Carlyle India Advisors (P.) Ltd. v. Asstt. CIT

53 SOT 267Income Tax Appellate Tribunal2012#25209 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2018 to 2022.

Judgments citing Carlyle India Advisors (P.) Ltd. v. Asstt. CIT

Hsbc Asset Management, Mumbai vs. DCIT 1(1), Mumbai

In the result, appeal of the Revenue is partly allowed

ITA 7136/MUM/2012[2007-08]Status: DisposedITAT Mumbai20 Apr 2022AY 2007-08

Section 143(3)

…the assessee’s international transaction and determined the ALP thereon. But we find that the entire list of 15 comparable companies chosen by the ld. TPO had been rejected by this Tribunal in the case of Carlyle India Advisors Pvt. Ltd., vs. ACIT reported in 53 SOT 267(Mumbai) dated 04/04/2012. In the said Tribunal order, IDC India Ltd., which was included as a comparable by the assessee was considered as a good comparable with assessee providing non-binding investment advisory services. It is pertinent to note that services rendered by the assessee are similar with the services rendered by Carlyle India Advisor…

Credit Suisse Consulting (India) P. Ltd, Mumbai vs. DCIT RG 3(1), Mumbai

619/Mum/2014

ITA 619/MUM/2014[2009-10]Status: DisposedITAT Mumbai05 Apr 2022AY 2009-10

Section 143(3)Section 144C(5)

…It is further observed that this company also makes significant investments in companies using its own funds. This company has not been considered by the Co-ordinate Benches of the Tribunal in the case of Carlyle India Advisors (P.) Ltd. v. Asstt. CIT [2012] 53 SOT 267/24 taxmann.com 176 (Mum.) and also in the case of Temasek Holdings Advisors (I) (P.) Ltd. v. Dy. CIT [2013] 60 SOT 134/38 taxmann.com 80 (Mum. - Trib.) wherein the Tribunal at para-53 on page-56 of its order have observed that this company is mostly into making investment in the companies using its own fund and it is a leading player in distress a…

DCIT, New Delhi vs. M/S. Freescale Semiconductor India (P) Ltd., New Delhi

The appeal of the Revenue is dismissed

ITA 1266/DEL/2011[2005-06]Status: DisposedITAT Delhi29 Oct 2018AY 2005-06

Bench: Shri N. K. Billaiya & Ms Suchitra Kamble

Section 143(2)Section 143(3)Section 92C

….) iii) CIT vs. Mentor Graphics (Noida) (P) Ltd. 215 Taxman 539 (Del. HC) iv) ACIT vs. Maersk Global Service Centre (India) (P) Ltd. 133 ITD 543 (Mum Tri.) 4 v) Tevapharm (P) Ltd. vs. ACIT 50 SOT 150 (Mum Tri.) vi) Carlyle India Advisors (P) Ltd. vs. ACIT 53 SOT 267 (Mum Tri.) vii) ST Microelectronics (P) Ltd. vs. CIT 15 ITR 410 (Del. Tri.) viii) ST Microelectronics Pvt. Ltd. vs. CIT 2016-TII-15-HC-DEL-TP (Del. HC) As regards Ground No. 2, the Ld. AR submitted as per Rule 27 of the Income Tax Act, 1961 that the claim of the assessee company relating to Section 10A has to be kept open by the Revenue authori…