M/S. FDC LIMITED,MUMBAI vs. ADDLL. CIT- 8 (1), MUMBAI

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ITA 6901/MUM/2018Status: DisposedITAT Mumbai08 October 2021AY 2010-1155 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partly allowed the assessee's appeals for both assessment years and dismissed the revenue's appeal. Several grounds were decided in favor of the assessee, including issues related to transfer pricing adjustments, deduction for R&D expenses, disallowance of promotional items, and disallowance under Section 14A.

What were the facts?

The assessee, M/s FDC Limited, filed appeals for Assessment Years 2010-11 and 2011-12, and the revenue also filed an appeal for AY 2010-11. The appeals involved issues related to transfer pricing, deduction claims under Section 35(2AB), disallowance of promotional expenses, and other miscellaneous adjustments.

What were the issues?

Key issues included the determination of Arm's Length Price (ALP) for international transactions, eligibility for weighted deductions for R&D expenses, and the allowability of promotional expenses incurred for business purposes.

Which sections of the Income-tax Act were involved?

Section 35(2AB),Section 37(1),Section 14A,Section 115JB,Section 234C

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Cases cited in this judgment(24)Show list

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Income Tax Appellate Tribunal, “K” BENCH, MUMBAI

Before: HON’BLE SHRI MAHAVIR SINGH, VP & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

For Appellant: Shri S. S. Nagar, Ld. AR
For Respondent: Shri Sunil Deshpande, Ld. CIT-DR

Heard together (3 matters)

I.T.A. No.6901/Mum/2018
I.T.A. No.6840/Mum/2018
I.T.A. No.7016/Mum/2018

Read from the judgment's own cause title. This page is filed under one of them.

आदेशाि सार/ BY ORDER,

उप/सहायक पुंजीकार (Dy./Asstt.Registrar) आयकरअपीलीयअधिकरण, मुिंबई / ITAT, Mumbai.

55 M/s FDC Limited Assessment Years: 2010-11 & 2011-12 Sr. No. Details Date Initials Designation 1 Draft dictation sheets are attached Directly Typed Sr.PS/PS on Computer / Laptop 2 Draft dictated on Not Applicable/ Sr.PS/PS 3 Draft Placed before author Not Applicable Sr.PS/PS 4 Draft proposed & placed before the Second Member JM/AM 5 Draft discussed/approved by Second Member JM/AM 6 Approved Draft comes to the Sr.PS/PS 02.11.2021 Sr.PS/PS 7 Order pronouncement on 08.10.2021 Sr.PS/PS 8 File sent to the Bench Clerk 02.11.2021 Sr.PS/PS 9 Date on which the file goes to the Head clerk 10 Date on which file goes to the AR 11 Date of Dispatch of order

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