DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE 1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order u/s.92CA(3) of the Act making an upward adjustment of Rs.1,54,77,374/- namely [a] on benchmarking of provision of services rendered to Associate Enterprise of Rs.67,96,987/- and [b] Corporate Guarantee given to AE of Rs.86,80,387/-. 2.2. As the assessee has not chosen to challenge the TPO’s order before Dispute Resolution

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

pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period of 180 days, resulting in an upward adjustment of Rs.14,64,47,827/-. It is not disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM

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

pricing adjustment made by the TPO and confirmed by the CIT(A) by imputing notional interest on receivables outstanding from AEs beyond a credit period of 180 days, resulting in an upward adjustment of Rs.14,64,47,827/-. It is not disputed that the assessee had benchmarked its international transactions of export of finished goods to AEs under the TNMM

DCIT CENTRAL CIRCLE 1(1), AHMEDABAD, GUJARAT vs. PRIYA BLUE INDUSTRIES PVT. LTD., GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order\nu/s.92CA(3) of the Act making an upward adjustment of\nRs.1,54,77,374/- namely\n[a] on benchmarking of provision of services rendered to\nAssociate Enterprise of Rs.67,96,987/- and\n[b] Corporate Guarantee given to AE of Rs.86,80,387/-.\n2. 2. As the assessee has not chosen to challenge the TPO's order

DEPUTY COMMISSIONER OF INCOME -TAX, CENTRAL CIRCLE-1(1), AHMEDABAD, AHMEDABAD vs. PRIYA BLUE INDUSTRIES PVT. LTD, GUJARAT

In the result the appeals filed by the Revenue in ITA No

Bench: Shri T.R. SENTHIL KUMAR, Judicial Member\nAnd Shri Narendra Prasad Sinha (Accountant Member)

Transfer Pricing Order\nu/s.92CA(3) of the Act making an upward adjustment of\nRs.1,54,77,374/- namely\n\n[a] on benchmarking of provision of services rendered to\nAssociate Enterprise of Rs.67,96,987/- and\n[b] Corporate Guarantee given to AE of Rs.86,80,387/-.\n\n2. 2. As the assessee has not chosen to challenge

BUNDY INDIA LIMITED,,VADODARA vs. THE DY. CIT., CIRCLE-1(1),, BARODA

In the result, Ground Number 6 of the assessee’s appeal is allowed for statistical purposes

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1403/Ahd/2016 िनधा"रण वष" /Assessment Year : 2009-10 Bundy India Limited The Dy.Cit बनाम/ Plot No.2, Circle-1(1) V/S. Gidc Industrial Estate, Baroda Makarpura Vadodaria - 390 010 "थायी लेखा सं./Pan: Aaacb 3039 M (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shree Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

section 144C(4) determining the total income at Rs. 8,57,52,857/-. In the assessment order, the Assessing Officer made various additions Bundy India Ltd. vs. DCIT Asst. Year : 2009-10 including transfer pricing adjustments amounting to Rs. 1,77

D S TRADING,AHMEDABAD vs. THE ITO, WARD-1(1)(1), AHMEDABAD

In the result, appeal of the assessee is allowed

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

transfer pricing adjustment of INR 2,80,66,728/- on account of benchmarking of export transaction to Associated Enterprises 1.1. On the facts and in the circumstances of the case and in law, the learned AO / Hon'ble DRP has erred in facts and circumstances of the case and in law, in re-computation of the arm's length price

ZYDUS LIFESCIENCES LTD.,AHMEDABAD vs. THE DY.CIT, CENTRAL CIRCLE-2(1), AHMEDABAD

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

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

price of a transaction and does not have the jurisdiction to examine the allowability of expenses as provided in section 37 of the Act. [Luwa India Pvt. Ltd (Karnataka High Court) (I.T. A.No.296 of 2017), Lumax Industries Limited (Delhi High Court) (ITA Nos. 102,103, 104 & 587/2014), Cushman and Wakefield (India) Pvt. Ltd. (Delhi High Cadila Healthcare

BOCK COMPRESSORS INDIA PRIVATE,BENGALURU vs. THE DY. CIT, CIRCLE - 1(1)(1), VADODARA

In the result, the appeal of the assessee is partly allowed

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarassessment Year 2020-21

Transfer Pricing Study Report using Resale Price Method (RPM) accordance with Section 920 and Section 920 of the Act read with Rule 10B, 10C and 10D of the Income-tax Rules, 1962 (the “Rules”) without providing the cogent reason. 3. The ld. AO., Ld. TPO and Ld. DRP erred in law and on facts in not appreciating that goods sold

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA vs. M/S SCHAEFFLER INDIA LTD, VADODARA

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

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2006-07 to 2009-10. Since common issues are involved in all these appeals, for the sake of convenience the same are disposed of by this common order. I.T.A Nos. 2017, 2018, 2019 & 2036/Ahd/2025 A.Ys

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA vs. M/S SCHAEFFLER INDIA LTD, VADODARA

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

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2006-07 to 2009-10. Since common issues are involved in all these appeals, for the sake of convenience the same are disposed of by this common order. I.T.A Nos. 2017, 2018, 2019 & 2036/Ahd/2025 A.Ys

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), VADODARA vs. M/S SCHAEFFLER INDIA LTD, VADODARA

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

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2006-07 to 2009-10. Since common issues are involved in all these appeals, for the sake of convenience the same are disposed of by this common order. I.T.A Nos. 2017, 2018, 2019 & 2036/Ahd/2025 A.Ys

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),VADODARA, VADODARA vs. M/S SCHAEFFLER INDIA LTD, VADODARA

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

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2006-07 to 2009-10. Since common issues are involved in all these appeals, for the sake of convenience the same are disposed of by this common order. I.T.A Nos. 2017, 2018, 2019 & 2036/Ahd/2025 A.Ys

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

77,87,586/- was declared. The return of income was filed on 23.11.2012 declaring loss of Rs.(-) 11,67,17,728/-. The return was duly processed under Section 143(1) of the Income Tax Act, 1961 and notice under Section 143(2) of the Act was issued on 06.08.2013 which was duly served upon the assessee. Notice under Section

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

77,87,586/- was declared. The return of income was filed on 23.11.2012 declaring loss of Rs.(-) 11,67,17,728/-. The return was duly processed under Section 143(1) of the Income Tax Act, 1961 and notice under Section 143(2) of the Act was issued on 06.08.2013 which was duly served upon the assessee. Notice under Section