THE DCIT, CIRCLE-6,, AHMEDABAD vs. VISHAL ENGINEERING & GALVANIZERS,, AHMEDABAD

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

4) stood immediately attracted. Accordingly, the Assessing Officer held, that the income earned on such transfer at the agreed price to the firm over and above the book value was liable to be taxed. On appeal, the Commissioner (Appeals) confirmed the order of the Assessing Officer on the ground that there was a transfer within the meaning of section

ZYDUS LIFESCIENCES LIMITED (FORMERLY KNOWN AS CADILA HEALTHCARE LTD.),AHMEDABAD vs. THE DCIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, appeal preferred by the assessee is allowed

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 162/Ahd/2021 ("नधा"रण वष" / Assessment Years : 2016-17)

transfer pricing order under Section 92CA(3) of the Act beyond the mandatory prescribed time limit as per Section 92CA(3A) r.w.s. 153(4

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

In the result, appeal filed by the assessee in ITA no

Bench: Us & That These Four

price as defined in clause (ii) of section 92F. (11) The Central Government may, after making such inquiry as it may think fit, direct, by notification in the Official Gazette, that the exemption conferred by this section shall not apply to any class of industrial undertaking or enterprise with effect from such date as it may specify in the notification

RANBAXY LABORATORIES LTD.,DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

Transfer Pricing ('TP') documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('Rules'); 2.2 not accepting the overseas Associated Enterprises ('AEs') as the tested party, being the least complex of the transacting entities and instead considering the appellant as the tested party, thus violating the basic principles

M/S. RANBAXY LABORATORIES LIMITED,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee in IT(TP) A No

Bench: Justice P.P. Bhatt & Shri Waseem Ahmed1. आयकर अपील सं./It(Tp)A No. 1782/Del/2014 2. आयकर अपील सं./It(Tp)A No. 781/Del/2015 ("नधा"रण वष"/Assessment Years : 2009-10 & 2010-11) Ranbaxy Laboratories Ltd. The Dcit बनाम/ 12Th Floor, Devika Tower Circle-21(1), New Vs. 6, Nehru Place, New Delhi Delhi/ 110 019 Addl.Cit Range-15 New Delhi "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacr0127N .. (अपीलाथ"/Appellant) (""यथ" / Respondent) अपीलाथ" ओर से/ Appellant By : Shri S.N.Soparkar, Shri Vartik Chokshi, Ms.Urvashi Shodhan & Shri P.Shah, Ars ""यथ" क" ओर से/Respondent By: Shri Mahesh Shah, Cit-Dr

Transfer Pricing ('TP') documentation maintained by it in terms of section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('Rules'); 2.2 not accepting the overseas Associated Enterprises ('AEs') as the tested party, being the least complex of the transacting entities and instead considering the appellant as the tested party, thus violating the basic principles

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ACIT, CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

THE DCIT, CIRCLE-3(1)(2),, AHMEDABAD vs. M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

THE ACIT, CIRCLE-5,, AHMEDABAD vs. M/S. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

THE DCIT, CIRCLE-5,, AHMEDABAD vs. RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE ACIT., CIRCLE-3(1)(2),, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE DY.CIT., CIRCLE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE ADDL.CIT., RANGE-5,, AHMEDABAD

In the result this ground of appeal preferred by the assessee is allowed

Bench: Shri (Dr.) Arjun Lal Saini & Ms. Madhumita Roy

prices of materials, cost of labourers, overhead expenses etc. and as a result whereof many times, the assessee has to incur heavy loss too in various projects. These facts clearly demonstrate that the financial and other risk, responsibility, obligations is undertaken by ITA.No.441/Ahd/2011 and 20 Others Rajkamal Builders Infrastructure P.Ltd. 8 the assessee in construction and development