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

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 ASSTT. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM LTD.,, AHMEDABAD

In the result, revenue’s appeal is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfil the scope set therein by the virtue of this addendum. (b)This commission is over the above the commission payable by Welspun to Global

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE ACIT, CIRCLE-4,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

THE DCIT, CIRCLE-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

GUJARAT GAS TRADIANG CO.LTD.,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-4(1),, AHMEDABAD

In the result, the appeal of the assessee is partly allowed for statistical purposes

50 SOT ITA Nos. 2371& 2394/Ahd/2013, ITA Nos. 363, 364, 467 & 468/Ahd/2014 Assessee : Gujarat Gas Trading Co Ltd Assessment Year : 2007-08 to 2009-10 Page 7 of 37 268 (Mum.)) wherein the proposition laid down is that merely because the foreign selling agent has provided procurement services, it would not fall under the category of "managerial services

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over the above the commission payable by Welspun to Global

THE DCIT, CIRCLE-1(1)(2), BARODA vs. INOX INDIA PRIVATE LTD.,, VADODARA

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Prasad, Judicial Memebr & Shri Waseem Ahmed, Accountant Memebr

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over the above the commission payable by Welspun to Global

M/S. INOX INDIA LTD.,,BARODA vs. THE PR. CIT-1,, VADODARA

In the result, the appeal is allowed

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over the above the commission payable by Welspun to Global

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. INDO COLCHEM PVT. LTD.,, AHMEDABAD

In the result, the appeal is dismissed

price for the GK 3 project equal to: ACIT Vs. Indo Colchem Pvt Ltd Assessment Year : 2014-15 Page 12 of 29 (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfil the scope set therein by the virtue of this addendum

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax From The Payments Made To M/S. Urja International, Usa Which Proves That The

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over the above the commission payable by Welspun to Global

M/S. PANASONIC ENERGY INDIA CO.LTD,VADODARA vs. THE PR. CIT-2,, BARODA

In the result, the appeal is allowed

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last M/s. Panasonic Energy Inddia Co Ltd vs. Pri. CIT Assessment year: 2009-10 Page 9 of 24 (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue

KARNAVATI ENGINEERING LTD.,,AHMEDABAD vs. THE DEPUTY COMMISSIONER OF INCOME TAX (OSD) CIRCLE-4,, AHMEDABAD

In the result, the appeal is allowed in the terms indicated above

price for the GK 3 project equal to: Assessment Year: 2010-11 Page 12 of 27 (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over

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

Section 92B. As for the postamendment law and the impact of amendment in the definition of 'international transaction', the matter was again decided in favour of the assessee by Bharti Airtel Ltd. decision (supra) on the peculiar facts of that case. The Meghmani Organics Ltd. vs. DCIT Asst.Year –2009-10 decisions like Everest Kento Cylinders Ltd. (supra) and Aditya Birla

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. ASTRAL PHARMACEUTICALS INDUSTRIES,, BARODA

In the result, appeal, the appeal and cross-objection, both are dismissed

Bench: The Ao U/S 195(2) Of The Act, Though It Was Obligation Of The Assessee. 3. The Ld. Cit(Appeals) Erred In Law In Allowing The Claim Of The Assessee Without Appreciating The Fact That Assessee Itself Has Deducted Service Tax

price for the GK 3 project equal to: (i) 4.10% of the FOB Mill value in U.S. Dollar for the quantity shipped is last (18") Shipment. (a) GLOBAL SYNERGY INTERNATIONAL LTD agrees to unconditionally to fulfill the scope set therein by the virtue of this addendum. (b) This commission is over the above the commission payable by Welspun to Global

SUN PHARMACEUTICALS INDUSTRIES LTD. ( ERSTWHILE RANBAXY LABORATORIES LIMITED),BARODA vs. THE ACIT,CENT.CIRCLE-1, BARODA

50,980/-. The case was selected for scrutiny through CASS and notice u/s. 143(2) of the Act was issued on 6th August, 2012. The assessee was having international transaction with associated enterprise as per form 3CEB report. Therefore, the case was referred to the transfer pricing officer and the TPO had passed order u/s. 92CA