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50 results for “transfer pricing”+ Survey u/s 133Aclear

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Key Topics

Addition to Income41Disallowance26Section 14724Section 133A21Survey u/s 133A21Section 26319Section 13214Natural Justice14Section 153C12Section 153A

SUN PHARMACEUTICALS INDUSTRIES LTD.,,BARODA vs. THE ACIT, CENTRAL CIRCLE-1, BARODA

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

ITA 1659/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad20 Jun 2019AY 2008-09

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy1. आयकर अपील सं./Ita No.1659/Ahd/2015 2. आयकर अपील सं./Ita No.1689/Ahd/2015 ("नधा"रण वष"/Assessment Year : 2008-09 ) बनाम/ 1. Sun Pharmaceuticals 1. The Acit Industries Ltd. Cen.Cir-1 Vs. “Sparc” Tandalja Baroda – 20 2. The Acit 2. Sun Pharmaceu- Central Circle-1 Ticals Industries Baroda Ltd. Baroda. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcs 3124K (अपीलाथ"/Appellant) (""यथ" / Respondent) .. अपीलाथ" ओर से/ Appellant By : Shri S.N. Soparkar, Ar ""यथ" क" ओर से/Respondent By: Shri R.C. Panday, Cit-Dr सुनवाई क" तार"ख/ Date Of Hearing 28/03/2019 घोषणा क" तार"ख /Date Of Pronouncement 20/06/2019 आदेश / O R D E R Per Waseem Ahmed: The Captioned Cross-Appeals Have Been Filed At The Instance Of The Assessee & Revenue Against The Order Of The Commissioner Of Income Tax (Appeals)–2, Vadodara [Cit(A) In Short] Vide Appeal No.Cab/(A)- 2/387/2014-15 Dated 31/03/2015 Arising In The Assessment Order Passed Under S.143(3) R.W.S.147 Of The Income Tax Act, 1961(Hereinafter Referred To As "The Act") Dated 14/02/2014 Relevant To Assessment Year (Ay) 2008-09. Ita Nos.1659/Ahd/2015 (By Assessee) & Ita No.1689/Ahd/2015 (By Revenue) Sun Pharmaceuticals Industries Ltd. Vs. Acit Asst.Year - 2008-09 2

For Appellant: Shri S.N. Soparkar, ARFor Respondent: Shri R.C. Panday, CIT-DR
Section 143(3)Section 147Section 148

Showing 1–20 of 50 · Page 1 of 3

12
Penalty12
Section 139(1)11
Section 40A(2)(b)

133A of the Act on 08.11.2011 at the six business premises of the assessee located at Mumbai. 6. During the survey, a large number of incriminating documents (master formula, executive summary, master formula card, etc.) were found and impounded. Thus based on the survey report the case was reopened by issuing a notice u/s 148 of the Act dated 28/03/2013

THE DCIT, CIRCLE-8,, AHMEDABAD vs. SAMBHAV INFRASTRUCTURE PVT. LTD.,, AHMEDABAD

In the result, appeal of the Revenue is allowed

ITA 1818/AHD/2015[2012-13]Status: DisposedITAT Ahmedabad05 Jan 2022AY 2012-13

Bench: Shri Rajpal Yadav, Vice- & Shri Waseem Ahmedआयकर अपील सं./ Ita No.1818/Ahd/2015 "नधा"रण वष"/Asstt. Year: 2012-13 Dcit, Cir.4(1)(1) Vs. Sambhav Infrastructure P.Ltd. Ahmedabad. B-12, Amar Aprtment Vasna Barrage Road Vasna, Ahmedabad. Pan : Aakcs 5194 C

For Appellant: NoneFor Respondent: Shri Mohd Usman,CIT-DR
Section 133ASection 143(2)

u/s. 133A of the IT. Act. 2) The CIT(A) has erred in law and on facts by holding that the profits can only be taxed on unaccounted receipts in place of entire unaccounted receipts, in absence of any claim of unaccounted expenses by the assessee and also having deposited the majority of the unaccounted receipts in its bank account

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

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 provisions is required to be made with respect to the interest free loans and advances by the assessee to its associated enterprises in the given facts and circumstances. Hence, the ground of appeal of the assessee is allowed and the ground of appeal of the revenue is dismissed. 11. The next issue raised by the assessee in ground

JAS INFRASPACE PVT. LTD.,AHMEDABAD vs. DCIT, CIRCLE-2(2)(1),, AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 398/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2014-15

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 131Section 133ASection 150Section 292CSection 34Section 69B

u/s 68 of the IT Act the advance from Sundry debtors where the identity, creditworthiness of the parties could not be proved and genuineness of the transaction could not be established. 2.1 The Ld. CIT(A) has erred in law and on facts by holding that section 68 did not apply to the advances received for alleged sale of land

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRASPACE PRIVATE LIMITED,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 547/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2014-15

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 131Section 133ASection 150Section 292CSection 34Section 69B

u/s 68 of the IT Act the advance from Sundry debtors where the identity, creditworthiness of the parties could not be proved and genuineness of the transaction could not be established. 2.1 The Ld. CIT(A) has erred in law and on facts by holding that section 68 did not apply to the advances received for alleged sale of land

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRA SPACE PRIVATE LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 2131/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2013-14

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 131Section 133ASection 150Section 292CSection 34Section 69B

u/s 68 of the IT Act the advance from Sundry debtors where the identity, creditworthiness of the parties could not be proved and genuineness of the transaction could not be established. 2.1 The Ld. CIT(A) has erred in law and on facts by holding that section 68 did not apply to the advances received for alleged sale of land

THE ACIT, CIRCLE-2(1)(2),, AHMEDABAD vs. JAS INFRA SPACE PRIVATE LTD.,, AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 2130/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad28 Jan 2022AY 2012-13

Bench: Shri Rajpal Yadav & Shri Waseem Ahmed

Section 131Section 133ASection 150Section 292CSection 34Section 69B

u/s 68 of the IT Act the advance from Sundry debtors where the identity, creditworthiness of the parties could not be proved and genuineness of the transaction could not be established. 2.1 The Ld. CIT(A) has erred in law and on facts by holding that section 68 did not apply to the advances received for alleged sale of land

MEHAAN ENTERPRISE,AHMEDABAD vs. THE PCIT, CENTRAL, AHMEDABAD

In the result, the appeal of the assessee is dismissed

ITA 789/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad27 Mar 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra Kamble

For Appellant: Shri M S Chhajed, ARFor Respondent: Shri R P Rastogi, CIT-DR
Section 132Section 133ASection 143(1)Section 153CSection 153DSection 263Section 68

survey u/s 133A was conducted on 24.04.2019 in the case of Rajyash Group, which was subsequently converted into a search u/s 132 on 25.04.2019. During the course of search, certain documents were found which were stated to pertain to the assessee, leading to initiation of proceedings u/s 153C of the Act. Subsequently, the assessment u/s 153C was completed

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-3(3),, AHMEDABAD vs. M/S. ATRI DEVELOPERS,, AHMEDABAD

Appeal is dismissed

ITA 2855/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

transferred by the society to the Appellant - Clause 29 it is mentioned that the landowner will give the Appellant 20% as development charge Reading of the above clauses, makes it amply clear that the expenses towards the development was required to be borne and incurred by the society, whereas the role of the appellant was only towards arranging such materials

M/S. ATRI DEVELOPERS,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX, CIRCLE-3(3),, AHMEDABAD

Appeal is dismissed

ITA 2859/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad23 Jul 2024AY 2013-14

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year : 2013-14 The Dcit, Cir.3(3) M/S.Atri Developers Ahmedabad. Vs 19, Ambalal House Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D Assessment Year : 2013-14 M/S.Atri Developers The Dcit, Cir.3(3) 19, Ambalal House Vs Ahmedabad. Mayur Park Society Satellite Road Ahmedabad. Pan : Aatfa 1086 D

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Prateek Sharma, Sr.DR
Section 133ASection 250

transferred by the society to the Appellant - Clause 29 it is mentioned that the landowner will give the Appellant 20% as development charge Reading of the above clauses, makes it amply clear that the expenses towards the development was required to be borne and incurred by the society, whereas the role of the appellant was only towards arranging such materials

SUN PHARMACEUTICAL INDUSTRIES,MUMBAI vs. JCIT 20(3), MUMBAI

In the result appeal of the Revenue is hereby dismissed

ITA 3507/MUM/2016[2011-12]Status: DisposedITAT Ahmedabad24 Aug 2022AY 2011-12

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Mohd Usman, CIT-DR
Section 80I

u/s 80IE(6) r.w.s. 80IA(10) in respect of alleged price difference Rs.1,25,288/- on purchase from Sun Pharmaceutical Industries Limited (SPIL) On the facts and in the circumstances of the case and in law, the Learned CIT (A) erred m upholding the invoking of the provisions of S.80IE(6) r.w.s. 80IA(10) and thereby upholding the disallowance

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 442/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

survey u/s. 133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic

THE DY.CIT, CIRCLE-3(1)(1)., AHMEDABAD vs. N.K. INDUSTRIES LTD., AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 443/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

survey u/s. 133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 447/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2010-11

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

survey u/s. 133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic

N.K. INDUSTRIES LTD.,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(1)(1), AHMEDABAD

In the result, the appeal of the assessee on this ground is allowed

ITA 448/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad25 Apr 2025AY 2013-14

Bench: Dr. B.R.R. Kumarms. Suchitra Kamble

For Appellant: NK Industries Ltd (Cross Appeals)
Section 250

survey u/s. 133A of the Act, and that the modus operandi adopted by NK Proteins and its clients was explained by him. The relevant para is para 7.6 of the order. The same is summarized as under:- I) NK Proteins is Member Broker on NSEL. II) NK Inds. being client of NK Proteins executes T+3 contract on the electronic