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

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 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. 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

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

2) of section 92C, the arm's length price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely:— (a) comparable uncontrolled price method, by which,— (i) the price charged or paid for property transferred or services provided

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

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

In the result, the appeal is dismissed

92A are to be fulfilled, and only then the enterprises can be said to be associated enterprises. It is only when both of these conditions are fulfilled that these four companies and the assessee can be said to be associated enterprises. 33. The expression ‘person’, under section 2(31), has been defined to include (i)an individual, (ii) a Hindu

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

Section 14A of the Income-tax Act, 1961 ('the Act') by invoking Rule 8D of the Income-tax Rules, 1962. 38. The above grievance is not pressed by the assessee, on account of smallness of amount, and is dismissed as such. 39. Ground no. 2 is dismissed. 40. In ground no. 3, the assessee has raised the following grievance

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

Section 14A of the Income-tax Act, 1961 ('the Act') by invoking Rule 8D of the Income-tax Rules, 1962. 38. The above grievance is not pressed by the assessee, on account of smallness of amount, and is dismissed as such. 39. Ground no. 2 is dismissed. 40. In ground no. 3, the assessee has raised the following grievance

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

Section 14A of the Income-tax Act, 1961 ('the Act') by invoking Rule 8D of the Income-tax Rules, 1962. 38. The above grievance is not pressed by the assessee, on account of smallness of amount, and is dismissed as such. 39. Ground no. 2 is dismissed. 40. In ground no. 3, the assessee has raised the following grievance

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

2. The Ld. AO and Ld. Transfer Pricing Officer (TPO) erred in law and on facts, in disregarding the ALP determined by the Appellant and rejecting the methodical benchmarking analysis carried out by the Appellant in its Transfer Pricing Study Report using Resale Price Method (RPM) accordance with Section 920 and Section 920 of the Act read with Rule