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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for determining arm's length price (ALP) of international transactions Though TPO did not suggest any adjustment in his order, he suggested initiation of penalty proceedings under sections 271AA, 271G and 271BA on ground that assessee had not maintained prescribed TP documentation and did not furnish information requisitioned by TPO On basis of recommendation

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 officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G and\n271BA on ground that assessee had not maintained prescribed TP\ndocumentation and did not furnish information requisitioned by TPO\nOn basis of recommendation

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 officer (TPO) for\ndetermining arm's length price (ALP) of international transactions\nThough TPO did not suggest any adjustment in his order, he suggested\ninitiation of penalty proceedings under sections 271AA, 271G and\n271BA on ground that assessee had not maintained prescribed TP\ndocumentation and did not furnish information requisitioned by TPO\nOn basis of recommendation

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

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

Appeal is dismissed

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

transfer pricing has to be understood as per the clause (v) of section 92F, which is wider than the normal

THE DY. CIT., CIRCLE-4(1)(2),, AHMEDABAD vs. M/S. VISHAL FABRICS LTD.,, AHMEDABAD

In the result, the appeal preferred by the Revenue is dismissed

Bench: Shri Waseem Ahmed& Ms. Madhumita Roy

Transfer Pricing Officer (TPO) with the determination of Arms Length Price (ALP). The TPO under Section 92CA(3) of the Act on 30.10.2011 proposed upward adjustment of Rs. 8,90,32,096/- to the total income of the assessee including the transaction of sale of electricity by CPP to manufacturing unit which was revised down

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

Section 92F (iii) defines enterprise as a person including a permanent establishment of such person. A permanent establishment has been defined u/s 92F(iiia) as a fixed place of business through which the business of the enterprise is carried on. Accordingly, the Act itself considers a Permanent establishment as an enterprise. Therefore, all the dealings between the enterprise

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified

BGSCTPL- MSKEL (JV),AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-5(2)(1),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified

BGSCTPL- MSKEL CONSORTIUM,,AHMEDABAD vs. THE INCOME TAX OFFICER, WARD-10(1),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified

JMC-MSKE(JV),,AHMEDABAD vs. INCOME TAX OFFICER, WARD-5(2)(3),, AHMEDABAD

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

Bench: Us & That These Four

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified

THE TORRENT PHARMACEUTICALS LTD.,,AHMEDABAD vs. THE ACIT.,CIRCLE-8,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

92F(v) of the Act. 5.1 In view of the above the ld. CIT (A) dismissed the appeal of the assessee and confirmed the addition made by TPO/AO. Being aggrieved by order of TPO/AO, the assessee is in appeal before us. 6. Ld. AR before us filed a paper book-running form pages 1 to 253 and submitted that there

THE ACIT,(OSD)CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS LTD.,, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

92F(v) of the Act. 5.1 In view of the above the ld. CIT (A) dismissed the appeal of the assessee and confirmed the addition made by TPO/AO. Being aggrieved by order of TPO/AO, the assessee is in appeal before us. 6. Ld. AR before us filed a paper book-running form pages 1 to 253 and submitted that there

THE ACIT, CIRCLE-8,, AHMEDABAD vs. THE TORRENT PHARMACEUTICALS, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

92F(v) of the Act. 5.1 In view of the above the ld. CIT (A) dismissed the appeal of the assessee and confirmed the addition made by TPO/AO. Being aggrieved by order of TPO/AO, the assessee is in appeal before us. 6. Ld. AR before us filed a paper book-running form pages 1 to 253 and submitted that there

THE TORRENT PHARMACEUTICALS,AHMEDABAD vs. THE ADDITIONAL CIT, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

Bench: Shri Waseem Ahmed & Ms. Madhumita Roysl. Ita No(S) Asset. Appeal(S) By No(S) Year(S) Appellant Vs. Respondent Appellant Respondent 1. 907/Ahd/2012 2007-08 M/S. Torrent Add. Cit, Pharmaceuticals Ltd., Range – 8, Torrent House, Off. Ahmedabad. Ashram Road, Ahmedabad. Pan No. Aaact 5456 A 2. 938/Ahd/2012 2007-08 The Acit, M/S. Torrent Ahmedabad. Pharmaceuticals Ltd. Ahmedabad. 3. 1634/Ahd/2012 2008-09 M/S. Torrent The Acit, Pharmaceuticals Ltd. Ahmedabad Ahmedabad. 4. 1725/Ahd/2012 2008-09 The Acit M/S. Torrent Ahmedabad. Pharmaceuticals Ltd., Ahmedabad.

92F(v) of the Act. 5.1 In view of the above the ld. CIT (A) dismissed the appeal of the assessee and confirmed the addition made by TPO/AO. Being aggrieved by order of TPO/AO, the assessee is in appeal before us. 6. Ld. AR before us filed a paper book-running form pages 1 to 253 and submitted that there