CIT v. Cotton Naturals (I) (P.) Ltd.

55 Taxmann.com 523High Court2015#291 most cited

What is CIT v. Cotton Naturals (I) (P.) Ltd. authority for?

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

273

judgments rely on this decision, according to BharatTax’s citation analysis of 369,743 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Cotton Naturals (I) (P.) Ltd. · 55 Taxmann.com 523 · 231 Taxmann 401 · section 92B · section 92CA(3) · arm's length interest · foreign currency loan · outstanding receivables · LIBOR · PLR · benchmarking interest · associated enterprise

Also reported as

231 Taxmann 401

Sections most often in play

Section 143(3)Section 92BSection 144C(13)Section 144BSection 144C(5)Section 234BSection 92CA(3)Section 234C
Read the full judgment

Issues it is cited on

interest on outstanding receivablessection 92b(1)safe harbour rulessafe harboursection 92bsection 72asection 92(1)preliminary expensescup methodcorporate guaranteeworking capital adjustmenttransfer pricing order

Judgments citing CIT v. Cotton Naturals (I) (P.) Ltd.

Maanaveeya Development & Finance Private Limited, Hyderabad vs. ACIT, Circle-16(2), Hyderabad

ITA 134/HYD/2017[2011-12]Status: DisposedITAT Hyderabad14 Dec 2021AY 2011-12

Bench: Shri A.M. Alankamony & Shri S.S. Godara

Section 1

…ITA Nos 134 of 2017 and others Manaveeya Development and Finance Ltd IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad (Through Video Conferencing) Before Shri A.M. Alankamony, Accountant Member and Shri S.S. Godara, Judicial Member Appeal in ITA A.Y Appellant Respondent 134/Hyd/2017 2011-12 Maanaveeya A.I.C.T. Development & Circle 16(2) Finance P Ltd Hyderabad Hyderabad PAN:AAECM1085E 149/Hyd/2017 2011-12 Dy.C.I.T. Maanaveeya Development Circle 16(2) & Finance P Ltd Hyderabad Hyderabad PAN:AAECM1085E 565/Hyd/2017 2012-13 -do- Dy.C.I.T. Circle 16(2) Hyderabad 1507/Hyd/2018 2013-14 -do- -do…

M/S Trilar Video Technologies India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-7(1)(1), Bangalore

In the result, the appeal filed by assessee stands allowed

ITA 3367/BANG/2018[2014-15]Status: DisposedITAT Bangalore30 Nov 2021AY 2014-15

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “B” BENCH: BANGALORE BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER IT(TP)A. No. 3367/Bang/2018 Assessment Year: 2014-15 M/s. Synamedia India Pvt. Ltd. (Formerly known as Trilar Video Technologies The Assistant India Pvt. Ltd.), Commissioner of Income Block 9A & 9B, Pritech Tax, Park, Survey No. 51-64/4, Circle 7(1)(1), Sarjapur Outer Ring Road, vs. Bangalore. Bellandur Village, Bangalore – 560 103. PAN: AACCN1140K (Appellant) (Respondent) Assessee by : Shri Sharath Rao, CA Revenue by : Shri Muzaffar Hussain, CIT (DR)…

JCIT, Bangalore vs. M/S Biocon Ltd., Bangalore

In the result appeal filed by assessee for assessment year

ITA 558/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “B” BENCH: BANGALORE BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER Assessment Appeal No. Appellant Respondent Year M/s. Biocon The Deputy Ltd., Commissioner IT(TP)A No. of Income Tax, 2009-10 20th KM, Hosur 230/Bang/2014 Road, LTU, Electronic City, Bangalore. Bangalore – The Joint IT(TP)A No. 560100. Commissioner 2011-12 557/Bang/2016 PAN: of Income Tax, AAACB7461R LTU, Bangalore. M/s. Biocon Ltd., 20th KM, Hosur The Joint Road, IT(TP)A No. Commissioner Electronic City, 2011-12 558/Bang/2016 of Income Tax, Bangalore – LT…

Biocon Limited, Bangalore vs. JCIT, Bangalore

In the result appeal filed by assessee for assessment year

ITA 557/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “B” BENCH: BANGALORE BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER Assessment Appeal No. Appellant Respondent Year M/s. Biocon The Deputy Ltd., Commissioner IT(TP)A No. of Income Tax, 2009-10 20th KM, Hosur 230/Bang/2014 Road, LTU, Electronic City, Bangalore. Bangalore – The Joint IT(TP)A No. 560100. Commissioner 2011-12 557/Bang/2016 PAN: of Income Tax, AAACB7461R LTU, Bangalore. M/s. Biocon Ltd., 20th KM, Hosur The Joint Road, IT(TP)A No. Commissioner Electronic City, 2011-12 558/Bang/2016 of Income Tax, Bangalore – LT…

DCIT, New Delhi vs. M/S. Jaypee Capital Services Ltd., New Delhi

In the result, ITA.No.3559/Del

ITA 3559/DEL/2016[2012-13]Status: DisposedITAT Delhi21 Sept 2021AY 2012-13

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: And Shri Ashish Goel, C.AFor Respondent: Shri Bhuvnesh Kulshreshtha
Section 132Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “I-1 ” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA.Nos.3558 & 3559/Del./2016 Assessment Years 2011-2012 & 2012-2013 The DCIT, M/s. Jaypee Capital Central Circle-29, Services Ltd., FA-45, Room No.318, 3rd Floor, vs. Shivaji Enclave, ARA Centre, New Delhi – 110 027. Jhandewalan Extn., New Delhi. PAN AAACJ0628A (Appellant) (Respondent) For Revenue : Shri Bhuvnesh Kulshreshtha, CIT-DR Shri Ved Jain, Sr. Advocate For Assessee : And Shri Ashish Goel, C.A. Date of Hearing : 23.06.…

DCIT, New Delhi vs. M/S. Jaypee Capital Services Ltd., New Delhi

In the result, ITA.No.3559/Del

ITA 3558/DEL/2016[2011-12]Status: DisposedITAT Delhi21 Sept 2021AY 2011-12

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: And Shri Ashish Goel, C.AFor Respondent: Shri Bhuvnesh Kulshreshtha
Section 132Section 153A

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES “I-1 ” : DELHI [THROUGH VIDEO CONFERENCING] BEFORE SHRI R.K. PANDA, ACCOUNTANT MEMBER AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER ITA.Nos.3558 & 3559/Del./2016 Assessment Years 2011-2012 & 2012-2013 The DCIT, M/s. Jaypee Capital Central Circle-29, Services Ltd., FA-45, Room No.318, 3rd Floor, vs. Shivaji Enclave, ARA Centre, New Delhi – 110 027. Jhandewalan Extn., New Delhi. PAN AAACJ0628A (Appellant) (Respondent) For Revenue : Shri Bhuvnesh Kulshreshtha, CIT-DR Shri Ved Jain, Sr. Advocate For Assessee : And Shri Ashish Goel, C.A. Date of Hearing : 23.06.…

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. At Kearney Ltd.- India Branch Office, Gurgaon

In the result, ITA.No.7888/Del

ITA 7888/DEL/2017[2010-11]Status: DisposedITAT Delhi14 Sept 2021AY 2010-11

Bench: Shri R.K. Panda & Shri Kul Bharat

For Appellant: And Shri Ashish Goel, C.AFor Respondent: Shri Vijay Choudhary, Sr. DR
Section 195

…rried on by him has actually resulted in profit or income either in the same year or in the subsequent years. 12 ITA.Nos.7887 & 7888/Del./2017 M/s. AT Kearney Limited, Gurgaon. 15. The Hon'ble High Court of Delhi in the case of Cotton Naturals India [P] Ltd 276 CTR 445 at para 17 of its order has held that “Chapter X and Transfer Pricing rules do not permit the Revenue authorities to step into the shoes of the assessee and decide whether or not a transaction should have been entered. It is for the assessee to take commercial decisions and decide how to conduct and carry on its business.” 16. It is incorrect to…

DCIT, Circle- 1(1)(1), International Taxation, New Delhi vs. At Kearney Ltd.- India Branch Office, Gurgaon

In the result, ITA.No.7888/Del

ITA 7887/DEL/2017[2009-10]Status: DisposedITAT Delhi14 Sept 2021AY 2009-10

Bench: Shri R.K. Panda & Shri Kul Bharat

For Appellant: And Shri Ashish Goel, C.AFor Respondent: Shri Vijay Choudhary, Sr. DR
Section 195

…rried on by him has actually resulted in profit or income either in the same year or in the subsequent years. 12 ITA.Nos.7887 & 7888/Del./2017 M/s. AT Kearney Limited, Gurgaon. 15. The Hon'ble High Court of Delhi in the case of Cotton Naturals India [P] Ltd 276 CTR 445 at para 17 of its order has held that “Chapter X and Transfer Pricing rules do not permit the Revenue authorities to step into the shoes of the assessee and decide whether or not a transaction should have been entered. It is for the assessee to take commercial decisions and decide how to conduct and carry on its business.” 16. It is incorrect to…

Asst.C.I.T., Bangalore vs. M/S Mphasis Limited, Bangalore

In the result appeal filed by revenue stands dismissed and appeal filed by assessee stands allowed as indicated hereinabove

ITA 429/BANG/2015[2010-11]Status: DisposedITAT Bangalore14 Jun 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 10ASection 143(3)Section 144C

…ould have to be studied. In the event any receivables needs to be separately benchmarked, we direct Ld.AO/TPO to compute the interest in accordance with the ratio of Hon’ble Delhi High Court in case of CIT vs Cotton Naturals India Pvt. Ltd. reported in (2015) 276 CTR 445. 36. With the above directions we remand this issue back to the Ld.AO/TPO to reconsider the issue in accordance with law. Accordingly this ground raised by assessee stands allowed for statistical purposes. 37. Ground No.8 is raised by assessee against not granting deduction under section 10A/10AA/10B with respect to profits attributable towards o…

M/S. Bry Air (Asia) Pvt. Ltd., Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is allowed

ITA 4107/DEL/2016[2010-11]Status: DisposedITAT Delhi08 Jun 2021AY 2010-11

Bench: Sh.Amit Shukla & Sh. Prashant Maharishiassessment Year: 2010-11 M/S. Bry Air (Asia) Pvt. Ltd, Dcit, 20, Rajpur Road, Vs Circle-5(1), Delhi New Delhi Pan: Aaacb4050A (Appellant) (Respondent) Appellant By Shri Shailender Kr. Bajaj, Ca Respondent By Shri Dheeraj Jain, Sr. Dr Date Of Hearing: 09/03/2021 Date Of Pronouncement: 08/06/2021 Order

Section 143(3)Section 144CSection 92C

…transfer pricing officer or the learned CIT – A. The learned CIT – A further increased Libor by 700 base points for covering capital risk. However, honourable Delhi High Court in Commissioner of income tax versus Cotton naturals India private limited (2015) 276 CTR 445 (Del) has categorically held that the financial position and credit rating of the subsidiaries will be broadly the same as of the holding company. Therefore, there should not be any adjustment on account of capital risk. The honourable court also categorically held that where the transaction was of lending money in foreign currency to its foreign…

Greatship (India ) Ltd, Mumbai vs. DCIT 5(1)(1), Mumbai

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1287/MUM/2017[2012-13]Status: DisposedITAT Mumbai05 Apr 2021AY 2012-13

Bench: Shri S.Rifaur Rahman () & Shri Ravish Sood () Ita No.6083/Mum/2018 (Assessment Years: 2012-13 & 2014-15) Greatship (India) Ltd., Dy. Commissioner Of Income- C/O. Kalyaniwalla & Mistry, Vs. Tax-5(1)(1), Army & Navy Building, 3Rd Floor, Room No. 568, 5Th Floor, 148, Mahatma Gandhi Road, Aayakar Bhavan, M.K. Road, Fort, Mumbai – 400 001 Mumbai – 400 020

For Appellant: Shri M.M. Golvala &For Respondent: Shri Anand Mohan &
Section 143(3)Section 92BSection 92C

…ITA No. 1287/Mum/2017& ITA No. 6083/Mum/2018 1 A.Ys.2012-13 & 2014-15 Greatship (India) Ltd., Vs. DCIT-5(1)(1) IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “K” MUMBAI BEFORE SHRI S.RIFAUR RAHMAN (ACCOUNTANT MEMBER) AND SHRI RAVISH SOOD (JUDICIAL MEMBER) ITA No.6083/MUM/2018 (Assessment Years: 2012-13 & 2014-15) Greatship (India) Ltd., Dy. Commissioner of Income- C/o. Kalyaniwalla & Mistry, Vs. tax-5(1)(1), Army & Navy Building, 3rd Floor, Room No. 568, 5th Floor, 148, Mahatma Gandhi Road, Aayakar Bhavan, M.K. Road, Fort, Mumbai – 400 001 Mumbai – 400 020 PAN No. AABCG8542K (Assessee) (Revenue) Assess…

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6525/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…comparable transaction for the purpose of applying of CUP should be considered to be foreign currency lending by unrelated parties with the LIBOR. Referring to the decision of the Hon’ble Delhi High Court in the case of DCIT vs. Cotton Naturals (I) Pvt. Ltd., 276 CTR 445, he submitted that the Hon’ble High Court, while upholding the order of the Tribunal has held that the interest rate should be the market determined interest rate applicable to the currency concerned in which the loan has to be repaid. Referring to the decision of the Delhi Bench of the Tribunal in the case of Bharti Airtel Limited vs. ACIT, 161…

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 6256/DEL/2014[2008-09]Status: DisposedITAT Delhi18 Feb 2021AY 2008-09

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…comparable transaction for the purpose of applying of CUP should be considered to be foreign currency lending by unrelated parties with the LIBOR. Referring to the decision of the Hon’ble Delhi High Court in the case of DCIT vs. Cotton Naturals (I) Pvt. Ltd., 276 CTR 445, he submitted that the Hon’ble High Court, while upholding the order of the Tribunal has held that the interest rate should be the market determined interest rate applicable to the currency concerned in which the loan has to be repaid. Referring to the decision of the Delhi Bench of the Tribunal in the case of Bharti Airtel Limited vs. ACIT, 161…

M/S. Dabur India Ltd., New Delhi vs. Addl.CIT, New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3241/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Feb 2021AY 2007-08

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…comparable transaction for the purpose of applying of CUP should be considered to be foreign currency lending by unrelated parties with the LIBOR. Referring to the decision of the Hon’ble Delhi High Court in the case of DCIT vs. Cotton Naturals (I) Pvt. Ltd., 276 CTR 445, he submitted that the Hon’ble High Court, while upholding the order of the Tribunal has held that the interest rate should be the market determined interest rate applicable to the currency concerned in which the loan has to be repaid. Referring to the decision of the Delhi Bench of the Tribunal in the case of Bharti Airtel Limited vs. ACIT, 161…

DCIT, New Delhi vs. M/S. Dabur India Ltd., New Delhi

In the result, the appeals filed by the Revenue are partly allowed and the appeals filed by the assessee are partly allowed for statistical purposes

ITA 3114/DEL/2014[2007-08]Status: DisposedITAT Delhi18 Feb 2021AY 2007-08

Bench: Shri R.K. Panda & Ms Suchitra Kamble

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Shri Anupam Kant Garg, CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 80GSection 80ISection 92CSection 92E

…comparable transaction for the purpose of applying of CUP should be considered to be foreign currency lending by unrelated parties with the LIBOR. Referring to the decision of the Hon’ble Delhi High Court in the case of DCIT vs. Cotton Naturals (I) Pvt. Ltd., 276 CTR 445, he submitted that the Hon’ble High Court, while upholding the order of the Tribunal has held that the interest rate should be the market determined interest rate applicable to the currency concerned in which the loan has to be repaid. Referring to the decision of the Delhi Bench of the Tribunal in the case of Bharti Airtel Limited vs. ACIT, 161…

Aithent Technologies Pvt. Ltd., New Delhi vs. DCIT, Circle- 2(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 6293/DEL/2017[2005-06]Status: DisposedITAT Delhi05 Jan 2021AY 2005-06

Bench: Sh. H. S. Sidhudr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6293/Del/2017 : Asstt. Year : 2005-06 Aithent Technologies Pvt. Ltd., Vs Dcit, A-16/9, Vasant Vihar, Circle-2(1), New Delhi-110057 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacs2319H Assessee By : Sh. Atul Ninawat, Ar Revenue By : Sh. Surender Pal, Cit Dr. Date Of Hearing: 14.12.2020 Date Of Pronouncement: 05.01.2021 Order Per Dr. B.R.R. Kumar:

For Appellant: Sh. Atul Ninawat, ARFor Respondent: Sh. Surender Pal, CIT DR
Section 254

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I-1’, NEW DELHI Before Sh. H. S. Sidhu, Judicial Member Dr. B. R. R. Kumar, Accountant Member (Through Video Conferencing) ITA No. 6293/Del/2017 : Asstt. Year : 2005-06 Aithent Technologies Pvt. Ltd., Vs DCIT, A-16/9, Vasant Vihar, Circle-2(1), New Delhi-110057 New Delhi-110002 (APPELLANT) (RESPONDENT) PAN No. AAACS2319H Assessee by : Sh. Atul Ninawat, AR Revenue by : Sh. Surender Pal, CIT DR. Date of Hearing: 14.12.2020 Date of Pronouncement: 05.01.2021 ORDER Per Dr. B.R.R. Kumar, Accountant Member: The present appeal has been filed by the assessee against the…

M/S. Barco Electronic Systems (P) Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is allowed

ITA 1531/DEL/2016[2011-12]Status: DisposedITAT Delhi11 Nov 2020AY 2011-12
Section 143(2)Section 143(3)Section 144CSection 92BSection 92C

…ny case and without prejudice the Ld CIT(A) has also erred both in law and on facts in not applying the LIBOR rate for computation of interest in view of the judgment of jurisdictional High Court in the case of CIT Vs. Cotton Naturals (I) (P) Ltd. reported in 276 CTR 445. It is therefore prayed that, adjustment and addition so upheld by the Ld CIT(A) be deleted and appeal of the appellant company be allowed.” Barco Electronic Systems (P) ltd. vs. DCIT A.Y. 2011-12 4 4. Before us, at the outset, Learned AR submitted that though assessee has raised various grounds but the sole issue for adjudication is with respect…

Assotech Moonshine Urban Developers Pvt. Ltd., Noida vs. DCIT, New Delhi

The appeal of the assessee is allowed

ITA 1749/DEL/2017[2012-13]Status: DisposedITAT Delhi26 Aug 2020AY 2012-13

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

Section 143(3)Section 144CSection 234ASection 271Section 92Section 92C

…1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘I-1’ NEW DELHI BEFORE SHRI N. K. BILLAIYA, ACCOUNTANT MEMBER AND MS SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No. 1749/DEL/2017 (A.Y 2012-13) (THROUGH VIDEO CONFERENCING) Assotech Moonshine Urban Vs DCIT Developers Pvt. Ltd. Circle-3(2) Assotech One, C-20/1A/1, New Delhi Sesctor-62 Noida AAECM8184A (APPELLANT) (RESPONDENT) Appellant by Sh. Vishal Kalra & Sh. S. S. Tomar, Advs Respondent by Sh. Surender Pal, CIT(DR) Date of Hearing 13.08.2020 Date of Pronouncement 26 .08.2020 ORDER PER SUCHITRA KAMBLE, JM This appeal is filed by the assessee against t…

DCIT 1(3)(1), Mumbai vs. Serco Bpo Pvt. Ltd. 9Formerly Known As Intelenet Global Services Pvt. Ltd.), Mumbai

In the result this ground of appeal is partly allowed

ITA 1560/MUM/2015[2010-11]Status: DisposedITAT Mumbai17 Aug 2020AY 2010-11

Bench: Shri Pawan Singh & Shri M. Balaganesh & Vertual Court No. Iv Dcit, Circle 1(3)1, .M/S. Teleperformence Global Aayakar Bhavan, Services Private Limited, M.K. Road, (Earlier Known As “Intel Mumbai-400020 Global Services Private Vs. Limited”), Teleperformence Towers, Plot Cst No. 1406-A/28, Mindspace, Malad, (West) Mumbai-400090 Pan: Aabcv2572L Appellant Respondent

For Respondent: Shri J.D. Mistry Sr Advocate
Section 143(3)Section 144C(13)Section 254(1)

…IN THE INCOME-TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI M. BALAGANESH ACCOUNTANT MEMBER AND Vertual Court No. IV DCIT, Circle 1(3)1, .M/s. Teleperformence Global Aayakar Bhavan, Services Private Limited, M.K. Road, (Earlier Known as “Intel Mumbai-400020 Global Services Private Vs. Limited”), Teleperformence Towers, Plot CST No. 1406-A/28, Mindspace, Malad, (West) Mumbai-400090 PAN: AABCV2572L Appellant Respondent ITA No.5828/Mum/2015 (Assessment Year 2011-12) M/s. Teleperformence Global DCIT, Circle 1(3)1, Services Private Limited, (Earlier Aayakar Bhavan, Known a…

Serco Bpo P.Ltd, Mumbai vs. Asst CIT 1(3)(1), Mumbai

In the result this ground of appeal is partly allowed

ITA 5828/MUM/2015[2011-12]Status: DisposedITAT Mumbai17 Aug 2020AY 2011-12

Bench: Shri Pawan Singh & Shri M. Balaganesh & Vertual Court No. Iv Dcit, Circle 1(3)1, .M/S. Teleperformence Global Aayakar Bhavan, Services Private Limited, M.K. Road, (Earlier Known As “Intel Mumbai-400020 Global Services Private Vs. Limited”), Teleperformence Towers, Plot Cst No. 1406-A/28, Mindspace, Malad, (West) Mumbai-400090 Pan: Aabcv2572L Appellant Respondent

For Respondent: Shri J.D. Mistry Sr Advocate
Section 143(3)Section 144C(13)Section 254(1)

…IN THE INCOME-TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI M. BALAGANESH ACCOUNTANT MEMBER AND Vertual Court No. IV DCIT, Circle 1(3)1, .M/s. Teleperformence Global Aayakar Bhavan, Services Private Limited, M.K. Road, (Earlier Known as “Intel Mumbai-400020 Global Services Private Vs. Limited”), Teleperformence Towers, Plot CST No. 1406-A/28, Mindspace, Malad, (West) Mumbai-400090 PAN: AABCV2572L Appellant Respondent ITA No.5828/Mum/2015 (Assessment Year 2011-12) M/s. Teleperformence Global DCIT, Circle 1(3)1, Services Private Limited, (Earlier Aayakar Bhavan, Known a…