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

SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

The appeal is dismissed

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.196/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2011-12) Shri Rajkot District Co-Operative Vs. The Deputy Commissioner Of Bank Ltd., Income-Tax, Circle-1(1), Jilla Bank Bhavan, Kasturba Road, Aayakar Bhavan, Race Course Ring Opp. Chaudhary High School, Road, Rajkot-360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Commissioner Of Income Tax Office [(In Short “Ld.Cit(A)”] Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(1) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 30.03.2023 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

144C(1) of the Income Tax Act, 1961 (in short “the Act”), vide order dated 30.03.2023 2. Grounds of appeal raised by the assessee, are as follows: 1. The learned CIT(A) erred in upholding action of assessing officer in disallowing provision of Rs. 60,00,000/- made for standard asset contingency fund by the Appellant. Rajkot Dist

SHRI BHARATBHUSHAN KISHANLAL GUPTA,GANDHIDHAM vs. THE ITO- INTERNATIONAL TAXATION , GANDHIDHAM

In the result, the appeal is allowed in the terms indicated above

Bench: Dr. Arjun Lalsaini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 269/Rjt/2019 (Assessment Year: 2017-18) (Hybrid Hearing) Bharatbhushan Kishanlal Vs. The Income Tax Officer, Gupta, (International Taxation) Prop. Of Aqua Shipping, Suit - Gandhidham – 370210 100, Grain Merchant Association Bldg., 2Nd Floor, Plot No. 297, Wd – 12B, Gandhidham – 370001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afcpg3849N (अपीलाथ"/Assessee) (""यथ"/Respondent)

144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation which

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)

1) arises as a consequence of the order of the 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

SHRI SURESHKUMAR HARJIVANBHAI CHANDARANA,RAJKOT vs. THE ACIT, CIRCLE - 2 (2) (1), RAJKOT, RAJKOT

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

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

144C(3) of the Act, the assessee carried the matter in appeal before the Ld.CIT(A), who has confirmed the action of the assessing officer. The ld.CIT(A) noticed that the Transfer Pricing Regulations (TPR) does not presume that the price at which the taxpayer has transacted with a related party is not the actual price and there

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

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

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

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

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

144C(13) of the Income Tax Act, 1961 ("the Act" for short) pertaining to Asst.Year 2011-12, 2012-13 and 2013-14. Since identical issues are involved in these appeals, they are disposed of by this common order for the sake of convenience. 2. It was common ground that the issues involved in all the appeals was identical

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:

section 144C(13) of the Income- tax Act, 1961 ('the Act') and Transfer Pricing order passed by the Deputy Commissioner of Income-tax, Transfer Pricing Officer 2, Ahmedabad ('TPO') and in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel - 2, Mumbai ('DRP') on the following grounds: 1

THE ACIT.,GANDHIDHAM CIRCLE,, GANDHIDHAM-KUTCH vs. M/S. WOCO TECH POLYMERE KANDLA LTD.,, KANDLA, GANDHIDHAM-KUTCH

In the result, the appeal for the assessment year 2011-12 is also allowed

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

section 143(3) r.w.s. 144C(13)of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Year (A.Y) 2012-13. I.T.A No. 162/Rjt/2018 A.Y. 2012-13 . Page No 2 ACIT Vs. M/s. Woco Tech Polymere Kandla Ltd. 2. The solitary ground raised by the Revenue reads as under: 1

SHOBHNA DOSHI,LONDON vs. THE AC/DC (INT. TXN.), RAJKOT., RAJKOT

Bench: Dr. Arjun Lal Saini. & Dinesh Mohan Sinhaआयकर अपील सं./Ita No.135/Rjt/2025 "नधा"रण वष" / Assessment Year: (2018-19) (Hybrid Hearing) Shobhana Doshi The Ac/Dc Int. Txn. Rajkot. 68 Prices Avenue Kingsbury, Room No.312, Income Tax Vs. London-Nw99Jd, United Office, Amruta Estate Kingdom-999999 Building, Near Girnar Cinema, M.G. Road, Rajkot. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bespd0115G (Appellant) (Respondent)

Prices Avenue Kingsbury, Room No.312, Income tax Vs. London-NW99JD, United Office, Amruta Estate Kingdom-999999 Building, Near Girnar Cinema, M.G. Road, Rajkot. "थायीलेखासं./जीआइआरसं./PAN/GIR No.: BESPD0115G (Appellant) (Respondent) Appellant by : Ms. Devina Patel, Ld. AR Respondent by : Shri Sanjay Punglia, Ld. CIT. (DR) Date of Hearing : 16/07/2025 Date of Pronouncement : 28/07/2025 आदेश