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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

iii) Held for Trading (HFT). As per the guidelines investment made under the available for sale (AFS) category should be marked to market periodically. It was further submitted that assessee-bank is allowed to shift securities investment held to maturity category to AFS category with approval of Board of Directors, once a year as per RBI’s guidelines. The assessee

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

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

iii) to\ncompute the differential per MT between the member's rate and such\nbenchmark; and (iv) to multiply this differential by the quantity of cane\npurchased from members to arrive at the prima facie profit-embedded\ncomponent liable for disallowance, subject to any further reduction to the\nextent the assessee, by cogent contemporaneous evidence, demonstrates\nthat a part

DCIT, CENTRAL CIRCLE-2, SURAT, SURAT vs. DHANPRIYA PRINTS PVT. LTD.,, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

iii). Bank statement of M/s Rangila Suppliers Pvt. Ltd highlighting the transactions taken place during the year under consideration. (iv). Share certificate issued to the allottee, i.e. M/s Rangila Suppliers Pvt. Ltd. (v) PAN Number and address. Based on these documents and evidences, the ld Counsel contended that assessee has discharged its onus as required in the section

BETEX INDIA LIMITED,SURAT vs. DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

iii). Bank statement of M/s Rangila Suppliers Pvt. Ltd highlighting the transactions taken place during the year under consideration. (iv). Share certificate issued to the allottee, i.e. M/s Rangila Suppliers Pvt. Ltd. (v) PAN Number and address. Based on these documents and evidences, the ld Counsel contended that assessee has discharged its onus as required in the section

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-2, SURAT vs. BETEX INDIA LIMITED, SURAT

In the result, Ground No. 4 to 6 raised by the Revenue in ITA

Bench: Shri Pawan Singh, Hon'Ble & Dr. A. L. Saini, Hon'Ble Accountnat Member (Physical Court Hearing) Sl.

iii). Bank statement of M/s Rangila Suppliers Pvt. Ltd highlighting the transactions taken place during the year under consideration. (iv). Share certificate issued to the allottee, i.e. M/s Rangila Suppliers Pvt. Ltd. (v) PAN Number and address. Based on these documents and evidences, the ld Counsel contended that assessee has discharged its onus as required in the section

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