Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT

44 SOT 391Income Tax Appellate Tribunal2011#3032 most cited

What is Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT authority for?

The Comparable Uncontrolled Price (CUP) method is preferred over indirect methods for determining the arm's length price in transfer pricing matters, especially for royalty payments.

39

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2025.

Also referred to as

Serdia Pharmaceuticals India Pvt Ltd · 44 SOT 391 · ITAT · Transfer Pricing · Comparable Uncontrolled Price · CUP method · arm's length price · royalty payment · related party transaction · transactional net margin method

Also reported as

9 Taxmann.com 13

Sections most often in play

Section 143(3)Section 144C(13)Section 144C(5)Section 270ASection 92C(1)Section 10BSection 144BSection 274

Issues it is cited on

section 35abbsection 92asection 92c(1)section 92c(2)section 92(1)section 43(1)transactional net margin methodcup methodsection 92ca(1)arms length pricerelated party transactiondemerger

Judgments citing Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT

DCIT 1(1)(1), Mumbai vs. Alstom India Ltd, Mumbai

In the result, the assessee’s appeals are partly allowed, assessee’s cross objection is dismissed and Revenue’s appeals are dismissed

ITA 1727/MUM/2015[2010-11]Status: DisposedITAT Mumbai31 Aug 2020AY 2010-11

Bench: Shri Shamim Yahya & Shri Amarjit Singh: A.Y : 2010-11

For Appellant: Ms. Fereshte Sethna &For Respondent: Shri Anand Mohan

…nable. It cannot be arbitrary and capricious. The order of TPO is appealable and therefore, it must be objective, contain detailed reasons, conform to regulations and should be seen as just and fair. 6.15 In the case of Serdia Pharmaceuticals (India) Pvt Ltd 44 SOT 391 (Mum), it was held by the Bench that there cannot be a case where no method can be applied to the transaction. Even if all the methods are considered inappropriate, the method which is less inappropriate is to be applied. 6.16 The method of carrying out the exercise of determination of arm's length price of a transaction has been very lucidly bro…

Fulford (India) Ltd., Mumbai vs. ACIT.(OSD)-2(1), Mumbai

In the result, the appeal is partly allowed for statistical purposes

ITA 6154/MUM/2011[2003-04]Status: DisposedITAT Mumbai25 Nov 2019AY 2003-04

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2003-04 Fulford (India) Limited, The Assistant Commissioner Of 8Th Floor, Platina C-59, Vs. Income Tax (Osd)-2(1), Mumbai G-Block, Bandra Kurla Complex, Bandra (E), Mumbai-400098 Pan No. Aaacf1795L Appellant Respondent

For Appellant: Mr. P. J. Pardiwalla, Sr. AdvocateFor Respondent: Mr. Anand Mohan, CIT- DR
Section 133(6)Section 143(3)(ii)Section 250(4)Section 92BSection 92C(2)

…M as OP/OI of the assessee was 12.17% in the pharmaceutical segment, as against the arithmetic mean of 64 comparables which came to 12.30%. However, relying upon the decision of this Tribunal in the case of Serdia Pharmaceuticals India Pvt Ltd vs ACIT [(2011) 44 SOT 391 (Mum) holding that CUP method is the most appropriate method for determining arm's length price in the case of generic APIs and armed with the requisite CUP inputs gathered by him under section 133(6), the Transfer Pricing Officer proceeded to compute the arm's length price under CUP method. As number of comparable uncontrolled prices for small qu…

Dow Chemical Inernational Pvt. Ltd. As Successor of Roham and Haas (India) Pvt. Ltd., Mumbai vs. ITO - 14(1)(1), Mumbai

In the result, appeals of the assessee in A

ITA 6577/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Sept 2019AY 2014-15

Bench: Shri Saktijit Dey, Jm & Shri M.Balaganesh, Am M/S. Rohm & Haas India Vs. The Assistant Commissioner Pvt. Ltd., Of Income Tax-11(1)(1) 1St Floor, Block B, Room No.204, Aayakar 02, Godrej Business District Bhavan, M.K. Road, Priojshanagar, Lbs Marg Mumbai – 400 020 Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent) Sa No.261/Mum/2019 M/S. Dow Chemical Vs. Income Tax Officer – International Pvt. Ltd., As 14(1)(1), Room No. 431, Successor Of Rohm & Haas Aayakar Bhavan, Mk Road, (India) Pvt. Ltd., Mumbai – 400 020 Godrej It Park – P2 1St Floor Block B, 02 Lbs Road, Godrej Business District, Pirojshahnagar Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent)

Section 143(3)Section 92E

…The ld. AR argued that CUP being the more direct method, the same should be preferred over other methods. He also placed reliance on the decision of Co-ordinate Bench of this Tribunal in the case of Serdia Pharmaceuticals India Pvt. Ltd. vs. ACIT reported in 44 SOT 391, Mumbai wherein it was held that Traditional Transaction Method such as CUP, CPM and RPM should be used, if data is available, over Traditional Profit Methods such as PSM and TNMM. The ld. AR also placed reliance on the decision of this Tribunal in the case of Sonata Software Ltd. vs. ACIT in ITA No.3514/Mum/2010 wherein it was held that TNMM and…

Rohm and Haas India P.Ltd, Mumbai vs. Asst CIT 11(1)(1), Mumbai

In the result, appeals of the assessee in A

ITA 2199/MUM/2015[2010-11]Status: DisposedITAT Mumbai25 Sept 2019AY 2010-11

Bench: Shri Saktijit Dey, Jm & Shri M.Balaganesh, Am M/S. Rohm & Haas India Vs. The Assistant Commissioner Pvt. Ltd., Of Income Tax-11(1)(1) 1St Floor, Block B, Room No.204, Aayakar 02, Godrej Business District Bhavan, M.K. Road, Priojshanagar, Lbs Marg Mumbai – 400 020 Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent) Sa No.261/Mum/2019 M/S. Dow Chemical Vs. Income Tax Officer – International Pvt. Ltd., As 14(1)(1), Room No. 431, Successor Of Rohm & Haas Aayakar Bhavan, Mk Road, (India) Pvt. Ltd., Mumbai – 400 020 Godrej It Park – P2 1St Floor Block B, 02 Lbs Road, Godrej Business District, Pirojshahnagar Vikhroli (W) Mumbai – 400 079 Pan/Gir No.Aaacr2855F (Appellant) .. (Respondent)

Section 143(3)Section 92E

…The ld. AR argued that CUP being the more direct method, the same should be preferred over other methods. He also placed reliance on the decision of Co-ordinate Bench of this Tribunal in the case of Serdia Pharmaceuticals India Pvt. Ltd. vs. ACIT reported in 44 SOT 391, Mumbai wherein it was held that Traditional Transaction Method such as CUP, CPM and RPM should be used, if data is available, over Traditional Profit Methods such as PSM and TNMM. The ld. AR also placed reliance on the decision of this Tribunal in the case of Sonata Software Ltd. vs. ACIT in ITA No.3514/Mum/2010 wherein it was held that TNMM and…

Noble Resources & Trading India Pvt. Ltd., New Delhi vs. DCIT, New Delhi

The appeal is allowed with above direction

ITA 1847/DEL/2015[2010-11]Status: DisposedITAT Delhi15 Mar 2019AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Aseem Chawla, AdvFor Respondent: Shri H. K. Chaudhary, CIT DR
Section 143Section 144CSection 92C

…of the CUP method, have an inherent edge over indirect methods, such as TNMM, and, therefore, as long as it is possible to do so, a direct method of ascertaining the arm's length method should be applied. In the case of Serdia Pharmaceuticals Pvt Ltd Vs ACIT (44 SOT 391) = 2011-TII-02-ITAT-MUM- TP, a coordinate bench of the Tribunal has observed that,"….even as the transfer pricing legislation does not provide for an order of preference of methods of determining ALP, such an order of preference being drawn up is an integral, though somewhat subliminal, part of the process of determining the ALP" and that whenever…

Noble Resource & Trading India Pvt. Ltd., New Delhi vs. ACIT, New Delhi

The appeal is allowed with above direction

ITA 1827/DEL/2014[2009-10]Status: DisposedITAT Delhi15 Mar 2019AY 2009-10

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri Aseem Chawla, AdvFor Respondent: Shri H. K. Chaudhary, CIT DR
Section 143Section 144CSection 92C

…of the CUP method, have an inherent edge over indirect methods, such as TNMM, and, therefore, as long as it is possible to do so, a direct method of ascertaining the arm's length method should be applied. In the case of Serdia Pharmaceuticals Pvt Ltd Vs ACIT (44 SOT 391) = 2011-TII-02-ITAT-MUM- TP, a coordinate bench of the Tribunal has observed that,"….even as the transfer pricing legislation does not provide for an order of preference of methods of determining ALP, such an order of preference being drawn up is an integral, though somewhat subliminal, part of the process of determining the ALP" and that whenever…

Gulbrandsen Chemicals Private Limited, Baroda vs. The Dy.CIT., Circle-1(1), Baroda

In the result, the appeal is allowed in the terms indicated above

ITA 2276/AHD/2013[2008-09]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2008-09
Section 143(3)Section 274Section 92Section 92CSection 92C(2)

…omparable were possible in appellant’s case” and went on to add that “further, it is an accepted position that CUP is a superior method to other methods, if available” as “was also held in the case of Serdia Pharmaceuticals India Pvt Ltd by Mumbai ITAT (2011) 44 SOT 391 (Mum)”. Even as the learned CIT(A) held that adjustments were possible, he rejected the same, on the merits, including in respect of volume discount, credit terms, marketing and selling function and consequent costs, credit risk, reimbursement of R&D costs, interest free ECB loans, and all such factors. The TPO also observed that there is a huge d…

Gulbrandsen Chemicals Pvt.Ltd., Baroda vs. The Dy.CIT., Circle-1(1), Baroda

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

ITA 874/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2007-08
Section 143(3)Section 92

…omparable were possible in appellant’s case” and went on to add that “further, it is an accepted position that CUP is a superior method to other methods, if available” as “was also held in the case of Serdia Pharmaceuticals India Pvt Ltd by Mumbai ITAT (2011) 44 SOT 391 (Mum)”. Even as the learned CIT(A) held that adjustments were possible, he rejected the same, on the merits, including in respect of volume discount, credit terms, marketing and selling function and consequent costs, credit risk, reimbursement of R&D costs, interest free ECB loans, and all such factors. The TPO also observed that there is a huge d…

The DCIT, Circle-1(1), Baroda vs. Gulbrandsen Chemicals Pvt.Ltd., Baroda

Appeal of the assessee is allowed, the appeal of the revenue is dismissed

ITA 760/AHD/2012[2007-08]Status: DisposedITAT Ahmedabad12 Feb 2019AY 2007-08
Section 143(3)Section 92

…omparable were possible in appellant’s case” and went on to add that “further, it is an accepted position that CUP is a superior method to other methods, if available” as “was also held in the case of Serdia Pharmaceuticals India Pvt Ltd by Mumbai ITAT (2011) 44 SOT 391 (Mum)”. Even as the learned CIT(A) held that adjustments were possible, he rejected the same, on the merits, including in respect of volume discount, credit terms, marketing and selling function and consequent costs, credit risk, reimbursement of R&D costs, interest free ECB loans, and all such factors. The TPO also observed that there is a huge d…

At&S India Private Limited, Karnataka vs. D.C.I.T., Circle-11(1), Kolkata

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

ITA 69/KOL/2018[2013-14]Status: DisposedITAT Kolkata10 Oct 2018AY 2013-14

Bench: Shri S. S. Godara, Jm & Dr. A.L.Saini, Am At&S India Private Limited Vs. Dcit, Circle 11(1), Kolkata P-7, Chowringhee Square, 12A, Industrial Area, Nanjangud – 571 301 Kolkata – 700 069. Mysore District, Karnataka, India "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaeca 2930 J (अपीलाथ" /Appellant) (""यथ" / Respondent) ..

For Appellant: Shri Anup Sinha & Ms. Rituparna Sinha, ARFor Respondent: Shri P.K. Srihari, CIT, DR
Section 143(3)Section 144C(13)Section 37(1)Section 92C

…T [2010] 39 SOT 93 (Mum.) - Asstt. CIT v. Dufon Laboratories [2010] 39 SOT 59 (Mum.) 11. Reliance in this regard is also placed on the decision of Hon'ble Mumbai Tribunal in the case of Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT reported in [2011] 44 SOT 391/9 taxmann.com 13 wherein the Hon'ble Tribunal while dealing with the priority of applications of methods for the determination of ALP, has held as under: "64... as long as CUP method can be reasonably applied in determining the arm's length price of an international transaction in a particular fact situation, and unless another method is proven to…

At&S India Private Limited vs. D.C.I.T., Circle-11(1), Kolkata

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

ITA 77/KOL/2017[2012-13]Status: DisposedITAT Kolkata11 May 2018AY 2012-13

Bench: Shri A. T. Varkey, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita No.77/Kol/2017 ("नधा"रणवष" / Assessment Year: 2012-13) At & S India (P) Ltd. Vs. D.C.I.T, Circle-11(1), Kolkata

For Appellant: Smt. Rituparna Sinha, ARFor Respondent: Shri G. Mallikarjuna, CIT(DR)
Section 143(3)Section 144CSection 37Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “C”, BENCH KOLKATA BEFORE SHRI A. T. VARKEY, JM &DR. A.L.SAINI, AM आयकरअपीलसं./ITA No.77/Kol/2017 ("नधा"रणवष" / Assessment Year: 2012-13) AT & S India (P) Ltd. Vs. D.C.I.T, Circle-11(1), Kolkata Aayakar Bhawan, P-7, 12A Industrial Area, Nanjangud – 571301, Mysore District, Karnataka, Chowringhee Square, India. Kolkata – 700 069. "थायीलेखासं./जीआइआरसं./PAN/GIR No. :AAECA 2930 J (Appellant) .. (Respondent) Appellant by :Smt. Rituparna Sinha, AR Respondent by :Shri G. Mallikarjuna, CIT(DR) सुनवाईक"तार"ख/ Date of Hearing : 05/04/2018 घोषणाक"तार"ख/Date of Pronouncement : 11/05/2…

Rbs Equities (India) Ltd (Formerly Known As Abn Amro Asia Equities India Ltd), Mumbai vs. ACIT RG 4(1), Mumbai

ITA 3077/MUM/2009[2003-04]Status: DisposedITAT Mumbai14 Dec 2016AY 2003-04
For Appellant: Shri Arvind SondeFor Respondent: Shri Shiddaramappa Kappattanvar –Sr.AR
Section 143(3)Section 254(1)

…y him in the AY.2004-05 was not accordance with the 3077/M/09 provisions of section 92C of the Act.He relied upon cases of C bay system Pvt.Ltd.(152 ITD126),KSB Pump(147ITD482),ABB Lummus Heat Transfer BV(64taxmann. com. 210), Serdia Pharmaceuticals Pvt.Ltd.(44 SOT 391). 6.We have heard the rival submissions and perused the material before us.We find that the assessee is in business of broking and trading of shares,that it had entered in to IT.s.with its AE.s,that the dispute is mainly about the IT.entered in to with the Mauritius AE,that it had selected TNMM as MAM for determining the ALP of its IT.s,that it a…

At & S India Pvt. Ltd., Karnataka vs. DCIT, Cir-11(1), Kolkata

In the result, assessee’s appeal stands allowed

ITA 179/KOL/2016[2011-2012]Status: DisposedITAT Kolkata03 Aug 2016AY 2011-2012

Bench: Shri Waseem Ahmed & Shri S.S.Viswanethra Raviassessment Years:2011-12

Section 143(3)

…T [2010] 39 SOT 93 (Mum.) - Asstt. CIT v. Dufon Laboratories [2010] 39 SOT 59 (Mum.) 11 Reliance in this regard is also placed on the decision of Hon'ble Mumbai Tribunal in the case of Serdia Pharmaceuticals (India) (P.) Ltd. v. Asstt. CIT reported in [2011] 44 SOT 391/9 taxmann.com 13 wherein the Hon'ble Tribunal while dealing with the priority of applications of methods for the determination of ALP, has held as under: "64... as long as CUP method can be reasonably applied in determining the arm's length price of an international transaction in a particular fact situation, and unless another method is proven to…

DCIT, New Delhi vs. M/S. Noble Resource and Trading India Pvt. Ltd, New Delhi

In the result appeal of the assessee is partly allowed

ITA 3155/DEL/2013[2007-08]Status: DisposedITAT Delhi05 May 2016AY 2007-08

Bench: I. C. Sudhir & Shri Prashant Maharishidcit, Noble Resources & Trading India Pvt. Ltd., 1A-D, Circle-13(1), Room No. 406, Vandana Building, Vs. C.R. Building, Ip Estate, 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Acit (Osd), Ltd., 1A-D, Vandana Building, Cit-V, Vs. 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Ito, Ltd., 1A-D, Vandana Building, Ward-13(3), Vs. 11, Tolstoy Marg, New Delhi C.R. Building, Pan:Aaaca0443N New Delhi (Appellant) (Respondent)

For Appellant: Sh. Aseem Chawla, AdvFor Respondent: Sh. H. K. Chaudhary, CIT DR
Section 92

…of the CUP method, have an inherent edge over indirect methods, such as TNMM, and, therefore, as long as it is possible to do so, a direct method of ascertaining the arm‟s length method should be applied. In the case of Serdia Pharmaceuticals Pvt Ltd Vs ACIT (44 SOT 391), a coordinate bench of the Tribunal has observed that,”….even as the transfer pricing legislation does not provide for an order of preference of methods of determining ALP, such an order of preference being drawn up is an integral, though somewhat subliminal, part of the process of determining the ALP” and that whenever a direct method of ascerta…

Noble Resources & Trading India Pvt. Ltd., New Delhi vs. ACIT (OSD), New Delhi

In the result appeal of the assessee is partly allowed

ITA 3132/DEL/2013[2007-08]Status: DisposedITAT Delhi05 May 2016AY 2007-08

Bench: I. C. Sudhir & Shri Prashant Maharishidcit, Noble Resources & Trading India Pvt. Ltd., 1A-D, Circle-13(1), Room No. 406, Vandana Building, Vs. C.R. Building, Ip Estate, 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Acit (Osd), Ltd., 1A-D, Vandana Building, Cit-V, Vs. 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Ito, Ltd., 1A-D, Vandana Building, Ward-13(3), Vs. 11, Tolstoy Marg, New Delhi C.R. Building, Pan:Aaaca0443N New Delhi (Appellant) (Respondent)

For Appellant: Sh. Aseem Chawla, AdvFor Respondent: Sh. H. K. Chaudhary, CIT DR
Section 92

…of the CUP method, have an inherent edge over indirect methods, such as TNMM, and, therefore, as long as it is possible to do so, a direct method of ascertaining the arm‟s length method should be applied. In the case of Serdia Pharmaceuticals Pvt Ltd Vs ACIT (44 SOT 391), a coordinate bench of the Tribunal has observed that,”….even as the transfer pricing legislation does not provide for an order of preference of methods of determining ALP, such an order of preference being drawn up is an integral, though somewhat subliminal, part of the process of determining the ALP” and that whenever a direct method of ascerta…

Noble Resources & Trading India Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result appeal of the assessee is partly allowed

ITA 6470/DEL/2012[2008-09]Status: DisposedITAT Delhi05 May 2016AY 2008-09

Bench: I. C. Sudhir & Shri Prashant Maharishidcit, Noble Resources & Trading India Pvt. Ltd., 1A-D, Circle-13(1), Room No. 406, Vandana Building, Vs. C.R. Building, Ip Estate, 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Acit (Osd), Ltd., 1A-D, Vandana Building, Cit-V, Vs. 11, Tolstoy Marg, New Delhi New Delhi Pan:Aaaca0443N (Appellant) (Respondent) Noble Resources & Trading India Pvt. Ito, Ltd., 1A-D, Vandana Building, Ward-13(3), Vs. 11, Tolstoy Marg, New Delhi C.R. Building, Pan:Aaaca0443N New Delhi (Appellant) (Respondent)

For Appellant: Sh. Aseem Chawla, AdvFor Respondent: Sh. H. K. Chaudhary, CIT DR
Section 92

…of the CUP method, have an inherent edge over indirect methods, such as TNMM, and, therefore, as long as it is possible to do so, a direct method of ascertaining the arm‟s length method should be applied. In the case of Serdia Pharmaceuticals Pvt Ltd Vs ACIT (44 SOT 391), a coordinate bench of the Tribunal has observed that,”….even as the transfer pricing legislation does not provide for an order of preference of methods of determining ALP, such an order of preference being drawn up is an integral, though somewhat subliminal, part of the process of determining the ALP” and that whenever a direct method of ascerta…

Merck Ltd, Mumbai vs. DCIT 7(2)(1), Mumbai

In the result, the appeal of the Assessing Officer for the assessment year

ITA 1222/MUM/2015[2009-10]Status: DisposedITAT Mumbai31 Mar 2016AY 2009-10
Section 133(6)Section 143(3)

…I.T.A. No. 1946/Mum/2014 I.T.A. Nos. 1172 and 1222/Mum/2015 Assessment years: 2009-10, 2010-11 Page 1 of 32 IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI ‘K’ BENCH, MUMBAI [Coram: Pramod Kumar AM and Pawan Singh JM] I.T.A. No. 1946/Mum/2014 Assessment year: 2009-10 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. [PAN: AAACE 2616F] Vs. ……..…………….…Respondent Dy. Commissioner of Income Tax Range 6 (3), Mumbai. I.T.A. No. 1222/Mum/2015 Assessment year: 2010-11 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. […

DCIT Cir 7(2)(1), Mumbai vs. Merck Ltd, Mumbai

In the result, the appeal of the Assessing Officer for the assessment year

ITA 1172/MUM/2015[2010-11]Status: DisposedITAT Mumbai31 Mar 2016AY 2010-11
Section 133(6)Section 143(3)

…I.T.A. No. 1946/Mum/2014 I.T.A. Nos. 1172 and 1222/Mum/2015 Assessment years: 2009-10, 2010-11 Page 1 of 32 IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI ‘K’ BENCH, MUMBAI [Coram: Pramod Kumar AM and Pawan Singh JM] I.T.A. No. 1946/Mum/2014 Assessment year: 2009-10 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. [PAN: AAACE 2616F] Vs. ……..…………….…Respondent Dy. Commissioner of Income Tax Range 6 (3), Mumbai. I.T.A. No. 1222/Mum/2015 Assessment year: 2010-11 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. […

Merck Ltd, Mumbai vs. DCIT RG 6(3), Mumbai

In the result, the appeal of the Assessing Officer for the assessment year

ITA 1946/MUM/2014[2009-10]Status: DisposedITAT Mumbai31 Mar 2016AY 2009-10
Section 133(6)Section 143(3)

…I.T.A. No. 1946/Mum/2014 I.T.A. Nos. 1172 and 1222/Mum/2015 Assessment years: 2009-10, 2010-11 Page 1 of 32 IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI ‘K’ BENCH, MUMBAI [Coram: Pramod Kumar AM and Pawan Singh JM] I.T.A. No. 1946/Mum/2014 Assessment year: 2009-10 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. [PAN: AAACE 2616F] Vs. ……..…………….…Respondent Dy. Commissioner of Income Tax Range 6 (3), Mumbai. I.T.A. No. 1222/Mum/2015 Assessment year: 2010-11 Merck Limited ……….………………….Appellant Shiv Sagar Estate, ‘A’ Dr. Annie Besant Road, Worli, Mumbai 400018. […