EATON FLUID POWER LIMITED,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 8, PUNE

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ITA 204/PUN/2018Status: DisposedITAT Pune16 September 2022AY 2013-148 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the issue of corporate support services and manufacturing segment adjustments had been decided in favour of the assessee in preceding assessment years by its co-ordinate benches. The Tribunal found no distinction in facts or law for the current assessment years.

What were the facts?

The assessee challenged transfer pricing adjustments made by the revenue authorities concerning corporate support services and manufacturing segments for assessment years 2013-14 and 2014-15. The revenue had made significant arm's length price adjustments.

What were the issues?

Whether the arm's length price adjustments made by the revenue authorities for corporate support services and manufacturing segments were justified, considering previous tribunal decisions.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144C(13)

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(1)Show list

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Income Tax Appellate Tribunal, “C” BENCH, PUNE

Before: SHRI S.S.GODARA, JM & SHRI G.D. PADMAHSHALI, AM

For Appellant: Shri Vishal Karla
For Respondent: Shri Prashant Gadekar
Hearing: 26.08.2022Pronounced: 16.09.2022

Heard together (2 matters)

ITA No.204/PUN/2018
ITA No. 1882/PUN/2018

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

आदेश की प्रधतधलधप अग्रेधषत / Copy of the Order forwarded to : अपीलाथी / The Appellant. 1. प्रत्यथी / The Respondent. 2. 3. The DRP -3, Mumbai 4. The CIT-3, Pune. धवभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, “सी” बेंच, 5. पुणे / DR, ITAT, “C” Bench, Pune. गार्ा फ़ाइल / Guard File. 6. आदेशानुसार / BY ORDER, // True Copy //

Senior Private Secretary आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune.

A.Y. : 2013-14 & 2014-15 Eaton Fluid Power Ltd., S.No. Details Date Initials 1 Draft dictated on 02.09.2022 2 Draft placed before author 14.09.2022 Draft proposed & placed before the Second 3 Member 4 Draft discussed/approved by Second Member 5 Approved Draft comes to the Sr. PS/PS 6 Kept for pronouncement on 7 Date of uploading of Order 8 File sent to Bench Clerk 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R. 11 Date of Dispatch of order

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