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“associated enterprises”

Transfer PricingSection 92ASection 92A2,081 judgments

The decision most relied on for associated enterprises is CIT v. EKL Appliances Ltd. (345 ITR 241), cited in 422 judgments on BharatTax.

Leading authorities on associated enterprises

CIT v. EKL Appliances Ltd.
345 ITR 241 · 2012 · High Court
422
citing judgments

Transfer pricing adjustments for outstanding receivables are permissible only if the Tax Officer establishes, through analysis over a period, a pattern indicating an international transaction intended to benefit an associated enterprise. The Tax Officer cannot question purely business decisions like royalty payments or exceed jurisdiction by applying cost-benefit analysis to determine the arm's length price of services.

Sassoon J. David & Co. Pvt. Ltd. v. CIT
118 ITR 261 · 1979 · Supreme Court
323
citing judgments

An expense incurred by an assessee for its own business, such as advertising, marketing, and promotional (AMP) expenses, cannot be disallowed merely because it incidentally or indirectly benefits the assessee's sister concerns or associated enterprises.

CIT v. Everest Kento Cylinders Ltd.
378 ITR 57 · 2015 · High Court
304
citing judgments

Corporate guarantee fees are subject to transfer pricing rules, and adjustments may be needed to account for differences between corporate guarantees and more liquid bank guarantees when determining arm's length price.

CIT v. Cotton Naturals (I) (P.) Ltd.
55 Taxmann.com 523 · 2015 · High Court
273
citing judgments

The interest rate for benchmarking foreign currency loans advanced to Associated Enterprises should be the market-determined rate applicable to the currency of the loan, such as LIBOR for US Dollar loans, rather than a domestic lending rate like the Indian PLR.

CIT v. Agnity India Technologies (P.) Ltd.
36 Taxmann.com 289 · 2013 · High Court
171
citing judgments

The Delhi High Court holds that Infosys Ltd. is not comparable to a captive software development service provider for transfer pricing analysis, given its huge turnover, high profit margins, ownership of intangible intellectual property rights, branded products, and differing risk profile.

DIT v. Morgan Stanley Co. Inc.
399 ITR 34 · 2017 · Supreme Court
162
citing judgments

Once a transfer pricing analysis has been undertaken for an Indian associated enterprise, no further profits are attributable to it as a Permanent Establishment, thereby extinguishing the need for additional profit attribution.

PCIT v. Redington (India) Ltd.
430 ITR 298 · 2021 · High Court
132
citing judgments

A corporate guarantee issued to Associated Enterprises (AEs) is an international transaction under Section 92B, requiring adjustments for guarantee commission due to inherent risk. The reasonable arm's length rate for benchmarking such corporate guarantees can be determined using internal or external comparable uncontrolled prices.

Sony India (P) Ltd. v. DCIT
114 ITD 448 · 2008 · ITAT
131
citing judgments

For transfer pricing purposes, functionally dissimilar entities that have significant business differences must be excluded from the list of comparables for benchmarking analysis. It also provides guidance on the non-allocation of advertisement, marketing, and promotion (AMP) expenses to other entities when incurred solely for the assessee's business.

Judgments citing associated enterprises

Schott Glass India Pvt. Ltd., Mumbai vs. D.C.I.T. Circle 8(3), Mumbai

In the result, ITA 7356/Mum/2014 of the appeals of the assessee are allowed for statistical purpose and ITA No

ITA 2594/MUM/2012[2007-08]Status: DisposedITAT Mumbai24 Jan 2024AY 2007-08

Bench: Shri Narender Kumar Choudhry & Shri Amarjit Singhschott Glass India Private Vs. Income Tax Officer 8(3)-1 Limited, Dynasty “A” Wing Room No. 201, Aayakar 303/304, 3Rd Floor, Bhavan, M.K. Road, Andheri Kurla Road, Mumbai – 400020 Andheri (E) Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Schott Glass India Private Vs. Deputy Commissioner Of Limited, Dynasty “A” Wing Income Tax 8(3) 303/304, 3Rd Floor, Room No. 204, Aayakar Andheri Kurla Road, Bhavan, M.K. Road, Andheri (E) Mumbai – 400020 Mumbai – 400 059 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aadcs8583L Appellant .. Respondent Appellant By : Ketan Ved Respondent By : Mahesh Jiwade Date Of Hearing 12.12.2023 Date Of Pronouncement 24.01.2024 आदेश / O R D E R Per Amarjit Singh (Am): Both These Appeals Filed By The Assessee Are Directed Agasint The Different Orders Of Ld. Cit(A)-15, Mumbai. Since Both These Appeals

For Appellant: Ketan VedFor Respondent: Mahesh Jiwade
Section 143(2)Section 144C(1)Section 92C

divisions namely turbing and trading division. 3. During the course of assessment the AO noticed that assessee had entered into international transactions with the associated enterprises exceeding Rs. 15 crores. Therefore, after taking into consideration the transaction reported in the form no. 3CEB, the AO has made reference u/s 92CA ... length price by Rs.8,59,31,291/- in relation to the international transactions entered into by the assessee company with its associate enterprises during the financial year 2006-07. 4. In pursuance of the order passed by the TPO u/s 92CA(3) the assessing officer prepared a draft order

Toyota Kirloskar Motor Private Limited, Bangalore vs. DCIT, Circle-7(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 863/BANG/2023[2018-19]Status: DisposedITAT Bangalore22 Jan 2024AY 2018-19

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri Narendra Kumar Jain, A.RFor Respondent: Shri Senthil Kumar N., D.R
Section 40A(2)

length price or arm's length margin based on separate transaction approach is not possible.  The transactions between the assessee and its associated enterprises comprised both purchases, sale of parts and components and services. These transactions are linked and interdependent.  The various activities are intertwined and inter-related. The royalty

M/S Limagrain India Pvt. Ltd., Secunderabad, Hydrabad vs. N.F.A.C, Delhi

ITA 65/IND/2022[2017-18]Status: DisposedITAT Indore19 Jan 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2017-18 M/S.Limagrain India National Faceless Private Limited, Assessment Centre, H.No. 1-8-201 To 203, Delhi Ashoka My Home बनाम/ Chambers, Flat No. 208, 209, 2Nd Vs. Floor, S.P.Road, Secunderabad, Hyderabad (Assessee / Appellant) (Revenue / Respondent) Pan: Aaccb6862A Assessee By Shri Pankaj Sancheti, Ca Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 21.12.2023 Date Of Pronouncement 19.01.2024

Section 139(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 92C

while were complied with by assessee. During assessment-proceeding, the AO found that the assessee had entered into international transactions with its Associated Enterprises [“AEs”] situated outside India. The AO made a reference to Transfer Pricing Officer [“TPO”] on 27.09.2019 to determine Arm’s Length Price [“ALP”] of those transactions

Strides Shasun Ltd, Navi Mumbai vs. DCIT Cir 15(3)(2), Mumbai

In the result, appeal of assessee is partly allowed

ITA 932/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Jan 2024AY 2012-13

Bench: Shri Vikas Awasthy& Shri Amarjit Singhआअसं.932 /मुं/2017 (िन.व. 2012-13) Strides Pharma Science Limited [Formerly Known As Strides Arcolab Limited/ Strides Shasun Limited] 201, Devavrata, Sector -17, Vashi, Navi Mumbai – 400 703 Pan: Aadcs-8104-P ...... अपीलाथ"/Appellant बनाम Vs. The Deputy Commissioner Of Income Tax Circle – 15(3)(2), Mumbai Room No.451, 4Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Nitesh Joshi, Advocate With Shri Ninand Patade "ितवादी "ारा/Respondent By : Shri Anoop Hiwase सुनवाई क" ितिथ/ Date Of Hearing : 26/10/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 15 /01/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Final Assessment Order Dated 23/01/2017 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2012-13. 2. The Assessee In Appeal Has Raised As Many As 12 Grounds. Shri Nitesh Joshi, Advocate Appearing On Behalf Of The Assessee Submitted At The Outset

For Appellant: Shri Nitesh Joshi, Advocate with Shri Ninand PatadeFor Respondent: Shri Anoop Hiwase
Section 143(3)

Rs.22,91,372/-: 3 5. The ld.Counsel for the assessee submitted that the assessee is not charging interest on delayed realization either from the Associated Enterprises (AEs) or Non-AEs. He pointed that in case of some of the AEs, average realization period is 311 days, on which no interest ... that of Vodafone IV, as canvassed by the Revenue, is that Form 3CEB in respect of the transaction of issue of shares to its associated enterprises, is not disclosed as an international transaction. This the petitioner was obliged to do as the transaction is an international transaction. ' This

The ACIT, Circle-1(1)(1), Vadodara vs. Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 150/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

The ACIT, Circle-1(1)(1), Vadodara vs. Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 149/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

The ACIT, Circle-1(1)(1), Vadodara vs. Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 148/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

The ACIT, Circle-1(1)(1), Vadodara vs. Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 147/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara vs. The Assistant Commissioner of Income Tax, Circle-1(1)(2) Now Circle-1(1)(1), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 137/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara vs. The Assistant Commissioner of Income Tax, Circle-1(1)(2) Now Circle-1(1)(1), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 136/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara vs. The Assistant Commissioner of Income Tax, Circle-1(1)(2) Now Circle-1(1)(1), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 135/AHD/2023[2012-13]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara vs. The Assistant Commissioner of Income Tax, Circle-1(1)(2) Now Circle-1(1)(1), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 134/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

Schaeffler India Limited (Earlier Known As Fag Bearings India Ltd.), Vadodara vs. The Assistant Commissioner of Income Tax, Circle-1(2) Now Circle-1(1)(1), Vadodara

Appeals are partly allowed for statistical purposes and Department’s appeals are dismissed

ITA 133/AHD/2023[2010-11]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2010-11

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R. & Shri
Section 234Section 234ASection 271(1)(c)Section 37Section 90(2)

brief facts in relation to this ground of appeal are that the assessee paid Royalty to Schaeffler KG, Germany and Schaeffler Korea Corporation, Associated Enterprises of the assessee company @ 2.80% of net sales in respect of know-how, technical support and technological assistance provided by the AEs. The assessee company ... making the aforesaid payments. Accordingly, the TPO concluded that the Arm’s Length Price of the services provided to the assessee by both the Associated Enterprises towards management fee, is to be taken at “NIL” and accordingly, recommended adjustment of the entire amount

The Dy.CIT, Circle-1(1)(1), Vadodara vs. Ina Bearing India Pvt. Ltd., Pune

In the result, Ground Nos

ITA 540/AHD/2022[2014-15]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2014-15

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R

erred in ignoring the fact that the assessee had failed to benchmark the transactions properly with its Associate Enterprise (AE) as per the law thereby failing to discharge the primary onus cast upon it by the Act? [iii] On the facts and in the circumstances of the case ... that the assessee has not substantiated the benefit derived from such services availed by it for which very high prices were paid to its Associated Enterprise (AE) [v] On the facts and in the circumstances of the case and in law, the Ld, CIT (A) has erred in deleting

The Dy.CIT, Circle-1(1)(1), Vadodara vs. Ina Bearing India Pvt. Ltd., Pune

In the result, Ground Nos

ITA 539/AHD/2022[2013-14]Status: DisposedITAT Ahmedabad12 Jan 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Bhavin Marfatia, A.RFor Respondent: Dr. Darsi Suman Ratnam, CIT D.R

erred in ignoring the fact that the assessee had failed to benchmark the transactions properly with its Associate Enterprise (AE) as per the law thereby failing to discharge the primary onus cast upon it by the Act? [iii] On the facts and in the circumstances of the case ... that the assessee has not substantiated the benefit derived from such services availed by it for which very high prices were paid to its Associated Enterprise (AE) [v] On the facts and in the circumstances of the case and in law, the Ld, CIT (A) has erred in deleting

The Tata Power Co. Ltd, Mumbai vs. Addl CIT RG 2(3), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 753/MUM/2013[2008-09]Status: DisposedITAT Mumbai12 Jan 2024AY 2008-09

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.753/मुं/2013 (िन.व. 2008-09) The Tata Power Co. Ltd. Corporate Center, Block ‘B’, 5Th Floor, 34, Sant Thukaram Road, Carnak Bunder, Mumbai 400 009. Pan: Aaact-0054-A ...... अपीलाथ"/Appellant बनाम Vs. Additional Commissioner Of Income Tax, Range 2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent

For Appellant: Shri Nitesh Joshi with Shri Ninad PatadeFor Respondent: Shri Manoj Kumar&
Section 143(3)Section 14ASection 14A(2)

electricity. During the period relevant to assessment year under appeal, the 2 assessee had entered into international transaction of provision of loan to its Associated Enterprise(AE), Tata Power Mauritius and provision of corporate guarantee to its other A.E. In assessment proceedings the Assessing Officer referred international transactions ... Guarantee fee by observing as under: “030. Now the issue is what is the arm‟s-length price of the corporate guarantee commission to associated enterprises. The coordinate bench on identical facts and circumstances in case of Everest Kanto cylinders [Everest Kento Cylinder Ltd. [IT Appeal

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

ITA 1345/MUM/2017[2012-13]Status: DisposedITAT Mumbai10 Jan 2024AY 2012-13

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited 8Th Floor, Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Addl. Cit - 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited Central Avenue Road Hiranandani Business Park Opp. D-Mart, Powai Mumbai- 400076 Pan: Aaaст3151E (Appellant) V. Dy. Cit (Osd) – 8(1) Aayakar Bhavan, M.K. Road Mumbai- 400020 (Respondent)

Section 133(6)Section 144C(5)

Ratings and (ii) Research. Under the Ratings segment, the Assessee is engaged in rendering back-end support for data analysis services to its associated enterprises through the Global Analytical Centre (GAC) which is the transaction under dispute. The Assessee had undertaken, inter-alia, international transactions of provision of back ... support for data analysis services from the GAC to its associated enterprises for ₹.53,33,43,789/-. The Assessee adopted the Transactional Net Margin Method (TNMM') to determine the arm's length of the said international transactions. It earned a margin of operating profit to total cost (hereinafter referred

Crisil Ltd, Mumbai vs. DCIT 9(2)(2), Mumbai

ITA 997/MUM/2016[2011-12]Status: DisposedITAT Mumbai10 Jan 2024AY 2011-12

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleιτα.Νο. 7603/Mum/2012 (A.Y: 2008-09) M/S. Crisil Limited V. Addl. Cit - 8(1) 8Th Floor, Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant) Ιτα.Νο. 1564/Mum2014 (A.Y: 2009-10) M/S. Crisil Limited V. Dy. Cit (Osd) – 8(1) Central Avenue Road Aayakar Bhavan, M.K. Road Hiranandani Business Park Mumbai- 400020 Opp. D-Mart, Powai Mumbai- 400076 (Respondent) Pan: Aaaст3151E (Appellant)

Section 133(6)Section 144C(5)

Ratings and (ii) Research. Under the Ratings segment, the Assessee is engaged in rendering back-end support for data analysis services to its associated enterprises through the Global Analytical Centre (GAC) which is the transaction under dispute. The Assessee had undertaken, inter-alia, international transactions of provision of back ... support for data analysis services from the GAC to its associated enterprises for ₹.53,33,43,789/-. The Assessee adopted the Transactional Net Margin Method (TNMM') to determine the arm's length of the said international transactions. It earned a margin of operating profit to total cost (hereinafter referred

Asst CIT RG 9(2)(1), Mumbai vs. Crisil Ltd, Mumbai

In the result the issue under

ITA 843/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble

Section 133(6)Section 144C(5)

Ratings and (ii) Research. Under the Ratings segment, the Assessee is engaged in rendering back-end support for data analysis services to its associated enterprises through the Global Analytical Centre (GAC) which is the transaction under dispute. The Assessee had undertaken, inter-alia, international transactions of provision of back ... support for data analysis services from the GAC to its associated enterprises for %.53,33,43,789/-. The Assessee adopted the Transactional Net Margin Method (TNMM') to determine the arm's length of the said international transactions. It earned a margin of operating profit to total cost (hereinafter referred

Crisil Ltd, Mumbai vs. Asst CIT RG 9(2)(2), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1114/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

Ratings and (ii) Research. Under the Ratings segment, the Assessee is engaged in rendering back-end support for data analysis services to its associated enterprises through the Global Analytical Centre (GAC) which is the transaction under dispute. The Assessee had undertaken, inter-alia, international transactions of provision of back ... support for data analysis services from the GAC to its associated enterprises for ₹.53,33,43,789/-. The Assessee adopted the Transactional Net Margin Method (TNMM') to determine the arm's length of the said international transactions. It earned a margin of operating profit to total cost (hereinafter referred