimed by sister concern Nirma Industries limited in A.Y. 2006-07 but no addition made by the AO which shows the contradictory approach of the AO. 37. Being aggrieved by the order

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMA LABORATORIES LTD.,, MUMBAI

In the result, the Department’s appeal is partly allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Pricing and also much lesser than the prevailing interest rates in the market. It is undisputed fact that based on contractual obligation the late payment of 232 days has attracted the penal interest of Rs.50,16,000/- which is to be allowed u/s.37(1) of the Act. Thus the addition made by the Ld AO on this account is against

SUN PHARMA LABORATORIES LTD.,,MUMBAI vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA

In the result, the Department’s appeal is partly allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Pricing and also much lesser than the prevailing interest rates in the market. It is undisputed fact that based on contractual obligation the late payment of 232 days has attracted the penal interest of Rs.50,16,000/- which is to be allowed u/s.37(1) of the Act. Thus the addition made by the Ld AO on this account is against

BHOGILAL ODHAVJI INDUSTRIAL ENTERPRISES PVT. LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-1(1),, AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Smt Madhumita Royआयकर अपील सं./I.T.A. No. 2889/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2012-13) Bhogilal Odhavji Industrial Dcit, बनाम/ Enterprises Pvt. Ltd., Circle -1(1), Vs. Asarva Bethak, Asarva, Ahmedabad. Ahmedabad-380 016. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacv 6980 D .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri B. R. Popat, A.R. ""यथ" क" ओर से/Respondent By: Ms. Vasundhara Upmanya. Cit-D.R.

section 35D of the Act; and 2. Confirming the addition of Rs 22,59,10, 459/- made by the AO by treating the entire accounted cost of an immovable property as having been met out of unexplained sources and thereby treating the same as unexplained investment. While adjudicating this ground he ought to have inter alia appreciated the undisputed