How many judgments cite Rampgreen Solutions Pvt. Ltd. v. CIT?

196 judgments on BharatTax cite Rampgreen Solutions Pvt. Ltd. v. CIT (377 ITR 533), spanning 2016 to 2025.

Which sections of the Income Tax Act does Rampgreen Solutions Pvt. Ltd. v. CIT come up under?

It is most often cited in judgments turning on Section 10B(3), Section 133(6), Section 10B(2)(a), Section 234B, Section 10(B)(3), Section 108(1)(e).

Rampgreen Solutions Pvt. Ltd. v. CIT

377 ITR 533High Court2015#477 most cited

What is Rampgreen Solutions Pvt. Ltd. v. CIT authority for?

Knowledge Process Outsourcing (KPO) service providers are functionally dissimilar to Business Process Outsourcing (BPO) or Information Technology Enabled Services (ITeS) providers and cannot be compared for transfer pricing purposes, even under the Transactional Net Margin Method (TNMM). Further, companies with significantly different business models, such as those with extensive subcontracting, should be excluded as comparables.

196

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2016 to 2025.

Also referred to as

Rampgreen Solutions Pvt. Ltd. v. CIT · 377 ITR 533 · Section 92C(2) · Transfer Pricing · comparable companies · KPO BPO functional dissimilarity · Transactional Net Margin Method · TNMM · business model difference · subcontracting · Section 10A · Section 10B

Also reported as

279 CTR 441

Sections most often in play

Section 10B(3)Section 133(6)Section 10B(2)(a)Section 234B Section 10(B)(3)Section 108(1)(e)Section 10A Section 10B(1)(e)

Read the full judgment

Issues it is cited on

captive service provider section 92c(2)resulting company working capital adjustment transactional net margin method far analysis related party transaction demerger comparable companies tested party strategic investment amalgamation

Judgments citing Rampgreen Solutions Pvt. Ltd. v. CIT

ITO, New Delhi vs. M/S. Navisite India Pvt. Ltd., New Delhi

In the result appeal filed by assessee stands allowed

ITA 948/DEL/2016[2011-12]Status: DisposedITAT Delhi17 Dec 2018AY 2011-12

Bench: Sri R.K.Panda & Smt. Beena A Pillaia.Y. 2011-12 M/S Navisite India Pvt.Ltd. Vs. Ito, Ward -17(4) Vipul Plaza, 1St Floor New Delhi Golf Course Road Sector-54, Sun City Gurgaon 122 002 Pan: Aaccn0289R & A.Y. 2011-12 Ito, Ward 17(4) Vs. M/S Navisite India Pvt.Ltd. Room No.225D New Delhi C.R.Building I.P.Estate New Delhi 110 002 (Appellant) (Respondent) Assessee By: Sh.Manoneet Dalal, Adv. Sh. Prag Garg, Adv. Sh.Yishu Goel, Adv. Sh. Jatin Chawla, Adv. Department By: Sri Sarabjeet Singh, Sr.D.R.

For Appellant: Sh.Manoneet Dalal, AdvFor Respondent: Sri Sarabjeet Singh, Sr.D.R

Section 234BSection 274

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: BENCH “I-2” NEW DELHI BEFORE SRI R.K.PANDA, ACCOUNTANT MEMBER AND SMT. BEENA A PILLAI, JUDICIAL MEMBER A.Y. 2011-12 M/s NaviSite India Pvt.Ltd. vs. ITO, Ward -17(4) Vipul Plaza, 1st Floor New Delhi Golf Course Road Sector-54, Sun City Gurgaon 122 002 PAN: AACCN0289R & A.Y. 2011-12 ITO, Ward 17(4) vs. M/s Navisite India Pvt.Ltd. Room No.225D New Delhi C.R.Building I.P.Estate New Delhi 110 002 (Appellant) (Respondent) Assessee by: Sh.Manoneet Dalal, Adv. Sh. Prag Garg, Adv. Sh.Yishu Goel, Adv. Sh. Jatin Chawla, Adv. Department by: Sri Sarabjeet Singh, Sr.D.R.…

Navisite India Pvt. Ltd., Gurgaon vs. ITO, New Delhi

In the result appeal filed by assessee stands allowed

ITA 1054/DEL/2016[2011-12]Status: DisposedITAT Delhi17 Dec 2018AY 2011-12

For Appellant: Sh.Manoneet Dalal, AdvFor Respondent: Sri Sarabjeet Singh, Sr.D.R

Section 234BSection 274

M/S. Vaildor Capital India Pvt. Ltd., New Delhi vs. ITO, New Delhi

ITA 1961/DEL/2015[2010-11]Status: DisposedITAT Delhi22 Nov 2018AY 2010-11

Bench: Shri H.S. Sidhu & Shri Prashant Maharishia.Y.: 2010-11

For Appellant: Sh. S.D. Kapila, Adv. & Sh. R.RFor Respondent: Ms. Saweta Nakra Datta, Sr. DR

Section 143(3)Section 92C

…IN THE INCOME TAX APPELATE TRIBUNAL DELHI BENCH “I.2”: NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER A.Y.: 2010-11 VAILDOR CAPITAL INDIA PVT. LTD. VS. ITO, WARD 26(1), 8599, EAST PARK ROAD, C.R. BUILDING, KAROL BAGH, NEW DELHI NEW DELHI (PAN: AABCH8403J) (Appellant) (Respondent) Assessee by : Sh. S.D. Kapila, Adv. & Sh. R.R. Maurya, Adv. Department by : Ms. Saweta Nakra Datta, Sr. DR. O R D E R PER H.S. SIDHU, JM 01 This appeal is filed by the Assessee against the order of the Assessing Officer passed u/s. 143(3) of the Income Tax Act, 1961 (in short “Act”)…

Cairn India Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, the appeal of the assessee in ITA Nos

ITA 263/DEL/2017[2012-13]Status: DisposedITAT Delhi24 Oct 2018AY 2012-13

Bench: Shri N.K. Billaiya & Ms. Suchitra Kamble[A.Y 2011-12] & [A.Y 2012-13] Cairn India Ltd., Vs. The A.C.I.T, Dlf Atria Building, Circle-1(1), Jacaranda Marg, N Block, Gurgaon. Dlf City Phase Ii, Gurgaon. [Pan: Aaccc 8799D] [Appellant] [Respondent] Date Of Hearing : 17.10.2018 Date Of Pronouncement : 24.10.2018 Assessee By : Shri Ajay Vohra, Sr. Adv Shri Ravi Sharma, Adv

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Srinivasa Rao, Sr. DR

Section 143(3)

…ad arm’s length conditions prevailed is brought to tax. Misreporting, if any, on account of non-arm’s length conditions resulting on lower profits, is corrected.” 22. Decision of the Hon'ble Delhi High Court in the case of Ramgreen Solutions Pvt. Ltd Vs. CIT 377 ITR 533 is the case in point. The relevant observations read as under; “12. At the outset, it is necessary to bear in mind that the object and purpose of introducing provisions relating to transfer pricing adjustment in the Act. By virtue of Finance Act, 2001, Section 92 of the Act was substituted by Sections 92 ITA 102/2015 Page 10 of 42 ensure that th…

Omniglobe Information Technologies (India) Pvt. Ltd., New Delhi vs. Addl. CIT, Special Range -7, New Delhi

In the result, these grounds of appeal are rejected

ITA 6980/DEL/2017[2013-14]Status: DisposedITAT Delhi15 Oct 2018AY 2013-14

Bench: : Shri Bhavnesh Saini & Shri L.P. Sahu

Section 143(3)Section 144CSection 234BSection 234CSection 92C

…In the Income-Tax Appellate Tribunal, Delhi Bench ‘I-2’, New Delhi Before : Shri Bhavnesh Saini, Judicial Member And Shri L.P. Sahu, Accountant Member ITA No. 6980/Del./2017 Assessment Year: 2013-14 Omniglobe Information vs. Addl. CIT, Spcl.Range-7, Technologies (India) Pvt. Ltd., New Delhi. E-11, Rajouri Garden, New Delhi (Respondent) PAN-AAACO 6606M (Appellant) Appellant by Shri Abhishek Agarwal, Advocate Respondent by Shri Sanjay Kumar Yadav, Sr. DR Date of Hearing 19.07.2018 Date of Pronouncement 15.10.2018 ORDER Per L.P. Sahu, A.M.: This is an appeal filed by the assessee against the order of the AO/…

DCIT, New Delhi vs. M/S Microfoft India (R&D) Pvt. Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed and that of the

ITA 691/DEL/2016[2011-12]Status: DisposedITAT Delhi14 Sept 2018AY 2011-12

Bench: Shri R.S. Syal & Shri K. Narasimha Charyassessment Year : 2011-12

For Appellant: Shri Nageshwar RaoFor Respondent: Shri Sanjay I Bara, CIT, DR

Section 143(3)Section 144C

…was also submitted that it was outsourcing substantial amount of its work to outsiders. The DRP did not approve the view canvassed by the TPO. Relying on the judgment of the Hon'ble Delhi High Court in the case of Rampgreen Solutions Pvt. Ltd. vs. CIT (2015) 279 CTR 441 (Del), the DRP directed to exclude this company from the list of comparables. The Revenue is aggrieved by such exclusion. 100. We have heard both the sides and gone through the relevant material on record. The ld. DR contended that this company ought to have been retained in the list of comparables as the assessee was also providing KPO serv…

Giesecke & Devrient India Pvt. Ltd., Gurgaon vs. DCIT, New Delhi

ITA 5924/DEL/2012[2008-09]Status: DisposedITAT Delhi23 Aug 2018AY 2008-09

Bench: Shri Pramod Kumar & Shri Sudhanshu Srivastava

Section 143(3)Section 144C

…the preceding assessment year would not by itself be a ground for its acceptance in the subsequent assessment year. The Ld. Counsel placed reliance on the judgments of the Hon'ble Delhi High Court in Rampgreen Solutions Pvt. Ltd. vs. CIT reported in [2015] 377 ITR 533 (Delhi), Chryscapital Investment Advisors Pvt. Ltd. vs. DCIT reported in [2015] 376 ITR 183 (Delhi) and Avenue Asia Advisors Private Limited vs. DCIT (ITA No. 350/2016) and submitted that the functionality of an entity is the key determinative factor for its inclusion or exclusion in the list of comparables and there is no such thing as estopp…

ACIT, New Delhi vs. M/S Wns Business Consulting Services Pvt. Ltd., Mumbai

In the result, Appeal of the Department is dismissed

ITA 919/DEL/2013[2008-09]Status: DisposedITAT Delhi14 Aug 2018AY 2008-09

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri Tarandeep SinghFor Respondent: Shri Kumar Pranav, Sr. D.R

Section 10ASection 92

…design services, product and software customization and development which are high-end technical services. Learned Counsel for the Assessee also relied upon decision of the Hon’ble Delhi High Court in the case of Rampgreen Solutions (P.) Ltd., vs. CIT (2015) 377 ITR 533 (Del.) in which it was held as under : “Though entities rendering voice call center services for customer support and a KPO service provider employ IT- based delivery systems, but characteristics of services, functional aspects, business environment, risks and quality of human resource employed are materially different; and therefore, benchmarki…

Evalueserve.Com Pvt. Ltd., Gurgaon vs. ACIT, New Delhi

ITA 1466/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Aug 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92C

…owever, ITAT did not entertain such plea for the reason that this was not the case of the TPO and classification is not mandatory in law. The Ld. AR submitted that classification to BPO/KPO is not mandatory. The Hon’ble Delhi High Court in Rampgreen Solutions 377 ITR 533 held that classification is not mandatory. Furthermore, the concept of BPO and KPO is not mentioned in Rule 10B of the Income Tax Rules, 1962 (‘the Rules’). On examination of the Act and the Rules, it is evident that for comparability analysis, information technology enabled services are not bifurcated in strict compass of BPO/KPO. The basic rule…

Evalueserve.Com Pvt. Ltd., New Delhi vs. ITO, New Delhi

ITA 6310/DEL/2012[2008-09]Status: DisposedITAT Delhi03 Aug 2018AY 2008-09

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 143(3)Section 144CSection 92C

Bothra Shipping Services(Currently Known As Bothra Shipping Services (P) Ltd., Kolkata vs. ACIT, Cental Circle-1(1), Kolkata

In the result ground no. 11 & 12 are allowed for statistical purpose

ITA 178/KOL/2017[2010-2011]Status: DisposedITAT Kolkata31 Jul 2018AY 2010-2011

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey) Assessment Year: 2010-11 Assessment Year: 2011-12 Assessment Year: 2012-13 Bothra Shipping Services ......…..…….……………………..…………………………………..……….……..Appellant (Currently Known As Bothra Shipping Services Pvt. Ltd.) Room No. 10 2Nd Floor “Sagar Estate 2 Clive Ghat Street Kolkata – 700 107 [Pan : Aadfb 8479 P] Assistant Commissioner Of Income Tax, Central Circle-1(1), Kolkata.…….......….......Respondent Appearances By: Shri Naresh Jain & Mrs. Arati Debnath, Ar, Appeared On Behalf Of The Assessee. Shri G. Mallikarjuna, Cit, D/R. Appearing On Behalf Of The Revenue. Date Of Concluding The Hearing : June 26Th, 2018 Date Of Pronouncing The Order : July 31St , 2018 Order Per J. Sudhakar Reddy, Am :- All These Appeals Filed By The Assessee Are Directed Against The Separate Orders Passed U/S 144C R.W.S. 143(3) Of The Income Tax Act, 1961 (In Short The ‘Act’). As The Issues Arising In All These Appeals Are Common, For The Sake Of Convenience They Are Heard Together & Disposed Off By Way Of This Common Order. 2. Brief Facts Of This Case Are Brought Out By The Ld. Drp At Page 1 Of His Order Which Is Extracted For Ready Reference:- Bothra India Is Engaged In The Business Of Handling Bulk Cargoes. Its Activities Include Vessel Handling, Stevedoring & Cargo Handling, Clearing & Forwarding & Other Port Related Activities. Jaldhi Overseas Pte Ltd ('Jaldhi Overseas') Engages Bothra India For Vessel Handling At The Port, To Provide Various Vessel Related Services Until The Vessel

Section 143(3)Section 144CSection 153ASection 153BSection 92CSection 92C(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘C’ BENCH, KOLKATA (Before Sri J. Sudhakar Reddy, Accountant Member & Sri Aby T. Varkey, Judicial Member) Assessment Year: 2010-11 Assessment Year: 2011-12 Assessment Year: 2012-13 Bothra Shipping Services ......…..…….……………………..…………………………………..……….……..Appellant (Currently known as Bothra Shipping services Pvt. Ltd.) Room No. 10 2nd Floor “Sagar Estate 2 Clive Ghat Street Kolkata – 700 107 [PAN : AADFB 8479 P] Assistant Commissioner of Income Tax, Central Circle-1(1), Kolkata.…….......….......Respondent Appearances by: Shri Naresh Jain & Mrs. Arati Debnath, AR, appear…

Accenture Services P.Ltd, Mumbai vs. Addl CIT RG 3(1), Mumbai

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande

Section 10ASection 143(3)Section 154Section 92C

…facts in the impugned assessment year, the conclusion of the Transfer Pricing Officer relating to this comparable in assessment year 2009–10 will equally apply to the impugned assessment year. Moreover, in case of Rampgreen Solutions Pvt. Ltd. v/s CIT, [2015] 377 ITR 533, the Hon'ble Delhi High Court has held that E–Clerx Services Ltd. being involved in providing KPO services is not comparable to regular BPO service provider. The Hon'ble Jurisdictional High Court in PCIT v/s PTC Software India Pvt. Ltd., ITA no.598/2016, dated 16th April 2018, have held that E–Clerx 30. Objecting to the selection of this compan…

M/S. Philip Morris Services India S.A., New Delhi vs. ACIT, New Delhi

ITA 1408/DEL/2015[2010-11]Status: DisposedITAT Delhi19 Jul 2018AY 2010-11

Bench: Shri R.S. Syal & Smt. Beena A. Pillaiassessment Year : 2010-11

For Appellant: Shri Neeraj Jain, Advocate &For Respondent: Shri Sanjay I Bara, CIT, DR

Section 143(3)Section 144C(13)

…no requirement to have identical services for the purpose of making comparison under the TNMM. 6 9. We are unable to accept this argument in view of the judgment of the Hon’ble jurisdictional High Court in the case of Rampgreen Sales Pvt. Ltd. vs. CIT (2015) 377 ITR 533 (Del) in which it has been held that the comparables are to be selected on the basis of similarity even under TNMM. The Hon’ble High Court has laid down that selection of comparables does not differ with the method adopted. Ex consequenti, it is no more open to argue that the functional dissimilarity of the companies under the overall broader ca…

M/S. Cengage Learning India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result appeal filed by the assessee stands partly allowed

ITA 6484/DEL/2012[2008-09]Status: DisposedITAT Delhi19 Jul 2018AY 2008-09

Bench: Shri Rs Syal & Smt. Beena A Pillaia.Y. 2008-09

Section 10ASection 133(6)Section 143Section 92C(2)Section 92C(3)Section 92D

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: ‘I-1’, NEW DELHI BEFORE SHRI RS SYAL, VICE PRESIDENT AND SMT. BEENA A PILLAI, JUDICIAL MEMBER A.Y. 2008-09 Cengage Learning India Dy.CIT, Circle 3(1) P Ltd. vs. New Delhi 418, FIE, Patparganj New Delhi 110 092 PAN: AACCT5522B (Appellant) (Respondent) Assessee by Dr.Shashwat Bajpai, Adv. Sh. Sharad Agarwal, Adv. Department by Sh. Sanjay I Bara, CIT,DR Date of Hearing 16/07/2018 Date of Pronouncement 19/07/2018 ORDER PER BEENA A PILLAI, JUDICIAL MEMBER Present appeal has been filed by assessee against the final assessment order dated 29/10/12 passed by Ld. AC…

ACIT, Circle-17(1), Hyderabad vs. Dst Worldwide Services India Pvt. Ltd., Hyderabad

In the result, Revenue’s appeal is dismissed, while cross objections of the assessee are partly allowed

ITA 291/HYD/2015[2010-11]Status: DisposedITAT Hyderabad18 Jul 2018AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiahasstt. Commissioner Of Vs M/S. Dst Worldwide Income Tax, Circle 17(1) Services India Pvt. Ltd Hyderabad Hyderabad Pan: Aaaci7097L (Appellant) (Respondent)

For Appellant: Shri Abhiroop BhagravFor Respondent: Shri J. Siri Kumar, DR

Section 10Section 10ASection 143(3)Section 92C

…ITA No 291 and CO No 24 of 2015 DST Worldwide Services India P Ltd Hyderabad. IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘ A ‘ Bench, Hyderabad Before Smt. P. Madhavi Devi, Judicial Member AND Shri B. Ramakotaiah, Accountant Member Asstt. Commissioner of Vs M/s. DST Worldwide Income Tax, Circle 17(1) Services India Pvt. Ltd Hyderabad Hyderabad PAN: AAACI7097L (Appellant) (Respondent) C.O. No24/Hyd/2015 (Arising out of ITA No.291/Hyd/2015) A.Y 2010-11 M/s. DST Worldwide Vs Asstt. Commissioner of Services India Pvt. Income Tax, Circle 17(1) Ltd, Hyderabad Hyderabad PAN: AAACI7097L (Cross Objector) (R…

Keane Worldzen India (Pvt.) Ltd., Gurgaon vs. ITO, New Delhi

In the result this ground raised by assessee stands allowed for statistical purposes

ITA 5339/DEL/2011[2007-08]Status: DisposedITAT Delhi12 Jul 2018AY 2007-08

Bench: Shri P.M.Jagtap & Smt. Beena A Pillaiay: 2007-08 Ntt Data Global Delivery Vs. Ito, Ward 5(2) Services Ltd. New Delhi (Formerly Known As Keane Worldzen (I) Pvt.Ltd.) Splendor Trade Tower 2Nd, 3Rd, 4Th, 5Th, 6Th & 7Th Floor Golf Course Extension Road Sector 65, Village Tigra Gurgaon Haryana 122 001 Pan: Aaacw3622M (Appellant) (Respondent) Assessee By : Sh. S.D.Kapila, Adv. Department By : Sh. Sanjay Kumar Yadav, Sr.Dr Date Of Hearing : 26.04.2018 Date Of Pronouncement: 12.07.2018

For Appellant: Sh. S.D.Kapila, AdvFor Respondent: Sh. Sanjay Kumar Yadav, Sr.DR

Section 143(2)Section 143(3)Section 144CSection 92C(2)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: ‘I-2’, NEW DELHI BEFORE SHRI P.M.JAGTAP, ACCOUNTANT MEMBER AND SMT. BEENA A PILLAI, JUDICIAL MEMBER AY: 2007-08 NTT DATA Global Delivery vs. ITO, Ward 5(2) Services Ltd. New Delhi (Formerly known as Keane Worldzen (I) Pvt.Ltd.) Splendor Trade Tower 2nd, 3rd, 4th, 5th, 6th & 7th Floor Golf Course Extension Road Sector 65, Village Tigra Gurgaon Haryana 122 001 PAN: AAACW3622M (Appellant) (Respondent) Assessee by : Sh. S.D.Kapila, Adv. Department by : Sh. Sanjay Kumar Yadav, Sr.DR Date of Hearing : 26.04.2018 Date of Pronouncement: 12.07.2018 ORDER PER BEENA A…

M/S. Keihin Panalfa Ltd., Gurgaon vs. ACIT, New Delhi

In the result the appeal of the Department stands partly

ITA 1790/DEL/2014[2009-10]Status: DisposedITAT Delhi19 Jun 2018AY 2009-10

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri R.K. Kapoor, CAFor Respondent: Shri Sanjay I. Bara, CIT DR, Smt. Namita Panday, Sr. DR

Section 40A(2)(b)

…e assessee’s comparables were rejected without providing any cogent reasons. The Ld. authorised representative has also placed reliance on the judgment of the Hon’ble Delhi High Court in the case of Rampgreen Solutions Private Limited versus CIT reported in 377 ITR 533 (DEL) for the proposition that in determining appropriate comparables the importance of product and functional dissimilarity has to be properly considered. The Ld. authorised representative has also assessee will be at arm’s length if the assessee is allowed the benefit of capacity utilisation. The Ld. authorised representative has also made out…

ACIT, New Delhi vs. M/S. Keihin Panalfa Limited, New Delhi

In the result the appeal of the Department stands partly

ITA 1201/DEL/2014[2009-10]Status: DisposedITAT Delhi19 Jun 2018AY 2009-10

Bench: Shri R.K. Panda & Shri Sudhanshu Srivastava

For Appellant: Shri R.K. Kapoor, CAFor Respondent: Shri Sanjay I. Bara, CIT DR, Smt. Namita Panday, Sr. DR

Section 40A(2)(b)

Asst CIT 10(3) (OSD), Mumbai vs. Ferring Pharmaceuticals P.Ltd, Mumbai

In the result , appeal of the Revenue is allowed for statistical purposes

ITA 6072/MUM/2014[2008-09]Status: DisposedITAT Mumbai01 Jun 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपीऱ सं./I.T.A. No.6072/Mum/2014 (नििाारण वर्ा / Assessment Year : 2008-09) The Assistant Commissioner बिाम/ Ferring Pharmaceutical Of Income-Tax 10(3)(Osd) Private Limited Room No. 403, 4 Th Floor, 403/404, V. Aayakar Bhawan, Sigma Technology Street M K Road, Mumbai-400020 Hiranandani Gardens Powai , Mumbai-400076 स्थायी ऱेखा सं./ Pan : Aaacf3120H (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) ..

For Appellant: Shri. Subodh L. RatnaparkhiFor Respondent: Mr. Saurabh Deshpande & Ms

Section 143(3)(ii)Section 92C

…आयकर अपीऱीय अधिकरण “K” न्यायपीठ म ुंबई में। IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH, MUMBAI BEFORE SHRI SAKTIJIT DEY, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER आयकर अपीऱ सं./I.T.A. No.6072/Mum/2014 (नििाारण वर्ा / Assessment Year : 2008-09) The Assistant Commissioner बिाम/ Ferring Pharmaceutical of Income-tax 10(3)(OSD) Private Limited Room No. 403, 4 th Floor, 403/404, v. Aayakar Bhawan, Sigma Technology Street M K Road, Mumbai-400020 Hiranandani Gardens Powai , Mumbai-400076 स्थायी ऱेखा सं./ PAN : AAACF3120H (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. Revenue by : Mr. Saurabh Deshpa…

Assistant Commissioner of Income-Tax vs. Visteon Engg. Center (I) Pvt. Ltd., Pune

Accordingly, the appeal of Revenue is dismissed

ITA 540/PUN/2015[2010-11]Status: DisposedITAT Pune28 May 2018AY 2010-11

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Ketan Ved & Ms. Nupoor ShahFor Respondent: Smt. Nirupama Kotru

Section 143(3)

…ubmitted that the Tribunal in various cases has held that Coral Hub Limited is not a good comparable with a company engaged in ITES. To support his submissions, the ld. AR placed reliance on the following decisions : i. Rampgreen Solutions Pvt. Ltd. Vs. CIT, 377 ITR 533 (Delhi); ii. John Deere India (P.) Ltd. Vs. DCIT, 77 taxmann.com 7 (Pune-Trib.); iii. PTC Software (India) Pvt. Ltd. Vs. DCIT 67 SOT 138 (Pune-Trib.). 4.5 In ground No. 6 of the appeal the assessee has assailed application of export turnover filter in selection of comparable companies. The ld. AR fairly admitted that in the earlier assessment ye…