LAXMI HYDROCOLLOIDS,AHMEDABAD vs. ITO, WARD-3(2)(8), AHMEDABAD

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedआयकर अपील सं./Ita No. 416/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2014-2015 Laxmi Hydrocolloids, I.T.O., Plot No.104, Vs. Ward-3(2)(8), Devraj Industrial Estate, Ahmedabad. Piplej Pirana Road, Ahmedabad-380022. Pan: Aaefl2440D

9) of section 1 OB. hi the matter of General Finance Co. v. ACIT, which judgment has also been taken note of by the tribunal while repelling the contention raised by revenue with regard to retrospectively of section 92-BA (i) of the Act. Thus, when clause (i) of section 92-BA having been omitted by the Finance

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

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

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

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-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

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

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-4,, AHMEDABAD vs. GUJARAT GAS TRADING CO. LTD.,, AHMEDABAD

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

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

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

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

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

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(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

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-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

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. 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 ('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

Transfer 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. 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

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

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

9(1)(2)]. The issuance of guarantees is not within the ambit of transfer pricing in United States because it is a service but because it is covered by the specific definition discussed above. As a matter of fact, David S Miller, in a paper titled 'Federal Income Tax Consequences of Guarantees; A Comprehensive Framework for Analysis' published

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

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