582 and Honeywell Electrical Devices & Systems India Ltd. v. ACIT

64 SOT 118Income Tax Appellate Tribunal2014#21198 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 348,356 Indian tax judgments — from 2018 to 2023.

Judgments citing 582 and Honeywell Electrical Devices & Systems India Ltd. v. ACIT

Dic India Ltd., Kolkata vs. DCIT, Circle - 10(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 2084/KOL/2018[2014-15]Status: DisposedITAT Kolkata04 Jan 2023AY 2014-15

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No. 2084/Kol/2018 Assessment Year: 2014-2015 Dic India Limited,..................................Appellant Transport Depot Road, Kolkata-700088 [Pan: Aabcc0703C] -Vs.- Deputy Commissioner Of Income Tax,......Respondent Circle-10(1), Aayakarbhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Akkaldudhwewala, A.R., Appeared On Behalf Of The Assessee Shri Hukumasema, Cit, Appeared On Behalf Of The Revenue

Section 144CSection 144C(5)

…or the reason that the same was not an audited one. ln this connection, the Coordinate Bench on the decision of the Coordinate Bench Chennai in the matter of Honeywell Electrical Devices & Systems India Ltd. v. Asstt. CIT reported in [2014] 42 taxmann.com 223/64 SOT 118 (Chennai - Trib.) wherein the Chennai Tribunal, placing reliance on the decision rendered in the matter of 3iInfotec Ltd. v. ITO reported in [2013] 35 txmann.com 582 (Chennai - Trib), held that even if such segmental results were not shown in the audited financial 9 Assessment Year: 2014-2015 DIC India Limited accounts, they had to be accepted.…

ACIT, Circle - 2(2), Kolkata vs. M/S. Netguru Ltd., Kolkata

In the result, appeal filed by the Revenue is dismissed

ITA 1799/KOL/2018[2011-12]Status: DisposedITAT Kolkata24 Apr 2019AY 2011-12

Bench: Shri S.S.Godara, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.1799/Kol/2018 (िनधा"रणवष" / Assessment Year: 2011-12) Acit, Circle-2(2), Kolkata Vs. M/S Netguru Ltd.

For Appellant: Shri Sanjay Paul, JCIT, Sr. DRFor Respondent: Shri Anup Sinha, ACA and Rituparna Sinha, ACA
Section 143(3)Section 92C

…or the reason that the same was not an audited one. ln this connection, the Coordinate Bench on the decision of the Coordinate Bench Chennai in the matter of Honeywell Electrical Devices & Systems India Ltd. v. Asstt. CIT reported in [2014] 42 taxmann.com 223/64 SOT 118 (Chennai - Trib.) wherein the Chennai Tribunal, placing reliance on the decision rendered in the matter of 3i Infotec Ltd. v. ITO reported in [2013] 35 txmann.com 582 (Chennai - Trib), held that even if such segmental results were not shown in the audited financial accounts, they had to be accepted. The Coordinate Bench in the matter of Infotec Lt…

Assistant Commissioner of Income-Tax vs. Visteon Engg. Center (I) Pvt. Ltd., Pune

Accordingly, the appeal of Revenue is dismissed

ITA 540/PUN/2015[2010-11]Status: DisposedITAT Pune28 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Ketan Ved & Ms. Nupoor ShahFor Respondent: Smt. Nirupama Kotru
Section 143(3)

…ised by the assessee is accordingly allowed for statistical purposes.” 13. Similar issue has been decided by Chennai Bench of Tribunal in 3i Infotech Ltd. Vs. ITO (2013) 35 taxmann.com 582 and Honeywell Electrical Devices & Systems India Ltd. Vs. ACIT (2014) 64 SOT 118. Following the same parity of reasoning, we hold that segmental profitability in respect of provision of engineering design services by the assessee to its associate enterprises, should be considered to work out the PLI of international transactions undertaken by the assessee. The Assessing Officer / TPO is thus, directed to re-work the PLI of seg…

Visteon Engineering Center (India) Private Ltd., Pune vs. Assistant Commissioner of Income-Tax

Accordingly, the appeal of Revenue is dismissed

ITA 316/PUN/2015[2010-11]Status: DisposedITAT Pune28 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Ketan Ved & Ms. Nupoor ShahFor Respondent: Smt. Nirupama Kotru
Section 143(3)

…ised by the assessee is accordingly allowed for statistical purposes.” 13. Similar issue has been decided by Chennai Bench of Tribunal in 3i Infotech Ltd. Vs. ITO (2013) 35 taxmann.com 582 and Honeywell Electrical Devices & Systems India Ltd. Vs. ACIT (2014) 64 SOT 118. Following the same parity of reasoning, we hold that segmental profitability in respect of provision of engineering design services by the assessee to its associate enterprises, should be considered to work out the PLI of international transactions undertaken by the assessee. The Assessing Officer / TPO is thus, directed to re-work the PLI of seg…

582 and Honeywell Electrical Devices & Systems India Ltd. v. ACIT (64 SOT 118) — Cited in 4 Judgments | BharatTax