“draft assessment order”

Ingredion India P.Ltd, Navi Mumbai vs. ITO 15(2)(1), Mumbai

In the result appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm The Income Tax Officer Ingredion India Pvt. Ltd 15(20)(1) 1605 Rupa Solitaire, Millennium Business Park, 2Nd Floor, Aaykar Bhavan, Vs. Thane, Belapur Rd, Mahape, M.K.Road, Navi Mumbai- 400 710 Mumbai- 400 020 (Appellant) (Respondent) Pan No. Aaecc1920C Assessee By : Shri. Ketan Ved. Revenue By : Ms. Samruddhi D Hande, Sr Ar Date Of Hearing: 27.07.2022. Date Of Pronouncement: 20.10.2022. O R D E R

pricing range, 2(3)(2) Mumbai (the 2156/MUM/2017 M/s Ingredion India Pvt Ltd; A.Y. 2012-13 learned TPO) was made. Consequent, to that draft assessment order was passed on 14/03/2016. 06. Assessee filed objection before the learned Dispute Resolution Panel who passed its direction on 28/12/2016 confirming the action

Omni Active Health Technologies Ltd., Mumbai vs. Addl/Jt./Dy/CIT/Asstt/ITO, National E-Assessmetnt Centre, Delhi

In the result, appeal of assessee is partly allowed

Bench: Shri Baskaran Br & Sh. Anikesh Banerjee

144C(5) of the Income Tax Act, 1961 [In short “Act”] for the A.Y. 2016-17. The impugned order was raised from the draft assessment order passed by the Learned Income Tax Officer-7(3)(1), Mumbai [in short “A.O.”], vide order dated 31.12.2019 passed under section

Frost & Sullivan (I) P. Ltd, Mumbai vs. DCIT 8(1), Mumbai

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Dy. Commissioner Of Income Frost & Sullivan (I) P. Ltd. Tax, Tower Vi, Iv Floor, Solitaire Central Circle 8(1), Corporate Park, Chakala, Vs. Andheri (E) Aaykar Bhavan Mumbai-400 093 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaacf4252A Assessee By : Shri Madhur Agrawal, Ar Revenue By : Shri Sumit Kumar, Sr. Ar Date Of Hearing: 20.07.2022 Date Of Pronouncement : 17/10/2022

passing an order under Section 92CA(3) of the Act on 20th October, 2009. Pursuant to that draft assessment order was passed by the learned Assessing Officer on 30th November, 2009, wherein over and above transfer pricing adjustment , made certain other additions (which are not part of the appeal before

Merck Specialities Pvt. Ltd, Mumbai vs. The Dy. Commissioner of Income Tax, Circle-7(2)(1), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

addition of Rs. 1,52,47,997 in respect of international transaction pertaining to ‘payment of technical consultancy fees’. The AO passed the draft assessment order under section 143 (3) r/w section 144C(1) of the Act and, inter-alia, incorporated the adjustment proposed by the TPO. 6. The assessee ... No.2056/Mum./2016 intangibles has been disallowed in earlier assessment years i.e. assessment year 2007–08 to 2010–11. The AO vide draft assessment order by referring to the findings rendered in previous assessment years held that since actually there were no assets transferred, for which consideration was paid

Ntt Asia Pacific Holdings Pte. Ltd.(Formerly Known As Dimension Data Asia Pacific Pte. Ltd., Mumbai vs. ACIT (It)2(1)(2), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Prashant Maharishi, Accountnat Member & Shri Sandeep Singh Karhail

regional sales personnel and operations, monitoring sales transactions to preserve pricing structures of the group entities, etc. The Assessing Officer (‘AO’) vide draft assessment order dated 27/02/2021, treated the entire amount of management fees received by the assessee as fee for technical services under the provisions of the DTAA

Infiniti Wholesale Ltd ( Formerly Knwon As Woolwonths Wholesale (India) P.Ltd), Mumbai vs. Asst CIT Cir 8(3), Mumbai

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

supported by Bills/documents] Total 9,65,96,086/- 5. In addition to the above transfer pricing adjustments which were incorporated in the Draft Assessment Order, dated 18.11.2011, the Assessing Officer also proposed addition of INR 80,07,197/- on account of software expenses and addition ... account of difference in the information contained in Annual Information Return pertaining to contract receipt from Bajaj Electrical Ltd in the Draft Assessment Order. The Appellant filed objections to the aforesaid additions proposed in the Draft Assessment Order, dated 18.11.2011, before Dispute Resolution Panel-II, Mumbai (hereinafter referred

M/S Iqvia Ag (Previously Known As Ims Ag, Switzerland vs. The DCIT (Intl Tax) 2(2) 2, Mumbai

In the result, appeal filed by the assessee is allowed for statistical purpose

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Iqvia Ag Dcit (It) – 2(2)(2) V. (Previously Known As Ims Ag) 16Th Floor, Air India Building C/O. Iqvia Consulting & Nariman Point Information Services India Pvt. Ltd., Mumbai – 400 021 Unit No. 902, 9Th Floor Supreme Business Park Hiranandani Gardens, Powai Mumbai - 400076 Pan: Aacci5872K Appellant Respondent Assessee By : Shri Madhur Agarwal Revenue By : Ms. Bharati Singh

beneficial provisions of the Tax Treaty as compared to the provisions of the Act, wherever applicable. The Assessing Officer passed a draft Assessment Order with the observation that ITAT has granted relief to the assessee for A.Y. 2013-14 to A.Y. 2015-16 and department has preferred 5 IQVIA

B Braun Medical (India ) Pvt. Ltd, Mumbai vs. DCIT -1(2) (1), Mumbai

determination of ALP for the international transaction entered into by the assessee and the TPO had proposed no variation in income thereafter draft assessment order dated 25-03-2021 was passed under section 144C(2) of the Income-Tax Act. The assessee filed its objection to the proposed additions/disallowance with ... 144C(13) r.w.s. 144B of the Income-Tax Act. The Ground No. 1 as per revised ground 4. The assessee has challenged the draft assessment order on the ground that the assessee is not an ‘eligible assessee’ as per 3 B Braun Medical (India) Pvt. Ltd. section 144C

Csav Group (India) Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

adjustment of Rs. 2,76,42,429, in respect of international transaction of „IT enabled back office support services‟. The AO passed the draft assessment order under section 143(3)/144C of the Act, inter-alia, after incorporating the adjustment proposed by the TPO. 14. The assessee filed detailed objections

Asst CIT Cir 2(2)(1), Mumbai vs. Mahindra & Mahindra Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

Bench: Shri M. Balaganesh () & Smt. Kavitha Rajagopal () Mahindra & Mahindra Limited Vs Asst.Commissioner Of Income-Tax, Corporation Taxation, P.K. Kurne Circle-2(2)(1), Mumbai Chowk, Worli, Mumbai-400 018 Aayakar Bhavan, M.K. Road Pan : Aaacm3025E Mumbai-400 020 Appellant Respondent Asst.Commissioner Of Income-Tax, Vs 020Mahindra & Mahindra Limited Circle-2(2)(1), Mumbai Corporation Taxation, P.K. Kurne Aayakar Bhavan, M.K. Road Chowk, Worli, Mumbai-400 018 Mumbai-400 Pan : Aaacm3025E Appellant Respondent

income on 29/03/2012 declaring total income of Rs. 18,99,47,48,506/-. The assessee’s case was selected for scrutiny and draft assessment order under section 143(3) r.w.s.144C (1) of the income tax Act 1961 dated 31/03/2014 was proposed to assess the income