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

Bench: Shri Pramod Kumar& Ms. Madhumita Roy

73, Block No.404/428/429, Ahwamegh Industrial Estate, Changodar, Tal: Sanand, Ahmedabad – 382 213. (PAN NO. AAEFV 9722 A) 2. CO No.271/Ahd/2014 2011-12 Vishal DCIT, (in ITA No.2316/Ahd/2014) Engineering Circle – 6, Ahmedabad. & Galvanizers. 3. 2008-09 --do-- --do-- 4. 2008-09 The ACIT Vishal Engineering & Circle – 3(2), Galvanizers, Ahmedabad. ` Appellant by : Shri N. R. Soni, CIT-D.R. Respondentby: Shri

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 adjustment of Rs.39,94,66,330/- in assessee’s ITA No. 162/Ahd/2021 (Zydus Lifesciences Ltd. vs. DCIT) A.Y.– 2016-17 - 4 – own case was made in A.Y.2013-14 and the said adjustment was made above Rs.10 Crores, the appeal whereof was pending. In that view of the matter, a reference under Section 92CA of the Act was made

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

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

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

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion

RAJKAMAL BUILDER INFRASTRUCTURE PVT. LTD,,AHMEDABAD vs. THE JT.CIT.,(OSD)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

transfer. Thus, the assessee does not satisfy this condition. Over and above, the assessee company had not entered into agreement with Ahmedabad Municipal Corporation for development of the above project but had obtained the work order for execution of contract as per terms and condition of the Ahmedabad Municipal Corporation. The assessee was allotted the work for execution and completion