How many judgments cite Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO?

42 judgments on BharatTax cite Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO (137 ITD 21), spanning 2014 to 2025.

Which sections of the Income Tax Act does Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO come up under?

It is most often cited in judgments turning on Section 10B(1)(a), Section 10B(1)(e), Section 92, Section 92CA.

Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO

137 ITD 21Income Tax Appellate Tribunal2012#2824 most cited

What is Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO authority for?

The Transfer Pricing Officer (TPO) is empowered to determine the Arm's Length Price (ALP) of an international transaction at "nil" if the assessee fails to establish that payments made to an Associated Enterprise (AE) were commensurate with the benefit received or the quality of services availed. This determination constitutes an adjustment to ALP, distinct from a disallowance of expenditure.

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2014 to 2025.

Also referred to as

Delloite Consulting India · 137 ITD 21 · 22 Taxmann.com 107 · section 92 · section 92CA · arm's length price nil · TPO power · commensurate benefit · international transaction · associated enterprises · transfer pricing adjustment · management consultancy services

Also reported as

22 Taxmann.com 107

Sections most often in play

Section 10B(1)(a)Section 10B(1)(e)Section 92 Section 92CA

Issues it is cited on

most appropriate method cup method arm's length price associated enterprises associated enterprise international transaction transfer pricing adjustment tnmm section 92 section 92ca section 92c final assessment order

Judgments citing Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO

KANTAR ANALYTICS INDIA PRIVATE LIMITED (FORMERLY KNOWN AS FIREFLY MARKET RESERCH INDIA PRIVATE LIMITED (SUCCESSOR OF ANALYTICS QUOTIENT SERVICE INDIA PRIVATE LIMITED),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

ITA 4733/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Nov 2025AY 2020-21

Section 143(3)Section 153Section 270ASection 92CSection 92C(1)

…the AEs. Also, when there are\nno services availed, there is no question of benchmarking the\ntransaction and in such cases; determination of ALP at Rs NIL has been\nupheld by the Hon'ble ITAT in the case of Deloitte Consulting India Pvt.\nLtd. vs DCIT (2012)137 ITD 21 (Mumbai).\n19 Conclusion:\nHence, in light of the of the discussion, the arm's length price of fee paid\nfor management consultancy services is treated as Rs.NIL due to\ninadequacy of the taxpayer's argument and the entire payment of fee\npaid for management consultancy services of Rs.5,52,62,002/- is\ntreated as an adjustment to ALP to the intern…

COMMISSIONER OF INCOME TAX vs. BENETTON INDIA PVT. LTD.

ITA/472/2018HC Delhi06 Feb 2025

Bench: CASES PERTAINING TO SPL.DIVISION BENCHES

For Appellant: Mr. Shlok Chandra, SSC with Ms. MadhviFor Respondent: Mr. Himanshu S. Sinha, Mr. Prashant

Section 143(1)Section 260ASection 92BSection 92C

…lowing expenditure. That decision is outside the authority of the Transfer Pricing Officer. This aspect was made clear by the Income-tax Appellate Tribunal in Deloitte Consulting India Pvt. Ltd. v. Deputy CIT/ITO (2012) 19 ITR (Trib) 378 (Mumbai) ; (2012) 137 ITD 21 (Mumbai): “37.On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India P. Ltd. 2010-TII- 55-ITAT-BANG- TP, held that the assessee has to establish before the Transfer Pricing Officer that the payments made were commens…

CATERPILLAR FINANCIAL SERVIES INDIA PRIVATE LIMITED,WHITEFIELD,BANGALORE,KARNATAKA vs. ASSESSMENT UNIT, INCOME TAX DEPARTMENT, JURISDICTIONAL AO - ACIT, CIRCLE 2(2)(1)), BMTC BUILDING, KORAMANGALA, BENGALURU

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1621/BANG/2024[2020-21]Status: FixedITAT Bangalore04 Feb 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Nageswar Rao, AdvocateFor Respondent: Shri Sridhar E, CIT (DR)

Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER IT(TP)A No.1621/Bang/2024 Assessment Years : 2020-21 Caterpillar Financial Services India Pvt. Vs. The Asst. Commissioner of Ltd., Income Tax, Ground Floor, Crescent 1, Prestige Circle – 2(2)(1), Shantiniketan, Whitefield, Hood B.O, Bengaluru. Bangalore North, Bangalore – 560048. PAN – AAHCC 7975 L APPELLANT RESPONDENT Assessee by : Shri Nageswar Rao, Advocate Revenue by : Shri Sridhar E, CIT (DR) Date of hearing : 11.11.2024 Date of Pronouncement : 04.02.2025 O R…

VODAFONE INDIA LTD,MUMBAI vs. DCIT 7(3), MUMBAI

In the result, the appeal of the assessee is treated as allowed and the appeal of the revenue is dismissed

ITA 1121/MUM/2014[2009-10]Status: DisposedITAT Mumbai08 Nov 2023AY 2009-10

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 143(3)Section 3Section 80Section 80I

…sessee did not benefit from these services, which amounts to disallowing expenditure. That decision is outside the authority of the TPO. This aspect was made clear by the ITAT in Delloite Consulting India Pvt. Ltd. v. Deputy Commissioner of Income Tax, [2012] 137 ITD 21 (Mum): 26 M/s. Vodafone India Ltd. "37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India P. Ltd. 2010-TII-55-ITAT-BANG- TP, held that the assessee has to establish before the Transfer Pricing Officer that the paymen…

DCIT, CIR- 4(2)(1), MUMBAI vs. HAMON COOLING SYSTEMS PVT. LTD., MUMBAI

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 2398/MUM/2021[2013-14]Status: DisposedITAT Mumbai06 Sept 2023AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Narender Kumar Choudhry (Jm)

…sessee did not benefit from these services, which amounts to disallowing expenditure. That decision is outside the authority of the TPO. This aspect was made clear by the ITAT in Delloite Consulting India Pvt. Ltd. v. Deputy Commissioner of Income Tax, [2012] 137 ITD 21 (Mum): "37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India P. Ltd. 2010-TII-55-ITAT-BANG-TP, held that the assessee has to establish before the Transfer Pricing Officer that the payments made were commensurate to t…

MENZIES BOBBA GROUND HANDLING SERVICES P. LTD., HYD,HYDERABAD vs. DCIT, CIRLCE-16(2), HYD, HYDERABAD

In the result, both the appeals are partly allowed

ITA 864/HYD/2016[2011-12]Status: DisposedITAT Hyderabad18 Jul 2023AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Darpan Kirpalani, ARFor Respondent: Shri Kumar Aditya, DR

…आयकर अपीलीय अधिकरण, हैदराबाद पीठ में IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B”, HYDERABAD BEFORE SHRI RAMA KANTA PANDA, VICE PRESIDENT & SHRI K. NARASIMHA CHARY, JUDICIAL MEMBER आ.अपी.सं / निर्धारण अपीलधर्थी / प्रत्‍यर्थी / वर्ा / A.Y. ITA No. Appellant Respondent The Deputy Menzies Bobba Ground 863/Hyd/2016 2010-11 Commissioner of Handling Services Income Tax, Private Limited, Circle-16(2), Hyderabad 864/Hyd/2016 2011-12 Hyderabad [PAN No. AAFCM0724P] निर्धाररती द्वधरध/Assessee by: Shri Darpan Kirpalani, AR रधजस्‍व द्वधरध/Revenue by: Shri Kumar Aditya, DR सुिवधई की तधरीख/Date of hearing: 06/0…

MENZIES BOBBA GROUND HANDLING SERVICES P. LTD., HYD,HYDERABAD vs. DCIT, CIRLCE-16(2), HYD, HYDERABAD

In the result, both the appeals are partly allowed

ITA 863/HYD/2016[2010-11]Status: DisposedITAT Hyderabad18 Jul 2023AY 2010-11

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri Darpan Kirpalani, ARFor Respondent: Shri Kumar Aditya, DR

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

ITA 1639/KOL/2019[2013-14]Status: DisposedITAT Kolkata27 Apr 2023AY 2013-14

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R

Section 143(3)Section 14A

…TPO stating that the assessee did not benefit from these services, which amounts to disallowing expenditure. That decision is outside the authority of the TPO. This aspect was made clear by the ITAT in Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO [2012] 137 ITD 21/22 taxmann.com 107 (Mum): AY 2012-13 AY 2013-14 Apollo Gleneagles Hospital Ltd. 21 '37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India (P.) Ltd. v. Asstt. CIT [IT Appeal No. 352 (Bang.) of 2009, dated 20- 10-2010] h…

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

ITA 1501/KOL/2019[2012-13]Status: DisposedITAT Kolkata27 Apr 2023AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R

Section 143(3)Section 14A

GIVAUNDAN(INDIA) PVT. LTD.,BANGALORE vs. ACIT ,LTU CR 1, BANGALORE

In the result the appeal filed by assessee stands allowed for statistical purposes

ITA 229/BANG/2015[2010-2011]Status: DisposedITAT Bangalore29 Mar 2022AY 2010-2011

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 229/Bang/2015 Assessment Year : 2010-11 M/S. Givaudan (India) The Assistant Pvt. Ltd., Commissioner Of Plot No. 26, 2Nd Cross, Income Tax, Jigani Industrial Area, Ltu, Bangalore – 562 106. Circle – 1, Vs. Pan: Aaacv7454J Bangalore. Appellant Respondent Assessee By : Shri Sumeet Khurana, Ca : Shri Sumer Singh Meena, Cit- Revenue By I Date Of Hearing : 11-01-2022 Date Of Pronouncement : 29-03-2022 Order Per Beena Pillaiit Is Submitted That The Main Appeal Was Heard By This Tribunal & Order Was Passed On 02/08/2019. However Grounds 6 & 7 Were Not Adjudicated Independently For Assessment Year 2010- 11. The Assessee Preferred Mp No.15/Bang/2020 Requesting For Adjudication Of These Grounds. 2. Accordingly The Present Appeal Is Fixed For Hearing For Adjudication Of Following Grounds: “6. That The Learned Ao & The Learned Panel Erred Both In Facts & Law In Confirming The Action Of The Learned Tpo Of Making An Adjustment To The Transfer Price Of The Appellant In Respect Of The Payment Of Royalty By Rs.27,67,42,242, Holding That The International Transaction

For Appellant: Shri Sumeet Khurana, CA

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI. B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 229/Bang/2015 Assessment Year : 2010-11 M/s. Givaudan (India) The Assistant Pvt. Ltd., Commissioner of Plot No. 26, 2nd Cross, Income Tax, Jigani Industrial Area, LTU, Bangalore – 562 106. Circle – 1, Vs. PAN: AAACV7454J Bangalore. APPELLANT RESPONDENT Assessee by : Shri Sumeet Khurana, CA : Shri Sumer Singh Meena, CIT- Revenue by I Date of Hearing : 11-01-2022 Date of Pronouncement : 29-03-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER It is submitted that the…

M/S. WATERS (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 7(1)(2), BANGALORE

In the result, the appeals filed by the assessee for assessment year 2010-2011 and 2011-2012 are partly allowed

ITA 2617/BANG/2019[2011-12]Status: DisposedITAT Bangalore01 Oct 2021AY 2011-12

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am It(Tp)A No.2616/Bang/2019 : Asst.Year 2010-2011 It(Tp)A No.2617/Bang/2019 : Asst.Year 2011-2012 M/S.Waters (India) Private Limited The Dy.Commissioner Of No.36A, 2Nd Phase, Income-Tax, Circle 12(5) V. Bangalore. Peenya Industrial Area Bengaluru – 560 058. Pan : Aaacw1411C. (Appellant) (Respondent) Appellant By : Smt.G.Vaidehi, Adovcate Respondent By : Sri.Priyardarshi Mishra, Addl.Cit-Dr Date Of Pronouncement : 01.10.2021 Date Of Hearing : 28.09.2021 O R D E R Per George George K, Jm These Appeals At The Instance Of The Assessee Are Directed Against Two Orders Of The Cit(A), Both Dated 30.10.2019. The Relevant Assessment Years Are 2010-2011 & 2011-2012. Common Issues Are Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Of By This Consolidated Order.

For Appellant: Smt.G.Vaidehi, AdovcateFor Respondent: Sri.Priyardarshi Mishra, Addl.CIT-DR

Section 40

…e is No. evidence of services having been rendered at all, the arm's length price of these services is 'nil'." 22. Another aspect that was made clear by coordinate bench of this Tribunal in Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO reported in [2012] 137 ITD 21/22 taxmann.com 107 (Mum) is that: '37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India (P.) Ltd. v. Asstt. CIT [IT Appeal No. 352 (Bang.) of 2009, dated 20-10- 2010] held that the assessee has to establish before the…

M/S. WATERS (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 12(5), BANGALORE

In the result, the appeals filed by the assessee for assessment year 2010-2011 and 2011-2012 are partly allowed

ITA 2616/BANG/2019[2010-11]Status: DisposedITAT Bangalore01 Oct 2021AY 2010-11

For Appellant: Smt.G.Vaidehi, AdovcateFor Respondent: Sri.Priyardarshi Mishra, Addl.CIT-DR

Section 40

M/S DISA INDIA LTD ,BANGALORE vs. INCOME TAX OFFICER WARD-2(1)(3), BANGALORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2196/BANG/2017[2013-14]Status: DisposedITAT Bangalore12 Jan 2021AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm It(Tp)A No.2196/Bang/2017 : Asst.Year 2013-2014 M/S.Disa India Limited The Income Tax Officer 5Th Floor, Kushal Garden Arcade Ward 2(1)(3) V. 1A, Peenya Industrial Area Bangalore. Peenya 2Nd Phase Bangalore – 560 058. Pan : Aaacg5030F. (Appellant) (Respondent) Appellant By : Sri.K.R.Vasudevan, Advocate Respondent By : Sri.Sunil Kumar Singh, Cit-Dr Date Of Date Of Hearing : 12.01.2021 Pronouncement : 12.01.2021 O R D E R Per George George K, Jm This Appeal At The Instance Of The Assessee Is Directed Against The Final Assessment Order Dated 21.09.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2013-2014. 2. The Assessee Has Raised Seven Grounds. All The Grounds Relate To The Solitary Issue Regarding Arms Length Price (Alp) Adjustment Amounting To Rs.1,33,76,590 Made To Group Service Fees Paid By The Assessee To Its Associate Enterprises (Aes).

For Appellant: Sri.K.R.Vasudevan, AdvocateFor Respondent: Sri.Sunil Kumar Singh, CIT-DR

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

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “A”, BANGALORE Before Shri Chandra Poojari, AM & Shri George George K, JM IT(TP)A No.2196/Bang/2017 : Asst.Year 2013-2014 M/s.Disa India Limited The Income Tax Officer 5th Floor, Kushal Garden Arcade Ward 2(1)(3) v. 1A, Peenya Industrial Area Bangalore. Peenya 2nd Phase Bangalore – 560 058. PAN : AAACG5030F. (Appellant) (Respondent) Appellant by : Sri.K.R.Vasudevan, Advocate Respondent by : Sri.Sunil Kumar Singh, CIT-DR Date of Date of Hearing : 12.01.2021 Pronouncement : 12.01.2021 O R D E R Per George George K, JM This appeal at the instance of the assessee…

M/S. DISA INDIA LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 290/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 Nov 2020AY 2012-13

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No.290/Bang/2017 Assessment Year : 2012 – 13

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Shri Farhat Hussain Qureshi, CIT

Section 143Section 144C(13)Section 234ASection 40Section 92C

…e is No. evidence of services having been rendered at all, the arm's length price of these services is 'nil'." 23. Another aspect that was made clear by coordinate bench of this Tribunal in Delloite Consulting India (P.) Ltd. v. Dy. CIT/ITO reported in [2012] 137 ITD 21/22 taxmann.com 107 (Mum) is that: '37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India (P.) Ltd. v. Asstt. CIT [IT Appeal No. 352 (Bang.) of 2009, dated 20- 10- 2010] held that the assessee has to establish before th…

M/S. DENSO INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed for statistical purpose

ITA 1078/DEL/2016[2011-12]Status: DisposedITAT Delhi23 Nov 2020AY 2011-12

Bench: Shri R. K. Panda & Ms Suchitra Kamble(Through Video Conferencing) Denso India Pvt. Ltd. Vs Dcit B-1/D4, Ground Floor, Circle-7(1) Mohan Cooperative Industrial New Delhi Estate, Mathura Road New Delhi (Respondent) Aaacd4255F (Appellant) Appellant By Sh. Ravi Sharma, Adv & Sh. Anubhav Rastogi, Adv Respondent By Sh. Surendar Pal, Cit Dr Date Of Hearing 01.09.2020 Date Of Pronouncement 23.11.2020

Section 144Section 254Section 92CSection 92D

…costs involved and service India (P) Ld V SD actually rendered should be provided. CIT/ITO ITAT held ALP rightly determined at nil since (2012) 22 assessee had not furnish evidence to prove that Taxmann.com three personnel had rendered marketing services 107/137 ITD 21/19 to company. ITR (TRIB) 378/150 TTJ 824 (MUM) Nike India Pvt. Ltd Payments of cross charges of expats costs and [ITA No 653-654 of contractor charges claimed as reimbursements to 2011 (Bang)] the parent company. Tribunal confirmed TPO’s finding that these expenses could not have been solely and 21 exclusively for distribution business of the ta…

SABMILLER INDIA LTD,MUMBAI vs. ASST CIT CIR 11(1)(2), MUMBAI

In the result, Revenue’s appeal is dismissed

ITA 1205/MUM/2016[2011-12]Status: DisposedITAT Mumbai18 Feb 2020AY 2011-12

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri Rajan R. Vora a/wFor Respondent: Shri Anand Mohan

Section 143(3)Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBERAND SHRI N.K. PRADHAN, ACCOUNTANT MEMBER ITA no.1205/Mum./2016 (Assessment Year : 2011–12) Asstt. Commissioner of Income Tax ……………. Appellant Circle–11(1)(2), Mumbai v/s Anheuser Busch InBev India Ltd. (Earlier known as SABMiller India Ltd.) Unit no.301/302, 3rd Floor ……………. Respondent Dynasty Business Park, “B” Wing Andheri Kurla Road, Aneheri (E) Mumbai 400 059 PAN–AAICS2238R ITA no.1738/Mum./2016 (Assessment Year : 2011–12) Anheuser Busch InBev India Ltd. (Earlier known as SABMiller India Ltd.) Unit no.301/302,…

NYMPHEA DEVELOPERS PVT LTD,NEW DELHI vs. ACIT CIRCLE-19(1), NEW DELHI

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7555/DEL/2019[2014-15]Status: DisposedITAT Delhi03 Feb 2020AY 2014-15

Bench: Shri Sudhanshu Srivastava & Shri O.P. Kantassessment Year: 2014-15

Section 143(2)

…sessee did not benefit from these services, which amounts to disallowing expenditure. That decision is outside the authority of the TPO. This aspect was made clear by the ITAT in Delloite Consulting India Pvt. Ltd. v. Deputy Commissioner of Income Tax, [2012] 137 ITD 21 (Mum): "37. On the issue as to whether the Transfer Pricing Officer is empowered to determine the arm's length price at "nil", we find that the Bangalore Bench of the Tribunal in Gemplus India P. Ltd. 2010-TII-55-ITAT-BANG-TP, held that the assessee has to establish before the Transfer Pricing Officer that the payments made were commensurate to th…

IPSOS RESEARCH P. LTD,MUMBAI vs. ASST CIT 10(1)(2), MUMBAI

In the result, the appeal of the assessee is allowed

ITA 1361/MUM/2017[2012-13]Status: DisposedITAT Mumbai11 Dec 2019AY 2012-13

Bench: Shri M.Balaganesh, Am & Shri Ravish Sood, Jm M/S Ipsos Research Pvt. Vs. Acit-2(2)(1), Mumbai Ltd. (In Which Synovate India Private Limited Has Been Amalgamated), Lotus Corporate Park, Unit No.1701, 17Th Floor, F Wing, Off Western Express Highway, Goregaon (East), Mumbai-400063 Pan No.Aaace 1157 B (Appellant) .. (Respondent) Assessee By Shri Nishant Thakkar/Jasmin Annalsadvals Revenue By Shri Manjunath K/Anand Mohan, Citdr Date Of Hearing 29/11/2019 Date Of Pronouncement 11/12/2019

Section 144C(1)Section 144C(5)

…IN THE INCOME TAX APPELLATE TRIBUNAL “ K”, BENCH MUMBAI BEFORE SHRI M.BALAGANESH, AM & SHRI RAVISH SOOD, JM M/s Ipsos Research Pvt. Vs. ACIT-2(2)(1), Mumbai Ltd. (in which Synovate India Private Limited has been amalgamated), Lotus Corporate Park, Unit No.1701, 17th Floor, F Wing, Off Western Express Highway, Goregaon (East), Mumbai-400063 PAN No.AAACE 1157 B (Appellant) .. (Respondent) Assessee by Shri Nishant Thakkar/Jasmin Annalsadvals Revenue by Shri Manjunath K/Anand Mohan, CITDR Date of Hearing 29/11/2019 Date of Pronouncement 11/12/2019 आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.1…

CWT INDIA P.LTD,MUMBAI vs. ASST CIT CIR 9(2)(2), MUMBAI

In the result the ground No

ITA 5996/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Jul 2019AY 2014-15

Bench: Shri G. S. Pannu, Vice- & Shri Pawan Singhm/S Cwt India Pvt. Ltd. Acit Circle-9(2)(2) Unit No.2, Raheja Centre, Aayakar Bhavan, M.K. Vs. Ground Floor, Free Press Road, Mumbai- Journal Marg, Nariman Point, 400020. Mumbai-400021 Pan: Aaaci7084H Appellant Respondent M/S Cwt India Pvt. Ltd. Acit Circle-9(2)(2) Unit No.2, Raheja Centre, Aayakar Bhavan, M.K. Vs. Ground Floor, Free Press Road, Mumbai- Journal Marg, Nariman Point, 400020. Mumbai-400021 Pan: Aaaci7084H Appellant Respondent : Shri Mukesh Butani With Appellant By Shri Shreyash Shah (Ar) Respondent By : Shri Anand Mohan (Dr) Date Of Hearing : 18.06.2019 Date Of Pronouncement : 25.07.2019 Order Under Section 254(1)Of Income Tax Act

For Respondent: Shri Mukesh Butani with

Section 143(3)Section 144C(6)Section 234BSection 254(1)Section 271Section 274Section 92C

…IN THE INCOME-TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI G. S. PANNU, VICE-PRESIDENT AND SHRI PAWAN SINGH, JUDICIAL MEMBER M/s CWT India Pvt. Ltd. ACIT Circle-9(2)(2) Unit No.2, Raheja Centre, Aayakar Bhavan, M.K. Vs. Ground Floor, Free Press Road, Mumbai- Journal Marg, Nariman Point, 400020. Mumbai-400021 PAN: AAACI7084H Appellant Respondent M/s CWT India Pvt. Ltd. ACIT Circle-9(2)(2) Unit No.2, Raheja Centre, Aayakar Bhavan, M.K. Vs. Ground Floor, Free Press Road, Mumbai- Journal Marg, Nariman Point, 400020. Mumbai-400021 PAN: AAACI7084H Appellant Respondent : Shri Mukesh Butani with Appellant by Sh…

FCB ADVERTISING P. LTD,MUMBAI vs. ASST CIT CIR 3(1)(2), MUMBAI

The appeal stands allowed in terms of our above order

ITA 2194/MUM/2017[2012-13]Status: DisposedITAT Mumbai25 Jun 2019AY 2012-13

Bench: Hon’Ble Shri Saktijit Dey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Mr. Ajit Kumar Jain & Mr. SiddheshFor Respondent: Mr. Rignesh Das, Ld. DR

Section 143(3)Section 144C(13)Section 144C(5)Section 234BSection 40

…1 IT(TP)A No.2194/Mum/2017 M/s FCB Ulka Advertising Pvt. Ltd. Assessment Year 2012-13 आयकर अपीलीय अिधकरण “के” "ायपीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI माननीय "ी श""जीत दे, "ाियक सद" एवं माननीय माननीय माननीय माननीय "ी मनोज कुमार अ"वाल, लेखा सद" के सम"। माननीय माननीय माननीय BEFORE HON’BLE SHRI SAKTIJIT DEY, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपील सं./ I.T(TP).A. No. 2194/Mum/2017 (िनधा"रण िनधा"रण िनधा"रण वष" िनधा"रण वष" वष" / Assessment Year: 2012-13) वष" FCB Ulka Advertising Pvt. Ltd Assistant Commissioner of (Earlier known as Draft FCB Ulka Income Tax-Circle 3(1)(2…

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