“associated enterprises”

Kantar Analytics India Private Limited (Formerly Known As Firefly Market Reserch India Private Limited (Successor of Analytics Quotient Service India Private Limited), Mumbai vs. Assistant Commissioner of Income Tax, Circle 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

statistical modelling, tools, scorecards, dashboards, customer relationship management, transaction analytics and tracking services. The Ld.AO observed that, the assessee had international transactions with its associated enterprise beyond the threshold limit, and accordingly reference was made to the Ld.TPO to determine ALP of such international transaction under ... Method adopted Transactional Net Margin Method (TNMM') Other Method TNMM 3.4 The Ld.TPO noted that assessee entered into management consultancy services with its associated enterprise (AE), the details of which are as under: Name of AE Analytics Quotient USA Kantar UK Ltd Nature of international Transaction Marketing support Inc. Implementation

Dsv Air & Sea Private Limited, Mumbai vs. ACIT, Cirle-3(1)(1), Mumbai

In the result, this ground of appeal is allowed for statistical purpose

Bench: Shri Pawan Singh& Smt.Renu Jauhri(Physical Hearing)

income for A.Y. 2020-21 declared income of Rs.9.98 crores. The case was selected for scrutiny. The assessee reported certain international transaction with its associated enterprises (AEs). Thus, the assessing officer (AO) made reference to Transfer Pricing Officer (TPO) for computation of arm’s length price ... broad functional level. It requires comparison between net margins derived from the operation of the uncontrolled parties and net margin derived by an associated enterprise on similar operation. In Pino Bisazza Glass (P) Ltd. vs ACIT in ITA No. 1690/Ahd/2010 held that under TNMM what is needed is functional similarity

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have any permanent establishment in India, whether as fixed place

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

assessment years from 2018-19 to 2021-22 the co ordinate benches in those cases have held that no permanent establishment arises merely because associated enterprises in India render support functions and that the reinsurance and retrocession premium is not taxable in India in the absence of a permanent establishment ... India belong to them and are used by them to carry on their own business as service providers. The mere rendering of services by associated enterprises in their own premises does not automatically confer disposal or control of such premises on the foreign enterprise. This proposition has been clearly laid

Swiss Re Asia Pte Ltd, Singapore vs. Deputy Commissioner of Income Tax, (International Taxation) Circle - 4(2)(2), Mumbai

In the result, we hold that the assessee does not have

assessment years from 2018-19 to 2021-22 the co ordinate benches in those cases have held that no permanent establishment arises merely because associated enterprises in India render support functions and that the reinsurance and retrocession premium is not taxable in India in the absence of a permanent establishment ... India belong to them and are used by them to carry on their own business as service providers. The mere rendering of services by associated enterprises in their own premises does not automatically confer disposal or control of such premises on the foreign enterprise. This proposition has been clearly laid

Lintas India Private Limited, Mumbai vs. DCIT, Circle 16(1), Mumbai

The appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2021-22 M/S. Lintas India Private Assessment Unit, Limited, Income Tax Department Or A Wing, 16Th Floor, Deputy Commissioner Of Parinee Crescenzo, Income Tax, Bandra-Kurla Complex, Circle 16(1), Bandra (East), 1) National Faceless Mumbai – 400 051 Assessment Centre (Nafac), Vs. Pan: Aaacl0124F Delhi 2)Aayakar Bhawan, Maharshi Karve Road, New Marine Lines, Churchgate, Mumbai – 400020 (Appellant) (Respondent) Present For: Assessee By : Shri Ajit Jain, Ld. A.R. Shri Karnik Kansara, Ld. A.R Ms. Neha Rai, Ld. A.R. Ms. Sakshi Chimanani, Ld. A.R. Revenue By : Shri Kiran Unavekar, Ld. Sr. D.R. Date Of Hearing : 22.08.2025 Date Of Pronouncement : 19.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 15.05.2023, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Dispute Resolution Panel-1) (In Short Ld. Commissioner) U/S 144C(5) Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2021-22. 2 M/S. Lintas India Private Limited

providing media planning services to its clients. The Assessee during the assessment year under consideration, had carried out following international transactions with its Associate Enterprises (in short “AEs”): Sr. Nature of Transaction Receipt/ Amount of Method used No. Payment Transaction by Taxpayer (Rs) to determine ALP 1. Assistance in public ... contentions made by the assessee during the course of hearing before us. During the year under consideration, the assessee has paid to its Associated Enterprises (AEs) on account of intra-group services. The intra group services are broadly divided into the following categories as mentioned below: Payment of Global Information

Shell India Markets Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 3(4), Mumbai

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

course of assessment proceedings, it came to the notice of the Assessing Officer that the assessee had entered into substantial international transactions with its associated enterprises. Accordingly, the matter was referred to the Transfer Pricing Officer (TPO), Ward 4(1)(1), under section 92CA for determination ... making an upward adjustment amounting to INR 109,94,08,144 in respect of Provision of SBO IT services (Bengaluru) by the Appellant to Associated Enterprises ("AE"), alleging the same to be not at arm's length in terms of provisions of Chapter - X of the Act 2.1 Not appreciating

Aditya Birla Nuvo Ltd (Since Amalgamated With Grasim Industries Limited), Mumbai vs. DCIT CC-1(4) Earlier With ACIT(Ltu) 1, Mumbai

In the result, theappeals filed by the assessee and revenue are partly

Bench: The Hon’Bleunder Section 255(4) Of The Act. The Points Of Difference Were Thereafter Referred To The Hon’Blefor Resolution. The Hon’Blehas Now Rendered His Detailed Opinion & The Appeals Have Been Placed Before Us To Pass The Consequential

downward adjustment to the arm’s length price (ALP) of the cost of electricity supplied by the Captive Power Plant(CPP) to its Associate Enterprises (AE), the manufacturing unit being Rayon plant, by treating it as Specified Domestic Transaction (SDT) in terms with section 92BA of the Act. As could ... said provision ALP means the price which is applied or proposed to be applied in a transaction between a person other than Associated Enterprise in uncontrolled conditions. He submitted, as per the definition of ALP u/s. 92F(ii), the price should be in relation to a transaction between two unrelated