INTAS PHARMACEUTICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1), 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

section 40(a)(ii) of the Act. We shall now proceed to adjudicate the assessee’s appeal issue-wise as under. Ground No. 1(i) - Transfer Pricing Adjustment on Interest on Advances to Associated Enterprises 5. The assessee had during the year under consideration advanced loans to its Associated Enterprises (AEs) in foreign currency aggregating Rs.5,85,87,394/-. These

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

section 40(a)(ii) of the Act. We shall now proceed to adjudicate the assessee’s appeal issue-wise as under. Ground No. 1(i) - Transfer Pricing Adjustment on Interest on Advances to Associated Enterprises 5. The assessee had during the year under consideration advanced loans to its Associated Enterprises (AEs) in foreign currency aggregating Rs.5,85,87,394/-. These

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ASHOKJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

SHRI ROHITJI CHANDUJI THAKOR,,AHMEDABAD vs. THE ITO, WARD-3(3)(1), AHMEDABAD

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

price of this block was at Rs.5,13,883/-. The assessee has purchased this block along other family members, and was having 1/6th share. The AO has made addition of Rs.5,13,883/- on account of unexplained investment in block no.77. Similarly, the assessee has made addition of Rs.4,48,378/- on account of unexplained deposits in the bank account

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

THE ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1) (1),, AHMEDABAD vs. M/S. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

INTAS PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INTAS PHARMACEUTICALS PVT. LTD.,, AHMEDABAD

Accordingly the claim of expenditure is allowed as revenue

Bench: Smt. Annapurna Gupta& Shri Siddhartha Nautiyal

transfer pricing adjustment is called for. ITA Nos. 1334 to 1336/Ahd/2017 & ITA Nos. 1644 to 1646/Ahd/2017 Intas Pharmaceuticals Ltd. vs. ACIT Asst. Years –2009-10 to 2011-12 11. Looking into the instant facts, we are of the considered view that Ld. CIT(A) has erred in holding that the advances given by the assessee to three

ASSTT. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), AHMEDABAD vs. MAHALAXMI INFRACONTRACT PRIVATE LIMITED, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 484, 485 & 486/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2015-16, 2017-18 & 2018-19) बनाम/ Assistant Commissioner Mahalaxmi Infracontract Of Income Tax Private Limited Vs. Central Circle-1(4), B-21, Corporate House, Ahmedabad Opp-Pakwan-Ii, S. G. Highway, Bodakdev, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagcm4615E (Appellant) .. (Respondent) Assessee By : Shri S. N. Divatia & Shri B. K. Patel, A.Rs. Shri Sudhendu Das, Cit. Dr Revenue By : सुनवाई क" तार"ख / Date Of 22/01/2024 & Hearing घोषणा क" तार"ख /Date Of 31/05/2024 Pronouncement

price of the charges received for transporting the goods from one place to another. This Fact of the case is totally and identically applicable to us as we are required to transport excavated earth as per instruction for filling etc purpase and the earth so transported does not belongs to us. Our contract is for hiring for motor vehicles (Dumpers

ASSTT. COMMISSIONER OF INCOME TAX, AHMEDABAD vs. MAHALAXMI INFRACONTRACT PRIVATE LIMITED, AHMEDABAD

Bench: Shri Ramit Kochar & Ms. Madhumita Royआयकर अपील सं./I.T.A. Nos. 484, 485 & 486/Ahd/2023 ("नधा"रण वष" / Assessment Years : 2015-16, 2017-18 & 2018-19) बनाम/ Assistant Commissioner Mahalaxmi Infracontract Of Income Tax Private Limited Vs. Central Circle-1(4), B-21, Corporate House, Ahmedabad Opp-Pakwan-Ii, S. G. Highway, Bodakdev, Ahmedabad "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aagcm4615E (Appellant) .. (Respondent) Assessee By : Shri S. N. Divatia & Shri B. K. Patel, A.Rs. Shri Sudhendu Das, Cit. Dr Revenue By : सुनवाई क" तार"ख / Date Of 22/01/2024 & Hearing घोषणा क" तार"ख /Date Of 31/05/2024 Pronouncement

price of the charges received for transporting the goods from one place to another. This Fact of the case is totally and identically applicable to us as we are required to transport excavated earth as per instruction for filling etc purpase and the earth so transported does not belongs to us. Our contract is for hiring for motor vehicles (Dumpers