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36 results for “transfer pricing”+ Section 928clear

Sorted by relevance

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Key Topics

Section 143(3)32Addition to Income31Section 115J24Disallowance24Deduction20Section 14A19Section 271(1)(c)16Section 4013Section 80I

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

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

ITA 1519/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2011-12

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

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

transferred to its AE indirectly which amount to transfer of unique intangibles. Therefore, the profit split method will be appropriate method to determine ALP because assessee was not just manufacturer of the product. The AO/TPO further found that learned CIT(A) for AY 2008-09 while upholding the Profit Split Method taken the profit sharing ratio at 80:20 between

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

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

Showing 1–20 of 36 · Page 1 of 2

12
Penalty12
Natural Justice10
Section 43B9
ITA 1520/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2013-14

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

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

transferred to its AE indirectly which amount to transfer of unique intangibles. Therefore, the profit split method will be appropriate method to determine ALP because assessee was not just manufacturer of the product. The AO/TPO further found that learned CIT(A) for AY 2008-09 while upholding the Profit Split Method taken the profit sharing ratio at 80:20 between

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

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

ITA 1462/AHD/2018[2011-12]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2011-12

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

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

transferred to its AE indirectly which amount to transfer of unique intangibles. Therefore, the profit split method will be appropriate method to determine ALP because assessee was not just manufacturer of the product. The AO/TPO further found that learned CIT(A) for AY 2008-09 while upholding the Profit Split Method taken the profit sharing ratio at 80:20 between

SUN PHARMACEUTICALS INDUSTRIES LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1)(1), BARODA

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

ITA 1463/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2013-14

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

For Appellant: Advocate & Shri Parin Shah
Section 10Section 115JSection 28

transferred to its AE indirectly which amount to transfer of unique intangibles. Therefore, the profit split method will be appropriate method to determine ALP because assessee was not just manufacturer of the product. The AO/TPO further found that learned CIT(A) for AY 2008-09 while upholding the Profit Split Method taken the profit sharing ratio at 80:20 between

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 2114/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2013-14

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 2276/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2011-12

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

DY.COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 3470/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2010-11

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

LAMBDA THERAPEUTIC RESEARCH LTD.,,AHMEDABAD vs. DCIT CIRCLE-2(1) (2),, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 1751/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2013-14

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

LAMBDA THERAPEUTIC RESEARCH LIMITED,,AHMEDABAD vs. THE JT. CIT, RANGE-4,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 3492/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2010-11

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

THE DCIT, CIRCLE-2(1)(2),, AHMEDABAD vs. M/S. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result the appeal of the assessee is partly allowed

ITA 2293/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad12 Apr 2021AY 2011-12

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

For Appellant: Shri Tushar P. HemaniSr. Advocate withShriParimalSinhParmar, A.RFor Respondent: Shri Mohd Usman, CIT. D.R with Shri Lalit P. Jain. Sr. D.R
Section 115JSection 234ASection 271(1)(c)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at " 26,19,740/- whereas the amount of gross receipt generated by the assessee ITA No.3492/Ahd/2015 and 5 others A.Y. 2010-11 stands at USD 1,556,230 which is far more than the interest expenses after

LAMBDA THERAPEUTIC RESEARCH LTD.,,AHMEDABAD vs. DCIT CIRCLE-2(1) (2),, AHMEDABAD

In the result appeal of the Revenue is partly allowed

ITA 91/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad29 Apr 2022AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.91/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2012-2013 Lambda Therapeutic Research Ltd. D.C.I.T., Lambda House, Vs. Circle-2(1)(2), Opp. Gujarat High Court, Ahmedabad. S.G. Highway, Gota, Ahmedabad-382481. Pan: Aaacl4089R

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsingh B ParmarFor Respondent: Shri Purushottam Kumar, Sr.D.R
Section 2Section 234ASection 271Section 36Section 36(1)(va)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at ₹ 26,19,740/- whereas the amount of gross receipt generated by the assessee stands at USD 1,556,230 which is far more than the interest expenses after converting in India rupees. 10.8 Likewise, we also

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. LAMBDA THERAPEUTIC RESEARCH LTD.,, AHMEDABAD

In the result appeal of the Revenue is partly allowed

ITA 409/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad29 Apr 2022AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.91/Ahd/2018 िनधा"रण वष"/Asstt. Year: 2012-2013 Lambda Therapeutic Research Ltd. D.C.I.T., Lambda House, Vs. Circle-2(1)(2), Opp. Gujarat High Court, Ahmedabad. S.G. Highway, Gota, Ahmedabad-382481. Pan: Aaacl4089R

For Appellant: Shri Tushar Hemani, Sr. Advocate with Shri Parimalsingh B ParmarFor Respondent: Shri Purushottam Kumar, Sr.D.R
Section 2Section 234ASection 271Section 36Section 36(1)(va)

transfer pricing adjustment with the benefit derived by the assessee, the interest cost appears to be negligible. The amount of interest cost stands at ₹ 26,19,740/- whereas the amount of gross receipt generated by the assessee stands at USD 1,556,230 which is far more than the interest expenses after converting in India rupees. 10.8 Likewise, we also

GUJARAT FLUROCHEMICALS LIMITED.,,VADODARA vs. THE ACIT, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

ITA 2744/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2013-14

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

price that such goods or services will ordinarily fetch in the open market. To our mind sum of Rs. 4.51 per unit of electricity only represented cost of electricity generation to the assessee and not the market value thereof. It is not in dispute that the GEB charged Rs. 5 per unit for supplying electricity to other industries including

GUJARAT FLUOROCHEMICALS LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1),, VADODARA

In the result, both appeals of the assessee are partly allowed

ITA 805/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad03 Aug 2018AY 2012-13

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.805/Ahd/2017 "नधा"रण वष"/Asstt. Year: 2012-2013 & Asst.Year : 2013-2014

For Appellant: Shri S.N. Soparkar and Shri Parin Shah, ARFor Respondent: Shri O.P. Vaishnav, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

price that such goods or services will ordinarily fetch in the open market. To our mind sum of Rs. 4.51 per unit of electricity only represented cost of electricity generation to the assessee and not the market value thereof. It is not in dispute that the GEB charged Rs. 5 per unit for supplying electricity to other industries including

INEOS STYROLUTION INDIA LIMITED,VADODARA vs. THE DY.CIT, CIRCLE-1(1)(1), VADODARA

In the result, this ground of the assessee’s appeal is dismissed

ITA 330/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad11 Oct 2022AY 2018-19

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Ajit Kumar Jain, Ms. Sonal PandeyFor Respondent: Shri Alok Kumar, CIT DR
Section 143(3)Section 153Section 156Section 92CSection 92C(3)

Transfer Pricing Officer 3. On the facts and circumstances of the case and in law, the reference made to TPO u/s 92CA(1) of the Act is bad in law as it violates the provisions of that section. Consequently, the draft assessment order and final assessment order are bad in law and deserves to be quashed. 4. On the facts

SUN PHARMACEUTICALS INDUSTRIES LTD.,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

ITA 928/AHD/2017[2008-09]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2008-09

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

For Appellant: Shri S. N. Soparkar, Sr
Section 10BSection 115JSection 14ASection 271(1)(c)

transfer pricing report in Form 3CEB and notes to computation, hence no penalty ought to have been levied. ITA No. 928 & 921/Ahd/2017 [Sun Pharma Laboratories Ltd.] A.Y. 2008-09 - 5 - 3. Re: Levy of penalty on alleged addition for the profit on supply of Pantoprazole drug to Associated Enterprises amounting

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1),, BARODA vs. M/S. SUN PHARMACEUTICALS INDUSTRIES LIMITED,, VADODARA

In the result, the appeal of the Revenue is hereby partially allowed for statistical purposes

ITA 921/AHD/2017[2008-09]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2008-09

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

For Appellant: Shri S. N. Soparkar, Sr
Section 10BSection 115JSection 14ASection 271(1)(c)

transfer pricing report in Form 3CEB and notes to computation, hence no penalty ought to have been levied. ITA No. 928 & 921/Ahd/2017 [Sun Pharma Laboratories Ltd.] A.Y. 2008-09 - 5 - 3. Re: Levy of penalty on alleged addition for the profit on supply of Pantoprazole drug to Associated Enterprises amounting

CADILA PHARMACEUTICALS LTD. ,AHMEDABAD vs. THE ASST. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 54/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Section 143(3)Section 147Section 148Section 14ASection 35Section 36(1)(iii)Section 36(1)(vii)Section 37(1)Section 80I

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2),, AHMEDABAD vs. M/S. CADILA PHARMACEUTICALS LTD. , AHMEDABAD

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 1867/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2011-12

Section 143(3)Section 147Section 148Section 14ASection 35Section 36(1)(iii)Section 36(1)(vii)Section 37(1)Section 80I

Transfer Pricing addition :Rs. 60,83,440/- ii. Disallowance u/s 36(1)(iii) :Rs. 1,68,88,558/- iii. Disallowance u/s 35(2AB) :Rs. 3,82,99,313/- iv. Disallowance u/s 14A :Rs. 55,64,491/- v. Disallowance of deduction u/s 80IB :Rs.16,34,58,692/- vi. Disallowance of Foreign Currency Loss :Rs.25,39,60,000/- vii. Inadmissible expense

INCOME TAX OFFICER, WARD - 3(3)(5), AHMEDABAD, PANJARAPOLE, AHMEDABAD vs. VIKASH MORE, BODAKDEV, AHMEDABAD

In the result, appeal filed by the Revenue is dismissed

ITA 1036/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad14 Feb 2025AY 2016-17

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2016-17

Section 10(38)Section 115BSection 142(1)Section 144BSection 147Section 148Section 69ASection 69C

928/- as claimed as LTCG and the same was claimed as exempt income under Section 10(38) of the Act. The Ld. DR submitted that the Assessing Officer rightly made addition under Section 69A of the Act as the assessee could not establish the sale consideration received by the assessee on transfer of shares and of M/s. Kushal Tradelink