M/S. VISHAL ENGINEERS & GALVANIZERS,,AHMEDABAD vs. THE DY.CIT, CIRCLE-6,, AHMEDABAD

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

45(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)

Price in terms of the CBDT Instruction No. 03/2016 dated 10.03.2016 upon getting due approval from the Competent Authority by the then AO. Notice thereafter on 22nd July, 2017 under Section 143(2) of the Act, was issued and served upon the assessee. 4. Specific questionnaires were also issued from time-to-time and duly served upon the assessee alongwith

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 compliance efforts to reduce the disadvantage in staking their claim for tax. Higher risk of disputes may be reduced by the advance pricing agreements. On the same intentions and objects, the ld. TPO is also required to compute the ALP of the International transactions of the Assessee for this year. Therefore, the agreement entered into by CBDT with

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 compliance efforts to reduce the disadvantage in staking their claim for tax. Higher risk of disputes may be reduced by the advance pricing agreements. On the same intentions and objects, the ld. TPO is also required to compute the ALP of the International transactions of the Assessee for this year. Therefore, the agreement entered into by CBDT with

MEGHMANI ORGANICS LTD.,,AHMEDABAD vs. THE DCIT.,CENT.CIRCLE-1(1),, AHMEDABAD

In the result, assessee’s appeal is allowed for statistical purpose

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

4. At the time of the hearing of the instant appeal the Ld. Senior Counsel appearing for the assessee submitted before us that the issue is entirely covered in assessee’s own case by the judgment and order passed Meghmani Organics Ltd. vs. DCIT Asst.Year –2009-10 by the Co-ordinate Bench in favour of the assessee

THE ACIT, 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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, 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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. 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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

M/S. RAJKAMAL BUILDERS INFRASTRUCTURE PVT. LTD.,,AHMEDABAD vs. THE DCIT, 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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken

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

price escalation in respect of material, labour, which may be caused due to inflation and for these precise reason the assessee has suffered huge loss in the development of main projects as reflected in the materials placed before us. A look at these figures would carry the aspect of the financial risk involved in the various projects undertaken