VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd.

46 SOT 141Income Tax Appellate Tribunal2011#2132 most cited

What is VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd. authority for?

The Arm's Length Price for loans advanced to Associate Enterprises must be determined by the rate of interest prevalent in the country where the loan is received or consumed, taking into account the currency of the loan.

54

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

VVF Ltd. v. DCIT · DCIT v. Tech Mahindra Ltd. · Section 92B · Section 144C · Arm's Length Price · ALP loans to Associate Enterprises · interest rate benchmarking · country of loan consumption · inter-company loans · transfer pricing adjustment

Sections most often in play

Section 143(3)Section 92BSection 144C(5)Section 144C(13)Section 144BSection 153Section 234BSection 234C

Issues it is cited on

section 92b(1)safe harbour rulessection 72asection 92(1)section 32(2)section 92f(v)preliminary expensessafe harboursection 100corporate guaranteesection 92bcup method

Judgments citing VVF Ltd. v. DCIT I (supra) and DCIT Vs. Tech Mahindra Ltd.

Hindalco Industries Ltd, Mumbai vs. Addl CIT RG 6(3), Mumbai

In the result, the appeal of the learned Assessing Officer is partly allowed

ITA 5242/MUM/2013[2007-08]Status: DisposedITAT Mumbai16 Mar 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Addl Cit Range 6(3) M/S Hindalco Industries Ltd 5Th Floor, Room No. 522, 3Rd Floor, Century Bhavan, Dr A.B. Vs. Rd, Worli Aayakar Bhavan,M.K. Road, Mumbai-400 030 Mumbai-20 (Appellant) (Respondent) Dcit, Cir- 6(3) M/S Hindalco Industries Ltd 5Th Floor, Room No. 522, 3Rd Floor, Century Bhavan, Dr A.B. Vs. Aayakar Bhavan,M.K. Road, Rd, Worli Mumbai-400 030 Mumbai-20 (Appellant) (Respondent) Pan No. Aaach1201R

For Appellant: ShriFor Respondent: Dr. Samuel Pitta –SR AR
Section 80Section 801ASection 80I

…Cotton Naturals (I) Pvt. Ltd. (2015) 55 taxmann.com 523 (Delhi HC) ii. CIT V/s. Vaibhav Gems Ltd. (2017) 88 taxmann.com 12 (Rajasthan HC) iii. CIT V/s. Tata Autocamp Systems Ltd. (2015) 56 taxmann.com 206 (Bombay HC) iv. DCIT V/s. Tech Mahindra Ltd. (2011) 46 SOT 141 (Mumbai ITAT URO) ITA No. 5242, 5302/MUM/2013 Hindalco Industries Ltd,; A.Y.2007-08 v. Piramal Glass Ltd. V/s. DCIT (2017) 80 taxmann.com 68 (Mumbai ITAT) vi. Four soft Ltd. V/s. DCIT 142 TTJ 358 (Hyderabad ITAT) vii. Shiva Industries and Holdings Ltd. V/s. ACIT (2012) 26 taxmann.com 96 (Chennai ITAT) iii. VVF Ltd. V/s. DCIT (2010) TII-04 (Mumba…

Bombay Rayon Holding Ltd., Mumbai vs. Addl/Jt/Dy/CIT/Asstt. ITO, National E-Assessment Centre, Delhi

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

ITA 1208/MUM/2021[2016-17]Status: DisposedITAT Mumbai01 Feb 2023AY 2016-17

Bench: Shri B.R. Baskaran (Am) & Shri Rahul Chaudhary (Jm)

Section 143(3)Section 234ASection 234B

…nterest at 10.25% being the lending rate charged by the banks in India (Arms length price). The DRP enhanced the rate of interest to 12%. On appeal, the Tribunal followed its earlier view in WF Ltd. Vs. DCIT (ITA No.673/Mum/06) and DCIT Vs. Tech Mahindra Ltd (46 SOT 141) and held that as the amount was advanced to an AE in Germany, the ALP rate of the interest had to be determined by adopting the EURIBOR rate of interest i.e. rates prevailing in Europe. The Department challenged the said finding of the Tribunal in the High Court on the basis that the EURIBOR does not govern the monetary markets or interest rates…

Jain Irrigation Systems Ltd, Jalgaon vs. Deputy Commissioner of Income-Tax, Circle - 2, Jalgaon

Appeal is partly allowed in above terms

ITA 227/PUN/2018[2013-14]Status: DisposedITAT Pune22 Dec 2022AY 2013-14

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].

Section 143(3)Section 92D

…nsactions in the same foreign currency should be used to find out the Internal / External CUP in this regard. The CUP Method for benchmarking of interest has been approved by various Benches of ITAT, including ITAT Mumbai in the case of DCIT vs. Tech Mahindra 46 SOT 141(Mum.) and M/s. Aithent Technologies Pvt. Ltd.vs. ITO[TS-721-ITAT-2011(Del)], CUP method has also been impliedly upheld by the Hon’ble Delhi ITA No.227/PUN/2018 for A.Y. 2013-14(A) Jain Irrigation Systems Ltd., High Court in CIT vs Cotton Naturals (I) Pvt Ltd [TS-117-HC- 2015(Del)]. Thus the CUP method is the most appropriate method to ascertain…

Sasken Technologies Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 404/BANG/2017[2012-13]Status: DisposedITAT Bangalore30 Nov 2022AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 404/Bang/2017 Assessment Year : 2012-13 M/S. Sasken Technologies Ltd., (Formerly Known As The Deputy Sasken Communication Commissioner Of Technologies Ltd.), Income Tax, No. 139/25, Domlur Circle – 6(1)(1), Ring Road, Vs. Bangalore. Bangalore – 560 071. Pan: Aaecs6424R Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca : Shri K. Sankar Ganesh, Jcit Revenue By Dr Itat Date Of Hearing : 15-11-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Assessment Order Dated 31.01.2017 Passed By Ld.Dcit, Circle – 6(1)(1), Bangalore For A.Y. 2012-13 On Following Concise Grounds Of Appeal: “1. General:- The Learned Ao & The Drp Erred In Passing The Order / Directions In The Manner Passed By Them. The Orders Passed Being Bad In Law Is Liable To Be Quashed.

For Respondent: Shri Padam Chand Khincha
Section 133(6)Section 2(24)Section 92BSection 92C

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Highways Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle- 3(1)(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 495/BANG/2020[2016-17]Status: DisposedITAT Bangalore25 May 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Highways Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle 3(1)(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1643/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bengaluru vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1744/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bangalore vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1743/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Assistant Commissioner of Income Tax, Central Circle-2(2), Bengaluru vs. M/S. Gmr Infrastructure Limited, Bengaluru

In the result, Ground no. 1 raised for A

ITA 1742/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Assistant Commissioner of Income Tax Central Circle-2(2), Bangalore vs. M/S Gmr Infrastructure Ltd, Bangalore

In the result, Ground no. 1 raised for A

ITA 1741/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1705/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1622/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Infrastructure Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1600/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Gmr Infrastructure Limited, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, Ground no. 1 raised for A

ITA 1599/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

…llows: “7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Oriental Aromatics Ltd, Mumbi, Mumbai vs. DCIT CC 1(2)(2), Mumbai

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

ITA 6331/MUM/2019[2014-15]Status: DisposedITAT Mumbai10 Mar 2022AY 2014-15
Section 143(3)Section 4Section 92(1)

…ollows: 7. We find that the impugned order of the Tribunal inter alia has followed the decisions of the Bombay Bench of the Tribunal in cases of VVF Ltd. v. Dy. CIT [IT Appeal No. 673 (Mum.) of 2006] and Dy. CIT v. Tech Mahindra Ltd. [2011] 12 taxmann.com 132/46 SOT 141 (Mum.) (URO) to reach the conclusion that ALP in the case of loans advanced to Associate Enterprises would be determined on the basis of rate of interest being charged in the country where the loan is received/consumed. Mr. Suresh Kumar the learned counsel for the revenue informed us that the Revenue has not preferred any appeal against the decisi…

Virgo Valves & Controls Ltd, Mumbai vs. DCIT 1(3), Mumbai

ITA 5617/MUM/2016[2009-10]Status: DisposedITAT Mumbai08 Mar 2022AY 2009-10
Section 143(3)Section 92C

…ITA No 3577/Mum/2014 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 Page 1 of 13 IN THE INCOME TAX APPELLATE TRIBUNAL "J" BENCH, MUMBAI [Coram: Pramod Kumar, (Vice President) And Amarjit Singh, Judicial Member] ITA No. 361/Mum/2015 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 M/s. Virgo Valves & Controls Ltd. ………….……… Appellant (now Virgo Valves & Controls Pvt Ltd.) 7B, 3rd Floor, Sambhava Chambers, Sir P.M.Road, Fort, Mumbai 400001 [PAN: AABCV8733H] Vs Deputy Commissioner of Income Tax 1(3) Mumbai …………………… Respondent Appearances: Aditya Ajgaonkar for the Appellant V…

Virgo Valves & Controls Ltd. (Now Virgo Valves & Controls Pvt. Ltd.), Mumbai vs. DCIT - 1(3), Mumbai

ITA 5337/MUM/2016[2008-09]Status: DisposedITAT Mumbai08 Mar 2022AY 2008-09
Section 143(3)Section 92C

…ITA No 3577/Mum/2014 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 Page 1 of 13 IN THE INCOME TAX APPELLATE TRIBUNAL "J" BENCH, MUMBAI [Coram: Pramod Kumar, (Vice President) And Amarjit Singh, Judicial Member] ITA No. 361/Mum/2015 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 M/s. Virgo Valves & Controls Ltd. ………….……… Appellant (now Virgo Valves & Controls Pvt Ltd.) 7B, 3rd Floor, Sambhava Chambers, Sir P.M.Road, Fort, Mumbai 400001 [PAN: AABCV8733H] Vs Deputy Commissioner of Income Tax 1(3) Mumbai …………………… Respondent Appearances: Aditya Ajgaonkar for the Appellant V…

Virgo Valves & Controls Ltd, Mumbai vs. DCIT 1(3), Mumbai

ITA 361/MUM/2015[2010-11]Status: DisposedITAT Mumbai08 Mar 2022AY 2010-11
Section 143(3)Section 92C

…ITA No 3577/Mum/2014 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 Page 1 of 13 IN THE INCOME TAX APPELLATE TRIBUNAL "J" BENCH, MUMBAI [Coram: Pramod Kumar, (Vice President) And Amarjit Singh, Judicial Member] ITA No. 361/Mum/2015 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 M/s. Virgo Valves & Controls Ltd. ………….……… Appellant (now Virgo Valves & Controls Pvt Ltd.) 7B, 3rd Floor, Sambhava Chambers, Sir P.M.Road, Fort, Mumbai 400001 [PAN: AABCV8733H] Vs Deputy Commissioner of Income Tax 1(3) Mumbai …………………… Respondent Appearances: Aditya Ajgaonkar for the Appellant V…

Virgo Valves & Controls Ltd, Mumbai vs. DCIT 1(3), Mumbai

ITA 3577/MUM/2014[2008-09]Status: DisposedITAT Mumbai08 Mar 2022AY 2008-09
Section 143(3)Section 92C

…ITA No 3577/Mum/2014 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 Page 1 of 13 IN THE INCOME TAX APPELLATE TRIBUNAL "J" BENCH, MUMBAI [Coram: Pramod Kumar, (Vice President) And Amarjit Singh, Judicial Member] ITA No. 361/Mum/2015 ITA Nos. 5617 & 5337/Mum/2016 Assessment Years: 2008-09 to 2010-11 M/s. Virgo Valves & Controls Ltd. ………….……… Appellant (now Virgo Valves & Controls Pvt Ltd.) 7B, 3rd Floor, Sambhava Chambers, Sir P.M.Road, Fort, Mumbai 400001 [PAN: AABCV8733H] Vs Deputy Commissioner of Income Tax 1(3) Mumbai …………………… Respondent Appearances: Aditya Ajgaonkar for the Appellant V…

DCIT, New Delhi vs. M/S Omaxe Ltd., New Delhi

Appeal are dismissed

ITA 79/DEL/2016[2010-11]Status: DisposedITAT Delhi13 Oct 2021AY 2010-11

Bench: Ms Suchitra Kamble & Dr. B. R. R. Kumar & (Through Video Conferencing)

Section 143Section 250Section 253(2)Section 80I

…ssue I rely on various judicial pronouncements reported as under: " Siva Industries and Holdings Ltd. vs ACIT [ITA No. 2148/Mds/2148] " Tata Autocomp Systems Ltd vs ACIT [ITA No. 7354/Mum/2011] " Four Soft Ltd. vs DICT 142 TTJ 338 " DCIT vs Tech Mahindra Ltd [46 SOT 141 Mum] " Tricorn India Ltd. vs ITO [ITA No. 332/Mu m/2014] " Aurino Solutions Ltd [ita no. 7872/Mum/2011] " Hinduja Global Solutions Ltd vs ACIT [ITA No. 254/Mum/2013] " Cotton Natural India Private Limited [TS -304-lTAT-201(DEL)-TP] The decision in the case of cotton natural India private Limited has been affirmed by Hon’ble High Court of Delhi rep…