ACIT v. UE Trade Corporation (India) Pvt. Ltd.

45 SOT 197Income Tax Appellate Tribunal#25019 most cited
3

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2019 to 2022.

Judgments citing ACIT v. UE Trade Corporation (India) Pvt. Ltd.

The Dy. CIT, Circle-2(1)(1), Ahmedabad vs. M/S. Gujarat Microwax Ltd., Ahmedabad

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

ITA 2683/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad15 Jun 2022AY 2012-13

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10BSection 143(3)Section 92E

…the ratio of this decision is very much applicable. Page 19 of 51 ITA No.2682 & 2683/Ahd/2016 A.Y. 2011-12 and 2012-13 Gujarat Microwax Pvt. Ltd. (d) We would also like to refer a very relevant decision held in ACIT vs. UE Trade Corporation (India) Pvt. Ltd. 45 SOT 197 (Delhi), ITA No. 4405(Del)/2009 order dated 24.12.2010: "4.2. The second ground is that the position should be seen as a whole with respect to all the transactions and not only with respect to the disputed transactions. In other words, if transfer pricing study is made for all the transactions, the variation made by the AO would be of insignifica…

The Dy. CIT, Circle-2(1)(1), Ahmedabad vs. M/S. Gujarat Microwax Ltd., Ahmedabad

In the result, both of the Appeals of Revenue are partly allowed for statistical purposes

ITA 2682/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad15 Jun 2022AY 2011-12

Bench: Ms. Suchitra Kamble & Shri B.M. Biyani

Section 10BSection 143(3)Section 92E

…the ratio of this decision is very much applicable. Page 19 of 51 ITA No.2682 & 2683/Ahd/2016 A.Y. 2011-12 and 2012-13 Gujarat Microwax Pvt. Ltd. (d) We would also like to refer a very relevant decision held in ACIT vs. UE Trade Corporation (India) Pvt. Ltd. 45 SOT 197 (Delhi), ITA No. 4405(Del)/2009 order dated 24.12.2010: "4.2. The second ground is that the position should be seen as a whole with respect to all the transactions and not only with respect to the disputed transactions. In other words, if transfer pricing study is made for all the transactions, the variation made by the AO would be of insignifica…

DCIT 15 (1)(2), Mumbai vs. Dutyfree Distribution Services Pvt.Ltd., Mumbai

In the result, these grounds of appeal are dismissed

ITA 2855/MUM/2018[2013-14]Status: DisposedITAT Mumbai02 Dec 2019AY 2013-14

Bench: Shri Shamim Yahya () & Shri Pawan Singh () Assessment Year: 2013-14

For Appellant: Mr. J.P. Bairagra, ARFor Respondent: Mr. Anand Mohan, DR
Section 10A

…rking? 3. a. Whether on the facts and circumstances of the case and in law, the Id. CIT (A) has erred in deleting the TP adjustment made by the TPO ignoring the decision of the Hon’ble Delhi ITAT in the case of ACIT Vs. UE Trade Corporation (India) Pvt. Ltd. [45 SOT 197 (Del)], wherein it was held that where the impugned transactions did not constitute a series of connected and indivisible transactions, and each transaction was separate, benchmarking should also be carried out in a transaction-by-transaction manner? b. Whether on the facts and circumstances of the case and in law, the Id. CIT (A) has erred in del…

ACIT v. UE Trade Corporation (India) Pvt. Ltd. (45 SOT 197) — Cited in 3 Judgments | BharatTax