“associated enterprises”

DCIT Central Circle-1(1), Mumbai vs. S Vinodkumar Diamonds Private Limited, Mumbai

Accordingly, Ground No.1 & 2 raised by the Revenue are treated as allowed for statistical purpose

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

Assessee was selected for regular scrutiny. During the assessment proceedings the Assessing Officer noted that the Assessee had entered into international transaction with Associate Enterprises (AE) and therefore, reference was made to the Transfer Pricing Officer (TPO) for determination of Arms’ Length Price (ALP). The TPO noted that the Assessee ... adjustment of ₹1.51 crores was made on account of delayed realization of export proceeds beyond invoice credit period from its Associated Enterprises. Therefore, show cause notice was issued to the assessee on the issue. The assessee submitted that there is industry practices of not charging interest on delayed payments, outstanding

Netflix Entertainment Services India LLP, Mumbai vs. Deputy Commissioner of Income Tax- Circle 23(1), Mumbai

In the result, appeal of the assessee is partly

limited, personal, non-exclusive right of access. 5. For non-US territories, up to 31 December 2020, Netflix US granted a licence to its associated enterprise, Netflix International B.V. (NIBV), a company incorporated in the Netherlands. Under this licence, NIBV was authorised to use, exhibit, distribute, sub-distribute and premiere ... risk distributor. It was not involved in content creation, technology development, or global decision-making. All significant functions were performed and controlled by the Associated Enterprises, while Netflix India merely facilitated distribution of access to the platform within India. Furthermore, responsibility for last- mile connectivity that is, actual internet access

Michael Page International Recruitment Pvt Ltd, Mumbai vs. DCIT Circle 14(1)(1), Mumbai

upholding the action of the Ld. AO/Ld. TPO to determine the ALP of the Appellant's international transaction of availing of IGS from its Associated Enterprises ('AEs') as NIL instead of Rs.19,42,69,527 as determined by the Appellant. The Ld. AO/Ld.TPO while making TP adjustment on account ... Assessee was selected for scrutiny assessment. During the assessment proceedings, the Assessing Officer noted that Assessee had entered into international transactions with Associated Enterprises (AEs) and therefore, made a reference to the Transfer Pricing Officer (TPO) for computation of Arm's Length Price (ALP) under Section 92CA

Thyssenkrupp Industrial Solutions Ag, Mumbai vs. Deputy Commissioner of Income Tax Transfer Pricing Circle -4(2)(2), Mumbai

In the result, the appeal of the assessee is allowed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarthyssenkrupp Industrial V/S. Deputy Commissioner Of Solutions Ag बनाम Income Tax,Transfer Pricing C/O Mohinder Puri & Co., 1A- Circle – 4(2)(2), Air India D, Vandhna Building, 11 Building, Nariman Point, Tolstoy Marg, New Delhi – Mumbai–400021, Maharashtra 110 001 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aafcp5301B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

have grossly erred in disregarding the reliance placed by the Appellant on the Transfer Pricing Study Reports of its Associated Enterprises, by holding that the Appellant ought to have conducted an independent determination of arm’s length price and transfer pricing study 4. That the Hon’ble CTT(A) erred ... Notice, the assessee complied promptly by filing key documents on 25.01.2019 including Form 3CEB,return, computation, business details, and information on Associated Enterprises as requested and sought time to file further details.Additional details called for along with the full Transfer Pricing Study Report (TPSR) were furnished on 18.02.2019 covering

ACIT (Cir.) - 6(1)(2), Mumbai vs. Bhandar Power Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2013-14 Assistant Commissioner Of Bhandar Power Ltd. Income Tax, 14Th Floor, Essar House, Circle 6(1)(2), 11, K. K. Marg, Mahalaxmi, Vs. Mumbai Mumbai - 400034 (Pan: Aaacb6693B) (Appellant) (Respondent) Present For: Assessee : Shri Vijay Mehta, Fca & Shri Tarang Mehta, Advocate Revenue : Shri Satyaprakash R. Singh, Cit Dr Date Of Hearing : 29.07.2025 Date Of Pronouncement : 13.10.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue Is Against The Order Of Ld. Cit(A), Delhi, Vide Order Dated 25.01.2018 Passed Against The Assessment Order By Ito 6(1)(4), Mumbai, U/S. 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 20.12.2016, For Assessment Year 2013-14. 2. Grounds Taken By The Revenue Are Reproduced As Under: 1. On The Facts & In The Circumstances Of The Case & In Law, The Cit(A) Is Not Justified In Deleting The Disallowance Of Deduction U/S 80Ia Of The Income Tax Act Of Rs. 203,13,43,740/-Without Considering The Fact That The Provisions Of Section 801A(10) Is Clearly Attracted In This Case Hence The Assessee Is Not Eligible For Claiming Deduction U/S 801A Of The Income Tax Act.

Rules). In clause 25 of this Form, assessee reported about entering of transaction towards SDT for sale of power and charges to its Associated Enterprises (AEs) for which the method used for determining ALP was reported as Comparable Uncontrolled Price method (CUP). 8.1. Ld. TPO carried out a transfer pricing

Franklin Templeton Internaitoanl Services (I) P.Ltd, Mumbai vs. DCIT (OSD) 3(1), Mumbai

In the result the appeal filed by the assessee for assessment year 2007-08 and 2008-09 stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Ld.AO and filed requisite details as called for. 4.1 The Ld.AO from the details furnished observed that, the assessee undertook international transactions with its associated enterprises exceeding the threshold limit. A reference was therefore made to the transfer pricing officer under section 92CA(3) of the act to determine