GAP International Sourcing India Pvt Ltd. v. ACIT

20 ITR (Trib) 779Income Tax Appellate Tribunal#23561 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Judgments citing GAP International Sourcing India Pvt Ltd. v. ACIT

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DCIT, CC-4, JAIPUR

In the result, the appeal of the assessee in ITA no

ITA 1144/JPR/2024[2020-21]Status: DisposedITAT Jaipur30 Jun 2025AY 2020-21

For Appellant: Shri Vinod Kumar Gupta, AdvFor Respondent: Shri Rajesh Ojha, CIT-DR

Section 115JSection 115QSection 143(3)Section 144C(5)Section 36(1)(va)

…the same and particularly as there is no value addition or involvement of unique intangibles, the berry ratio should also be equally relevant as in the case of a limited risk distributor. - 54. In the case of GAP International Sourcing India Pvt Ltd Vs ACIT [20 ITR (Trib) 779], a coordinate bench has upheld the use of this ratio. While taking note of the contentions of the assessee in this case, the coordinate bench has, inter alia, observed as follows: - 6.4 Ld. counsel then referred to the well recognized Berry ratio in determination of ALP. Berry ratio also propounds that routine distributors should earn a re…

VAIBHAV GLOBAL LIMITED,JAIPUR vs. DEPUTY COMMISSIONER OF INCOME TAX, JAIPUR, JAIPUR

In the result, the appeal of the assessee is allowed and disposed off in light of aforesaid directions

ITA 97/JPR/2021[2016-17]Status: DisposedITAT Jaipur07 Feb 2022AY 2016-17

Bench: Shri Sandeep Gosain & Shri Vikram Singh Yadavvaibhav Global Limited, Deputy Commissioner Of बनाम Jaipur. Income Tax, Central Circle-4, Jaipur. "थायी लेखा सं./Pan No: Aaacv4679F

For Appellant: Shri Vijay Mehta, C.AFor Respondent: Shri B.K. Gupta, Pr.CIT

Section 143(3)Section 144C(13)Section 234ASection 92CSection 92D

…or the same and particularly as there is no value addition or involvement of unique intangibles, the berry ratio should also be equally relevant as in the case of a limited risk distributor. 54. In the case of GAP International Sourcing India Pvt Ltd Vs ACIT [20 ITR (Trib) 779], a coordinate bench has upheld the use of this ratio. While taking note of the contentions of the assessee in this case, the coordinate bench has, inter alia, observed as follows: 6.4 Ld. counsel then referred to the well recognized Berry ratio in determination of ALP. Berry ratio also propounds that routine distributors should earn a ret…

GAP INTERNATIONAL SOURCING (INDIA) PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

ITA 1077/DEL/2016[2011-12]Status: DisposedITAT Delhi17 May 2016AY 2011-12

Bench: Shri R.S. Syal & Shri Kuldip Singh

For Appellant: S/Shri Rahul K. Mitra, Vinay VermaFor Respondent: Shri Amit Mohan Govil, CIT DR

Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘I-2’ : NEW DELHI) BEFORE SHRI R.S. SYAL, ACCOUNTANT MEMBER and SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No.1077/Del./2016 (ASSESSMENT YEAR : 2011-12) Gap International Sourcing (India) Pvt. Ltd., vs. DCIT, Circle 10 (1), Unit No.201, DLF South Court, New Delhi. District Centre, Saket, New Delhi. (PAN : AACCG3437E) (APPELLANT) (RESPONDENT) ASSESSEE BY : S/Shri Rahul K. Mitra, Vinay Verma, Ashish Jain, Adity Anand and Ms. Neeti Satija, CAs REVENUE BY : Shri Amit Mohan Govil, CIT DR Date of Hearing : 10.05.2016 Date of Order : 17.05.2016 O R D E R PER KULDIP…