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 price of international transaction either at the time of setting them or by way of adjusting them subsequent to entering into the international transaction to align them to the arm's length price. This is a condition precedent for user of the multiple year financial data. Reliance is placed on the following decisions:- AZTEC Software

M/S. TBEA SHENYANG TRASFORMER GROPUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

In the result, the appeal filed by the assessee is dismissed

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleआयकर अपील सं./I.T.A. No. 581/Ahd/2017 (िनधा"रण वष" / Assessment Year : 2012-13) बनाम/ M/S. Tbea Shenyang Deputy Commissioner Of Transformer Group Income Tax Vs. Company Limited International Taxation, National Highway No.-8, Vadodara Villae : Miyagam, Karja, Vadodara, Gujarat - 390007 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadct4557F (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Arpit Jain, Ar ""यथ" क" ओर से/Respondent By : Shri Mahesh Shah, Cit. Dr 24/04/2025 Date Of Hearing Date Of Pronouncement 22/07/2025 O R D E R Per Smt. Annapurna Gupta, Am:

transfer pricing provision to transaction between a Foreign Enterprise and its Indian PE, the issue was referred to the Special Bench which has answered the question posed to it vide order dated 11.11.2024. 18. Having said so, the argument now raised before us by the Ld. Counsel for the assessee was that the Special Bench had not definitely answered

THE DY. CIT, CIRCLE-2(1)(1), ,, AHMEDABAD vs. M/S. HAZIRA LNG PRIVATE LIMITED,, AHMEDABAD

In the result, the appeal is dismissed

Transfer Pricing Guidelines] 25. As for the point regarding the assessee being a full risk distributor, and for that reason RPM should not apply, we are unable to see merits in this approach either. Firstly, the TPO has not adopted any alternate approach, which is sustainable in law and which is more appropriate than the approach of the assessee. Secondly

LONSEN KIRI CHEMICAL INDUSTRIES LTD.,,AHMEDABAD vs. THE DY.CIT, (OSD)-1, CIRCLE-4,, AHMEDABAD

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

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

section 92A of the Act. Once the comparable company becomes the AE of the assessee in the year under consideration, then such company cannot be considered for the purpose of comparable. In holding so we place our reliance on the order of this tribunal in the case of Gemstone Glass Pvt Ltd. reported in 63 taxmann.com 1 wherein

M/S. VENUS INFRASTRUCTURE & DEVELOPERS PVT. LTD.,,AHMEDABAD vs. THE DCIT, (OSD) CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./Ita No. 1582/Ahd/2019 िनधा"रण वष"/Asstt. Year: 2012-2013 M/S. Venus Infrastructure & D.C.I.T.,(Osd) Developers (P) Ltd., Vs. Central Circle-8, 801-802, Broadway Business Ahmedabad. Centre, Opp. Mayor’S Bungalow, Law Garden Ellisbridge, Ahmedabad. Pan: Aahcs6254J

92A(2)(d) ITA Nos.1582 & 1568/Ahd/2019 A.Y. 2012-13 14 of the Act. Thus the transaction of brokerage was to be benchmarked to justify the arm length price. Accordingly, the auditor of the assessee advised to submit transfer pricing study as per section

THE DCIT(INTL. TAXN),,, AHMEDABAD vs. M/S. SHANDONG TIEJUN ELECTRIC POWER ENGG. COMPANY LTD., KUTCH

In the result, all three appeals of the Revenue are dismissed

Bench: Shri Rajpal Yadav & Shri T. S. Kapoor

transfer pricing provisions are applicable between the foreign company i.e. HO and its PE, by observing as follows:- "7.5.2 I am unable to agree with the contentions of the appellant that the transactions between head office of the appellant company and its PE in India need not be considered as international transaction. I find that the project office

INDUCTOTHERM (INDIA) PRIVATE LTD.,AHMEDABAD vs. THE JT.CIT.,RANGE-4,, AHMEDABAD

In the result, the assessee’s appeal for the assessment year 2011-12 is also partly allowed in the terms indicated above

Transfer Pricing Officer, it was noticed that the assessee has paid royalty ITA Nos.3108/A/2010, 2609/A/2012, 671/A/2014, 243/A/2015 & 370/A/2016 AYs: 2006-07, 2008-09, 2009-10, 2010-11 & 2011-12 Page 19 of 31 to its parent company, i.e. Inductotherm Industries Inc USA (III, in short), aggregating to Rs 8,48,05,337. This was computed @ 5% in respect of domestic

INDUCTOTHERM (INDIA) PRIVATE LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-2(1)(1),, AHMEDABAD

In the result, the assessee’s appeal for the assessment year 2011-12 is also partly allowed in the terms indicated above

Transfer Pricing Officer, it was noticed that the assessee has paid royalty ITA Nos.3108/A/2010, 2609/A/2012, 671/A/2014, 243/A/2015 & 370/A/2016 AYs: 2006-07, 2008-09, 2009-10, 2010-11 & 2011-12 Page 19 of 31 to its parent company, i.e. Inductotherm Industries Inc USA (III, in short), aggregating to Rs 8,48,05,337. This was computed @ 5% in respect of domestic

INDUCTOTHERM (INDIA) PRIVATE LTD.,AHMEDABAD vs. THE DY.CIT.,CIRCLE-4,, AHMEDABAD

In the result, the assessee’s appeal for the assessment year 2011-12 is also partly allowed in the terms indicated above

Transfer Pricing Officer, it was noticed that the assessee has paid royalty ITA Nos.3108/A/2010, 2609/A/2012, 671/A/2014, 243/A/2015 & 370/A/2016 AYs: 2006-07, 2008-09, 2009-10, 2010-11 & 2011-12 Page 19 of 31 to its parent company, i.e. Inductotherm Industries Inc USA (III, in short), aggregating to Rs 8,48,05,337. This was computed @ 5% in respect of domestic

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