PCIT v. Sony Ericson Mobile Communication India (P) Ltd.

127 Taxmann.com 356High Court#13362 most cited
7

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2022 to 2022.

Issues it is cited on

cost plus methoddirections of the drpsection 292binterest u/s 234apermanent establishmenttransfer pricing adjustmentsection 144c(13)section 292penalty u/s 271(1)(c)dispute resolution panelsection 29section 144c

Judgments citing PCIT v. Sony Ericson Mobile Communication India (P) Ltd.

ACCENTURE SOLUTION PVT. LTD,MUMBAI vs. DCIT, CIRCLE 14(1)(1), MUMBAI

In the result, appeal by assessee is allowed in the terms aforesaid

ITA 7457/MUM/2018[2014-15]Status: DisposedITAT Mumbai23 Mar 2022AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं. 7457/मुं/2018 ("न. व. 2014-15 ) Accenture Solutions Private Limited(‘Asol) [As A Successor To Accenture Services Private Limited (“Aspl”) Which Has Merged Into Asol With An Effective Date Of 1 December 2016] Plant 3, Godrej & Boyce Complex, Phirojshah Nagar, Vikhroli West, Off Lbs Marg, Mumbai 400 079. Pan: Aaach-3235-M ...... अपीलाथ" /Appellant बनाम Vs. The Deputy Commissioner Of Income Tax, Circle 14(1)(1), Aaykar Bhavan, M.K.Road, Mumbai 400 021 ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By : Shri Percy J. Pardiwalla, Sr. Advocate With Shri Hiten Chande ""तवाद" "वारा/Respondent By : Dr.Yogesh Kamat Cit Dr & Shri Satya Pinisetty सुनवाई क" "त"थ/ Date Of Hearing : 01/02/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 23/03/2022 आदेश/ Order Per Vikas Awasthy, Jm:

For Appellant: Shri Percy J. Pardiwalla, Sr. Advocate with Shri Hiten ChandeFor Respondent: Dr.Yogesh Kamat CIT DR &
Section 143(2)Section 143(3)Section 144C(13)Section 92C

…आयकर अपील"य अ"धकरण मुंबई पीठ “के ” "ी "वकास अव"थी, "या"यक सद"य एवं "ी एम. बालगणेश, लेखा सद"य के सम" IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “K”, MUMBAI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER & SHRI M. BALAGANESH, ACCOUNTANT MEMBER आअसं. 7457/मुं/2018 ("न. व. 2014-15 ) Accenture Solutions Private Limited(‘ASOL) [as a successor to Accenture Services Private Limited (“ASPL”) which has merged into ASOL With an effective date of 1 December 2016] Plant 3, Godrej & Boyce Complex, Phirojshah Nagar, Vikhroli West, Off LBS Marg, Mumbai 400 079. PAN: AAACH-3235-M ...... अपीलाथ" /Appellant बनाम Vs. The Deput…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 5022/DEL/2018[2014-15]Status: DisposedITAT Delhi07 Feb 2022AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 5021/DEL/2018[2010-11]Status: DisposedITAT Delhi07 Feb 2022AY 2010-11

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 5020/DEL/2018[2009-10]Status: DisposedITAT Delhi07 Feb 2022AY 2009-10

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 4561/DEL/2018[2006-07]Status: DisposedITAT Delhi07 Feb 2022AY 2006-07

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 4560/DEL/2018[2005-06]Status: DisposedITAT Delhi07 Feb 2022AY 2005-06

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

LG ELECTRONICS INC., KOREA (LGEK),NOIDA vs. DCIT, CIRCLE- 2(2)(1), INTERNATIONAL TAXATION , NEW DELHI

In the result, the appeals of the assessee in:

ITA 4559/DEL/2018[2004-05]Status: DisposedITAT Delhi07 Feb 2022AY 2004-05

Bench: Shri N.K. Billaiya & Ms. Astha Chandra

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Ms. Anupama Anand, CIT- DR
Section 144C(13)Section 147Section 234ASection 263Section 271(1)(c)

…unds of appeal may not be admitted.” 7. We have given thoughtful consideration to the objections raised by the ld. DR. It would be pertinent to refer to the judgment of the Hon'ble High Court of Delhi in the case of Sony Mobile Communications India [P] Ltd 127 Taxmann.com 356 where the facts were identical to the facts of the captioned appeals. The facts considered by the Hon'ble High Court and the findings read as under: “3. The 1TAT, in the impugned order, has recorded the facts of 1TA No. 554/Del/2015 for the Assessment Year 2010-11 before it and has further recorded that the facts of ITA No. 836/Del/2014…

PCIT v. Sony Ericson Mobile Communication India (P) Ltd. (127 Taxmann.com 356) — Cited in 7 Judgments | BharatTax