Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. v. Addl.CIT & Anr.

197 TTJ 393Income Tax Appellate Tribunal2019#15194 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 350,364 Indian tax judgments — from 2019 to 2019.

Judgments citing Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. v. Addl.CIT & Anr.

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1066/PUN/2017[2011-12]Status: DisposedITAT Pune27 Jun 2019AY 2011-12

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1065/PUN/2017[2010-11]Status: DisposedITAT Pune27 Jun 2019AY 2010-11

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1064/PUN/2017[2009-10]Status: DisposedITAT Pune27 Jun 2019AY 2009-10

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1063/PUN/2017[2008-09]Status: DisposedITAT Pune27 Jun 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method

ITA 1062/PUN/2017[2007-08]Status: DisposedITAT Pune27 Jun 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14

For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)

…and findings of TPO in this regard were referred at pages 73 to 76 of TPO order. The Ld. DR placed reliance on the decisions in DIT (IT) Vs. Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. Vs. Addl.CIT & Anr. (2019) 197 TTJ 393 (Del) and Google India Pvt. Ltd. & Ors. Vs. Jt.DIT (IT) & Ors. (2018) 194 TTJ 385 (Bang). The Ld. DR stressed that TPO had carried out FAR analysis of transaction which was a very important part of TP analysis and it is wrong to say and vide para 15 of written note, it is stressed that, the TPO had not benchmarked any transaction of control and m…

Morgan Stanley & Co. Inc. (2007) 292 ITR 416 (SC), Pepsico India Holdings Pvt. Ltd. & Anr. v. Addl.CIT & Anr. (197 TTJ 393) — Cited in 6 Judgments | BharatTax