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

1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill 2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

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

1 Transfer Pricing Adjustment on account of interest 15,18,41,720 on advances to AEs 2 Disallowance of Depreciation on Goodwill 2,27,92,50,000 3 Disallowance due to Allocation of Common 10,19,24,003 Expenses (Inter-unit allocation) 4 Disallowance under Section

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

1 to section 80-IA(4), infrastructure means a road, bridge, airport, port, inland waterways and inland ports, rail system etc., and the assessee is engaged in development of New defined u/s. 80-IA(4), and hence, the assessee is eligible for claim of deduction u/s. 80-IA(4) of the Act. Assessee submitted that the assessee has filed audit

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

1 to section 80-IA(4), infrastructure means a road, bridge, airport, port, inland waterways and inland ports, rail system etc., and the assessee is engaged in development of New defined u/s. 80-IA(4), and hence, the assessee is eligible for claim of deduction u/s. 80-IA(4) of the Act. Assessee submitted that the assessee has filed audit

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

1 to section 80-IA(4), infrastructure means a road, bridge, airport, port, inland waterways and inland ports, rail system etc., and the assessee is engaged in development of New defined u/s. 80-IA(4), and hence, the assessee is eligible for claim of deduction u/s. 80-IA(4) of the Act. Assessee submitted that the assessee has filed audit

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

1 to section 80-IA(4), infrastructure means a road, bridge, airport, port, inland waterways and inland ports, rail system etc., and the assessee is engaged in development of New defined u/s. 80-IA(4), and hence, the assessee is eligible for claim of deduction u/s. 80-IA(4) of the Act. Assessee submitted that the assessee has filed audit

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

transferred to a special reserve account and the same is actually utilised for the highway project excluding housing and other activities before the expiry of three years following the year in which such amount was transferred to the reserve account; and the amount remaining unutilised shall be chargeable to tax as income of the year in which such transfer

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

transferred to a special reserve account and the same is actually utilised for the highway project excluding housing and other activities before the expiry of three years following the year in which such amount was transferred to the reserve account; and the amount remaining unutilised shall be chargeable to tax as income of the year in which such transfer

THE DY.COMMISSIONER OF INCOME TAX, PATAN CIRCLE,, PATAN vs. AJAY ENGG. INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

transferred to a special reserve account and the same is actually utilised for the highway project excluding housing and other activities before the expiry of three years following the year in which such amount was transferred to the reserve account; and the amount remaining unutilised shall be chargeable to tax as income of the year in which such transfer

THE DY. CIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

transferred to a special reserve account and the same is actually utilised for the highway project excluding housing and other activities before the expiry of three years following the year in which such amount was transferred to the reserve account; and the amount remaining unutilised shall be chargeable to tax as income of the year in which such transfer

THE ACIT, PATAN CIRCLE,, PATAN vs. AJAY ENGINEERING INFRASTRUCTURE PVT. LTD.,, UNJHA

In the result appeal of the Revenue in ITA no

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

transferred to a special reserve account and the same is actually utilised for the highway project excluding housing and other activities before the expiry of three years following the year in which such amount was transferred to the reserve account; and the amount remaining unutilised shall be chargeable to tax as income of the year in which such transfer

SCHAEFFLER INDIA LTD. (FORMERLY KNOWN AS INA BEARING INDIA PVT. LTD.),VADODARA vs. THE ACIT, CICLE-1(1)(2) NOW DCIT, CIRCLE-1(1)(1), VADODARA

In the result, appeal of the assessee is allowed

Transfer Pricing Officer (TPO), made an upward\nadjustment of Rs. 17,15,40,000/-. This included Rs. 12,45,49,000/-\nrelating to manufacturing business and Rs. 4,69,91,000/- to the distribution\nsegment. Based on the TPO's order, the same amount was added to the\nassessee's returned income, and penalty proceedings under section\n271(1

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 1 1 , VADODARA, VADODARA vs. NETAFIM IRRIGATION INDIA PRIVATE LIMITED, VADODARA

In the result appeal filed by the Revenue in ITA No

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 92C of the Act prescribes the methods under which arm's length price can be computed. Rule 10B of the Rules lays down the mechanism for computation of arm's length price under I.T.A Nos. 2005 & 2006/Ahd/2025 A.Ys. 2012-13 & 2013-14 12 DCIT vs. Netafim Irrigation India Pvt. Ltd. different methods. As per rule

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