Clestra Life Sciences P.Ltd, Mumbai vs. ITO WD 10(3)(1), Mumbai
In the result, the assessee’s appeal for A
ITA 6962/MUM/2014[2002-03]Status: DisposedITAT Mumbai02 Sept 2016AY 2002-03
Bench: Shri Shailendra Kumar Yadav & Shri Jason P. Boazm/S. Clestra Life Sciences P. Ltd. Ito, Ward 10(3)(1) (Formerly As Brahma Drugs P. Ltd.) 4Th Floor, Aayakar Bhavan ‘A’ Wing. 604 Delphi Orchid Vs. M.K. Road, Mumbai 400020 Avenue, Hiranandani Business Park, Powai, Mumbai 400076 Pan - Aaacb5795L Appellant Respondent
For Appellant: Shri Jitendra SanghviFor Respondent: Shri Sher Singh
Section 143(3)Section 271(1)(c)Section 274Section 80HSection 92C
…evied under section 271(1)(c) of the Act, on the adjustment made in transfer pricing audit, the assessee placed reliance on the decision of the Coordinate Bench of the ITAT - Delhi in the case of Mitsui Prime Advanced Composite India (P.) Ltd. vs. DCIT (2016) 178 TTJ 490 (Delhi- Trib). 3.3.1 Per contra, the learned D.R. for Revenue placed strong reliance on the decision of the learned CIT(A) in the impugned order in sustaining the levy of penalty under section 271(1)(c) of the Act on the transfer pricing adjustment of ALP at `3,86,810/-. According to the learned D.R., as per the facts of the case on hand, both th…