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

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

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

transfer pricing adjustment of Rs.60,83,440/- pertaining to corporate guarantee fee; as made by the TPO and affirmed in dispute resolution penal; "DRP"s directions. The said lower authorities hold that the assessee ought to have charged @1.24% on corporate guarantee amount of Rs.49,06,00,000/-. The assessee admittedly had provided the corporate guarantee in question

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

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

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

transfer pricing adjustment of Rs.60,83,440/- pertaining to corporate guarantee fee; as made by the TPO and affirmed in dispute resolution penal; "DRP"s directions. The said lower authorities hold that the assessee ought to have charged @1.24% on corporate guarantee amount of Rs.49,06,00,000/-. The assessee admittedly had provided the corporate guarantee in question

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY.COMMISSIONER OF INCOME TAX,CIRCLE-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

AMBALAL SARABHAI ENTERPRISES LIMITED,,BARODA vs. THE ACIT.,CIRCLE-1(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

AMBALAL SARABHAI ENTERPRISES LTD.,,BARODA vs. THE DY. COMMISSIONER OF INCOME TAX-1(1)(1),, BARODA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

THE DY.COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA vs. AMBALAL SARABHAI ENTERPRISES LIMITED,, VADODARA

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43B on account of employees’ contribution of PF in ITA No. 1290/Ahd/2016 for A.Y. 204-05. The decision of Hon’ble Jurisdictional High Court in case of CIT -II Vs. Gujarat State Road Transport Corporation [2014] 41 taxmann.com 100 is against the assessee on this issue and the AR has conceded the same before us. Hence, the ground

SCHAEFFLER INDIA LIMITED,VADODARA, GUJARAT vs. ASSISTANT DIRECTOR OF INCOME TAX,CPC, BANGALORE (JAO-DEPUTY COMMISSIONER OF INCOME TAX CIRCLE1(1)(1), VADODARA, GUJARAT

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

SCHAEFFLER INDIA LTD.(A SUCCESSOR OF LUK INDIA PVT. LTD)),VADODARA vs. THE ACIT, CIRCLE-1(1)(1) (EARLIER ACIT, CIRCLE-1, HOSUR), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

THE ACIT, CIRCLE-1(1)(1), VADODARA vs. SCHAEFFLER INDIA LTD.( ERSTWHILE LUK INDIA PVT. LTD)), VADODARA

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

Transfer Pricing Adjustment in respect of aforesaid services and accepted the payment of Management Fees to be at Arm’s Length Price. Further, we also observe that Ld. CIT(A) has made a detailed comparison between the decision rendered by ITAT, Pune Bench in the case of a group company (INA Bearings) in respect of management services and after

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

transfer pricing adjustment on corporate guarantee provided by Appellant to its AE's amounting to Rs. 39,48,000/-. 5.2 The Assessing Officer as well as Ld. CIT(A), by confirming the addition on account of corporate guarantee provided to AE, have grossly erred in disregarding the directions given by the Hon'ble Tribunal that the issue

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

transfer pricing adjustment on corporate guarantee provided by Appellant to its AE's amounting to Rs. 39,48,000/-. 5.2 The Assessing Officer as well as Ld. CIT(A), by confirming the addition on account of corporate guarantee provided to AE, have grossly erred in disregarding the directions given by the Hon'ble Tribunal that the issue

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

transfer pricing adjustment on corporate guarantee provided by Appellant to its AE's amounting to Rs. 39,48,000/-. 5.2 The Assessing Officer as well as Ld. CIT(A), by confirming the addition on account of corporate guarantee provided to AE, have grossly erred in disregarding the directions given by the Hon'ble Tribunal that the issue

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), VADODARA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

Appeal is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

transfer pricing adjustment on corporate guarantee provided by Appellant to its AE's amounting to Rs. 39,48,000/-. 5.2 The Assessing Officer as well as Ld. CIT(A), by confirming the addition on account of corporate guarantee provided to AE, have grossly erred in disregarding the directions given by the Hon'ble Tribunal that the issue

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

Appeal is dismissed

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarsn

transfer pricing adjustment on corporate guarantee provided by Appellant to its AE's amounting to Rs. 39,48,000/-. 5.2 The Assessing Officer as well as Ld. CIT(A), by confirming the addition on account of corporate guarantee provided to AE, have grossly erred in disregarding the directions given by the Hon'ble Tribunal that the issue