Dow Chemical Inernational Pvt. Ltd. As Successor of Roham and Haas (India) Pvt. Ltd., Mumbai vs. ITO - 14(1)(1), Mumbai
In the result, appeals of the assessee in A
ITA 6577/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Sept 2019AY 2014-15
Bench: Shri Saktijit Dey, Jm & Shri M.Balaganesh, Am M/S. Rohm & Haas India Vs. The Assistant Commissioner Pvt. Ltd., Of Income Tax-11(1)(1) 1St Floor, Block B, Room No.204, Aayakar 02, Godrej Business District Bhavan, M.K. Road, Priojshanagar, Lbs Marg Mumbai – 400 020 Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent) Sa No.261/Mum/2019 M/S. Dow Chemical Vs. Income Tax Officer – International Pvt. Ltd., As 14(1)(1), Room No. 431, Successor Of Rohm & Haas Aayakar Bhavan, Mk Road, (India) Pvt. Ltd., Mumbai – 400 020 Godrej It Park – P2 1St Floor Block B, 02 Lbs Road, Godrej Business District, Pirojshahnagar Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent)
Section 143(3)Section 92E
…le by the said entity. 5.4. The ld. AR with regard to his statement of adopting portfolio approach in CUP method by using TIPS Data Base, placed reliance on the decision of this Tribunal in the case of Boskalis International Dredging C.V vs. DDIT reported in 67 SOT 118. The ld. AR also submitted that this decision of Mumbai Tribunal in the case of Boskalis International Dredging C.V, supra had been upheld by the Hon’ble Jurisdictional High Court which is reported in TS-1310-HC-2018 (MUM). The ld. AR also submitted that in the recently released OECD final deliverables on the Base Erosion and Profit Shifting (BEPS…