THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

price (discount) (excluding value as on in value of on premium) 31.03.2009 investment acquisition 1 6.17% Bond maturing in 202,560,000 2,560,000 2000,000,000 173,700,000 26,300,000 2023 2 6.05% Bond maturing in 253,400,000 3,400,000 250,000,000 231,975,000 18,025,000 2019 3 6.01% Bond maturing

SHREE KHEDUT SAHAKARI KHAND UDYOG MANDLI LTD.,BARDOLI vs. INCOME TAX OFFICER, WARD-1, BARDOLI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

SAHAKARI KHAND UDUOG MANDAL LTD.,NA vs. ARIVS.DCIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

M/S. BAYER VAPI PRIVATE LTD. (FORMERLY KNOWN AS BILAG INDUSTRIES P. LTD.),VAPI vs. THE ASSTT. COMMISSIONER OF INCOME TAX, VAPI CIRCLE,, VAPI

In the result, the appeal of the assessee is partly allowed for A

Bench: Shri Amarjit Singh & Shri O.P. Meena, Accoutant Member आ.अ.सं/.I.T.A No’S.2886/Ahd/2010, 794/Ahd/2014 & 1769/Ahd/2016 िनधा"रण वष"/Assessment Years:2006-07, 2009-10 & 2011-12 बनाम M/S. Bilag Industries Pvt. Ltd. , Addl. Cit Range- ( Now Known As M/S. Bayer Vapi Vs. Vapi, Range Vapi Private Limited) 306/3,Phase-Ii Shivam Commercial Complex Gidc-1, Vapi Gujarat National Highway No 8 Vapi Pan: Aabcb 2100 L अपीलाथ" Appellant ""यथ"/Respondent Shri A. Gopalakrishnan Aiyer - Ca िनधा"रती क" ओर से /Assessee By Shri O. P. Singh Cit (D.R.) राज"व क" ओर से /Revenue By 26.09.2019 सुनवाई क" तारीख/ Date Of Hearing: 24.10.2019 उ"ोषणा क" तारीख/Pronouncement On आदेश /O R D E R Per O. P. Meena, Am: 1. The Above Captioned Three Appeals For The Assessment Year 2006-07, 2009-10 & 2011-12 By The Assessee Are Directed Against The Assessment Order Passed U/S. 143(3) R.W.S. 144C Dated 28.07.2010 & Dated 15.01.2014 Respectively Under The Income-Tax Act,1961 ['The Act' For Short] On The Direction Of Drp By The Addl. Cit Range-Vapi Range Vapi (Herein After Referred As The Ao) & The Appeal For The Assessment Year 2011-12 By The Assessee Is Directed Against The Order Of Ld. Cit (A) Dated 29.04.2016. Since The Common Issues Are Involved In These Appeals Therefore, These Were Heard Together & Consolidated Order Is Being Passed As Under: It(Tp)A No.2886/Ahd/2010/A.Y. 2006-07/ By The Assessee: 2. Ground Nos.1 Is General In Nature & Do Not Require Adjudication.

transfer pricing adjustment can be made. This proviso was substituted by the Finance (No.2) Act, 2009 w. e. f. 01-10-2009. Explanation to sub-section (2) of section 92C has clarified : "that the provisions of the second proviso shall also be applicable to all assessment or reassessment proceedings pending before the Assessing Officer as on 1st October, 2009". Thus

DCIT, CIRCLE-1(1)(2), SURAT vs. J K PAPER LTD, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

10 of the appeal is dismissed. 49. Ground No. 11 of the appeal relates to deleting the addition of Rs. 38,73,80,422/- made under Section 80IA of the Act. Learned Sr. Counsel for the assessee submits that the Assessing Officer made disallowance in pursuance of order passed by Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016

DCIT, CIRCLE-1(1)(2), SURAT vs. J K PAPER LTD, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

10 of the appeal is dismissed. 49. Ground No. 11 of the appeal relates to deleting the addition of Rs. 38,73,80,422/- made under Section 80IA of the Act. Learned Sr. Counsel for the assessee submits that the Assessing Officer made disallowance in pursuance of order passed by Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016

DCIT, CIRCLE-1(1)(1), SURAT, SURAT vs. M/S. J K PAPER LIMITED, SURAT

In the result, all these three appeals of the Revenue are dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

10 of the appeal is dismissed. 49. Ground No. 11 of the appeal relates to deleting the addition of Rs. 38,73,80,422/- made under Section 80IA of the Act. Learned Sr. Counsel for the assessee submits that the Assessing Officer made disallowance in pursuance of order passed by Transfer Pricing Officer (TPO) under Section 92CA(3) dated 28/3/2016

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD.,, NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

MAROLI VIBHAG KHAND UDYOG SAHAKARI MANDALI LTD,.,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, , NAVSARI

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

SAHAKARI KHAND UDYOG MANDAL LTD.,,GANDEVI vs. ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

ACIT, NA vs. ARI CIRCLE, NAVSARIVS.M/S. MAROLI VIBHAG, KAND UDYOG SAHAKARI MANDALI LTD., NAVSARI

In the result, all the appeals are disposed of in the manner indicated\nhereinbefore

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer

SAHADARI KHAND UDYOG MANDAL LTD.,,NA vs. ARIVS.ACIT, NAVSARI CIRCLE, NAVSARI, NAVSARI

10,40,214/- out of\nRs.23.46,50,203/- made in the assessment order on account of non\nbusiness expenditure and transfer of profits effected by payment of\nSugarcane purchase price at the rate over and above the Fait and\nRemunerative Price (FRP) holding that profit element embedded in the\nsugarcane purchase price paid to the member farmer