ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

Transfer Pricing Officer or any other authority; (e) records relating to the draft order; (f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made by, or caused to be made by, it. (7) The Dispute Resolution Panel may, before issuing any directions referred to in sub- section (5),— I.T.A Nos. 429 & 430/Rjt/2018

ISS SHIPPING INDIA PVT. LTD., (AS AGENT FOR MAERSK TANKERS SINGAPORE PTE. LTD., SINGAPORE),NAVI MUMBAI vs. DY. COMMR. OF INCOME TAX ( INTERNATIONAL TAXATION),, RAJKOT

In the result, both the appeals of the assessee are allowed for statistical purposes

Transfer Pricing Officer or any other authority; (e) records relating to the draft order; (f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made by, or caused to be made by, it. (7) The Dispute Resolution Panel may, before issuing any directions referred to in sub- section (5),— I.T.A Nos. 429 & 430/Rjt/2018

BHAVANI INDUSTRIES INDIA LLP,RAJKOT vs. ACIT, CIRCLE-2, RAJKOT, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

transfer pricing officer, has accepted the above price at arm`s length price, based on the same facts and circumstances, and did not make any addition in the hands of the assessee. Therefore, taking into account this factual position also, the disallowance restricted by the learned CIT(A) to the tune of Rs.1,18,45, 693/- should be deleted, accordingly

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

In the result, summarised and concise ground No

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No. 247 To 250 & 260/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2012-13, 2013-14, 2017-18 2018-19 & 2010-11 Bhawani Industries India Llp Assistant Commissioner Of बनाम/ Income-Tax, Cicle-2(1), Rajkot, C/1-B, 236/3 Gidc, Aji Industrial Room No.311, 3Rd Floor, Aaykar Estate, Rajkot-36 003 Vs. Bhawan, Race Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) आयकर अपील सं/.Ita No.254 To 256/Rjt/2024 "नधा"रण वष"/ Assessment Years: 2010-11, 2012-13 & 2013-14 Bhawani Industries India Llp Assistant Commissioner Of Income- C/1-B, 236/3 Gidc, Aji बनाम/ Tax, Cicle-2(1), Rajkot, Room No.311, Industrial Estate, Rajkot-36 3Rd Floor, Aaykar Bhawan, Race Vs. 003 Course Ring Road, Rajkot-360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aacfb 8046 R (अपीलाथ"/Assessee) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Mehul Ranpura, Ld.Ar राज"व क" ओर से/Revenue By : Shri Sanjay Punglia, Ld. Cit-Dr & Shri Abhimanyu Singh Yadav, Sr-Dr

transfer pricing officer, has accepted the above price at arm`s length price, based on the same facts and circumstances, and did not make any addition in the hands of the assessee. Therefore, taking into account this factual position also, the disallowance restricted by the learned CIT(A) to the tune of Rs.1,18,45, 693/- should be deleted, accordingly

HANDYTANKERS K/S AGENT OF F.B. MAERSK TANKERS C/O ATLANTIC SHIPPING PVT. LTD.,,SIKKA vs. THE DY. COMMR. OF INCOME TAX, (INTERNATIONAL TAXATION),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

LR2 MANAGEMENT K/S AGENT OF PRINCIPAL FREIGHT BENEFICIARY, INTEROCEAN SHIPPING (I) PVT. LTD.,,JAMNAGAR vs. THE INCOME TAX OFFICER, (INTER. TAXA.),, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

LR2 MANAGEMENT K/S (AS FOREIGN COMMR. MANAGER/AGENT OF PRINCIPAL FREIGHT BENEFICIARY, TORM A/S MAERSK TANKERS SINGAPORE P. LTD.,SIKKA vs. THE INCOME TAX OFFICER, INTER. TAXA.,, RAJKOT-GUJARAT

In the result, the appeals are allowed for statistical purposes

Transfer Pricing Officer passed under sub-section (3) of section 92CA; and (ii) any foreign company.' 8. If the above provisions of reference to the DRP are to be applied in the context of orders passed under section 172(4), in terms of the provisions of Section 144(1), it is ITA Nos. 756 of 2014, 276 of 2015 & 91/Rjt/2016

M/S. KANDLA ENERGY AND CHEMICALS LTD.,VILLAGE DEVALIYA, TAL. ANJAR(KUTCH) vs. ADD. CIT, GANDHIDHAM RANGE,, GANDHIDHAM(KUTCH)

In the result, the appeal filed by the Assessee is hereby dismissed

Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Transfer Pricing Officer passed under sub-section (3) of section 92CA ; and (ii) any foreign company.” 9.1. As per sub-section (2) of Section 144C eligible assessee has an option to file, either his acceptance of the variation proposed in the I.T.A No. 399/Rjt/2018 A.Y. 2014-15 Page No 9 Kandla Energy & Chemicals Ltd. Vs. ACIT draft assessment order

PRANAM ENTERPRISE,JUNAGADH vs. DCIT, CIRCLE-1(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.391/Rjt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Pranam Enterprise Vs. The Dcit Office No.3, City Centre, Opp. Circle-1(1), Rajkot New Collector Office, Junagadh – 362001, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaffp7926H (Assessee) (Respondent) Assessee By Shri Mehul Ranpura, Ar Respondent By Shri Abhimanyu Singh Yadav, Sr.Dr Date Of Hearing 18/12/2024 Date Of Pronouncement 06/03/2025 आदेश / O R D E R Per Dr. A. L. Saini, Am:

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the international transactions. The TPO, in his order passed dated 22.1.2015,made no adverse inference with respect to ALP of all other international transactions except that relating to the sale of finished goods to AE. 8. The assessee had benchmarked the said international transaction using Cost Plus Method

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the international transactions. The TPO, in his order passed dated 22.1.2015,made no adverse inference with respect to ALP of all other international transactions except that relating to the sale of finished goods to AE. 8. The assessee had benchmarked the said international transaction using Cost Plus Method

AHLSTROM FIBER COMPOSITES (I) P. LTD.,,MUNDRA (KUTCH) vs. THE ASSTT. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeals of the assessee are allowed for statistical purposes

Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyalit(Tp)A No.85& 287/Rjt/2017 Assessment Year :2012-13 & 2013-14

Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the international transactions. The TPO, in his order passed dated 22.1.2015,made no adverse inference with respect to ALP of all other international transactions except that relating to the sale of finished goods to AE. 8. The assessee had benchmarked the said international transaction using Cost Plus Method

NISHANT PAREKH- LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD-1(3), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.215/Rjt/2025 "नधा"रणवष" / Assessment Year: (2015-2016) Nishant Parekh – Legal Heir Of Vs. Income Tax Officer Mina Parekh Aaykar Bhavan 322 Madhav Square, Opp 361001, Gujrat Avantika Complex, Limda Lane Road, Gujrat-361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (Appellant) (Respondent)

price of the share, it can be said that assessee received the penny stock gain in order to off-set the loss or to convert the unaccounted money into white money, and that was the reason that the Government has introduced Section 56(2)(viia) of the Act. The assessee received the bogus long term capital gain (LTCG) and that

AHLSTROM FIBERCOMPOSITES INDIA PVT. LTD.,,MUNDRA (KUTCH) vs. THE DY. COMMR. OF INCOME TAX, GANDHIDHAM CIRCLE,, GANDHIDHAM

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Ms Suchitra Kamble & Shri Waseem Ahmedआयकरअपीलसं./Ita No. 437/Rjt/2018 धििाधरणणवध/Asstt. Year:2014-2015 Ahlstrom Munksjo Vs. D.C.I.T, Fibercomposites(India) Pvt. Ltd., Gandhidham Circle, Mundra Sez Integrated Textile & Gandhidham. Apparel Park (Mitap), Plot No.07, Survey No.141, Mundra, Kutch-370421. Pan: Aagca9137M (Applicant) (Respondent) Assessee By : Shri Tushar Hemani, A.R Revenue By : Shri Shramdeep Sinha, C.I.T Dr सुिणाईकीतारीख/Date Of Hearing : 06/12/2023 घोवणाकीतारीख/Date Of Pronouncement: 20/12/2023 आदेश/O R D E R Per Waseem Ahmed:

transfer pricing adjustment considering entity wide margins. 1.3. On the facts and in the circumstances of the case and in law, the Learned AO/TPO has erred in and learned DRP has further erred in rejecting cost plus method ('CPM') adopted by the Appellant and selecting Transactional Net Margin Method ('TNMM') as the most appropriate method to determine

SAMEER SHAH (HUF),1 "SWAPNEEL" ,OPP. GURUDATATREY TEMPLE PALACE ROAD vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR, GUJARAT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Saini. आयकरअपीलसं./Ita No.248/Rjt/2025 "नधा"रणवष" / Assessment Year: (2013-14) (Hybrid Hearing) Sameer Shah (Huf), Vs. The Ito Ward 1(3), 1 “Swapneel”, Opp. Jamnagar - 361001 Gurudatatrey Temple, Palace Road, Jamnagar - 361008 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aawhs3749E (Appellant) (Respondent)

10(38) is in accordance with the provision of the Act. There is no finding of the learned assessing officer as to why the claim of the assessee based on this evidence is not in accordance with the law. Not only that, but the learned assessing officer has also added the amount

NISHANT PAREKH - LEGAL HEIR OF MINA PAREKH,JAMNAGAR vs. INCOME TAX OFFICER, WARD 1(3), JAMNAGAR

The appeal of the assessee is allowed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 196/Rjt/2025 ("नधा"रणवष"/Assessment Year: (2012-13) Nishant Parekh – Legak Heir Of Mina Income Tax Officer, Wd – 1(3), Parekh Vs. Aayakar Bhavan, 322, Madhav Square, Opp. Avantika Jamnagar – 361001 Complex, Limda Lane Road, Jamnagar – 361001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aanpp9471F (अपीलाथ"/Assessee) (""यथ"/Respondent)

transferred from the dematerialized account and received consideration through legitimate banking channels. The assessing officer did not have any independent source or evidence to show an agreement between the assessee and any other party to convert unaccounted money by taking the fictitious loss. The decision of assessing officer was unsupported by any material on record, and the finding was purely

KAUSHALIYA SAMPATLAL DUDANI,JAMNAGAR vs. INCOME TAX OFFICER, WARD 2(6), JAMNAGAR

In the result, the appeal of the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./ Ita No.659/Rjt/2025 िनधा"रण वष"/Assessment Year :2012-2013 Kaushaliya Sampatlal Dudani The Ito, Ward-2(6), बनाम/ K-1/79/4 G.I.D.C., Shanker Ayakar Bhawan, Jamnagar Vs Tekri, Udyognagar, Jamnagar Jamnagar. Gujarart-361005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Abnpd8662P (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Sagar Shah, Ld. Ar राज" की ओर से/Revenue By : Shri Abhimanyu Singh, Ld. Sr-Dr

transfer of shares in Tuni Textiles was bogus. Hence the addition was deleted by the ITAT. In the present case, the assessee has already placed on record the contract notes/bill for sale of shares and this substantiates the fact that assessee or his broker was not involved in price ragging or manipulation activities as alleged by assessing officer. Further, assessing

KANTABEN VAJUBHAI PAGHADAL,RAJKOT, GUJARAT vs. ITO WD 1(2)(1), RAJKOT, RAJKOT

In the result, appeal filed by the assessee is allowed

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No.552/Rjt/2025 "नधा"रणवष" / Assessment Year: (2016-17) (Hybrid Hearing) Kantaben Vajubhai Paghadal Vs. It-Office, New Aayakar At- Charan Samadhiyala, Bhawan, Jetpur – 360370(Gujarat) Rajkot - 360370 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Cxmpp2962D (Appellant) (Respondent)

transfer of the capital asset. The court considered the provisions of sections 23(1), 23(1-A) and section 23(2) of the Act as well as section 28 and section 34 of the Act of 1894 and observed that section 23(1-A) was introduced in the 1894 Act to mitigate the hardship caused to the owner

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), RAJKOT, RAJKOT vs. BHAWANI INDUSTRIES INDIA LLP, RAJKOT

transfer pricing officer, in the subsequent assessment years, in the assessee`s case, having same facts and circumstances, and no addition were made in the hands of the assessee. Besides, with help of 22 Bhavani Industries India LLP ITA Nos.247 to 250/RJT/2024 & Ors. (AYs: 2012-13, 2013-14 & Ors.) documentary evidences, the assessee has demonstrated, before the assessing officer that