Mattel Toys India (P.) Ltd. v. Dy. CIT

34 Taxmann.com 203Income Tax Appellate Tribunal2013#5437 most cited

What is Mattel Toys India (P.) Ltd. v. Dy. CIT authority for?

An assessee is not barred from deviating from a method applied in its own transfer pricing study for the current year if the facts of the case warrant the adoption of other methods to determine the arm's length price of international transactions.

22

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

Also referred to as

Mattel Toys India · 34 taxmann.com 203 · ITAT · transfer pricing · ALP · international transactions · most appropriate method · TNMM · CPM · TPSR · Form 3CEB

Judgments citing Mattel Toys India (P.) Ltd. v. Dy. CIT

RFS INDIA TELECOM PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, appeal of the assessee is allowed

ITA 2040/DEL/2017[2012-13]Status: DisposedITAT Delhi11 Nov 2020AY 2012-13

Bench: Sh. Anil Chaturvedi & Sh. Kuldip Singh(Through Video Conferencing) Rfs India Telecom Pvt. Vs. Acit Ltd. Circle – 21(1), E-8/1, Lower Ground Floor New Delhi Near Geeta Bhawan Mandir, Malviya Nagar Pan No. Aadcr 5389 R (Appellant) (Respondent) Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agarwal, Adv. Revenue By Shri Anupam Kant Garg, Cit-D.R. Date Of Hearing: 04/11/2020 Date Of Pronouncement: 11/11/2020 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of The Assessing Officer U/S 143(3)/ 144C/ 92Ca(4) Of The Act, 1961, Pursuant To The Directions Given By The Drp, Passed U/S 144C(5) Of The Income-Tax Act, 1961 Dated 19.12.2016 Relating To Assessment Year 2012-13. Rfs India Telecom Pvt. Ltd. Vs. Acit A.Y. 2012-13 2 2. The Relevant Facts As Culled From The Material On Records Are As Under:

Section 142(1)Section 143(2)Section 143(3)Section 144CSection 144C(5)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘I-2’, NEW DELHI BEFORE SH. ANIL CHATURVEDI, ACCOUNTANT MEMBER AND SH. KULDIP SINGH, JUDICIAL MEMBER (THROUGH VIDEO CONFERENCING) RFS India Telecom Pvt. Vs. ACIT Ltd. Circle – 21(1), E-8/1, Lower Ground Floor New Delhi Near Geeta Bhawan Mandir, Malviya Nagar PAN No. AADCR 5389 R (APPELLANT) (RESPONDENT) Assessee by Shri Neeraj Jain, Adv. Shri Abhishek Agarwal, Adv. Revenue by Shri Anupam Kant Garg, CIT-D.R. Date of hearing: 04/11/2020 Date of Pronouncement: 11/11/2020 ORDER PER ANIL CHATURVEDI, AM: This appeal filed by the assessee is directed against the order o…

TOPCON SOKKIA INDIA PVT. LTD.,NEW DELHI vs. DCIT, CIRCLE- 25(2), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 8110/DEL/2018[2014-15]Status: DisposedITAT Delhi29 Jun 2020AY 2014-15

Bench: Sh. Anil Chaturvedi & Ms Suchitra Kamble(Through Video Conferencing) Assessment Year: 2014-15 Topcon Sokkia India Pvt. Vs. Dcit Ltd., Unit No.101 To 106A, Circle- 25 (2) Abw Tower, 1St Floor, New Delhi Mg Road, Iffco Chowk, Sector-25, Gurgaon, Haryana – 122 001 Pan No. Aaccs 9107 K (Appellant) (Respondent) Appellant By Sh. Neeraj Jain, Adv. Sh. Ramit Katyal, C.A. Respondent By Sh. M. Barhwal, Sr. D.R. Date Of Hearing: 23/06/2020 Date Of Pronouncement: 29/06/2020 Order Per Anil Chaturvedi, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.10.2018 Passed By The Dcit, Circle 25(2) New Delhi Pursuant To The Directions Of Drp, Relating To Assessment Year 2014-15. 2. The Relevant Facts As Culled From The Material On Records Are As Under:

Section 143(3)Section 144CSection 144C(5)Section 234DSection 271(1)(c)Section 92C

…urt in the case of Matrix Cellular International Services P Ltd (90 Taxmann.com 54), Delhi Bench of Tribunal in case of Swarovski India Pvt. Ltd. Vs ACIT [(2017) 78 taxmann.com 325 (Del)], Mumbai Tribunal in the case of Mattel Toys India P Ltd Vs DCIT [(2013) 34 Taxmann.com 203], Delhi Tribunal in the case of Nokia (India) Pvt. Ltd.(ITA No.242/Del/2010) and Videojet Technologies (I) P Ltd Vs ACIT (ITA No 6956/Mum/2012). 17. We further find that the Pune Benches of the Tribunal in the case of ACIT vs MSS India Pvt Ltd ((2009) 123 TTJ 657 (Pune) has observed as under: “While there is no particular order or priority…

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