“international transaction”

DCIT-1(2)(1), Mumbai vs. M/S Cactus Communication Pvt Ltd, Mumbai

The appeal of the Assessee is allowed

case of the Appellant was selected for scrutiny. During the assessment proceedings, the Assessing Officer noted that the Appellant has entered into international transactions with its Associated Enterprises (AEs) and therefore, a reference was made under Section 92CA(1) to the Transfer Pricing Officer (TPO) for the determination ... Length Price (ALP) of the international transactions. 5.2. The TPO noticed that Appellant is a company engaged in the business of providing editing, educational transaction, and training services to individual and institutional clients worldwide. The Appellant has, selected its AE as a tested party for benchmarking the international transactions using

Tech Mahindra Ltd, Mumbai vs. DCIT 2(3), Mumbai

In the result we are not inclined to interfere in the order of Ld

Bench: Shri Vikas Awasthy & Shri Gagan Goyaltech Mahindra Limited, C/O Marriott Hotels India Pvt. Ltd. Gateway Building, Apollo Bunder, Mumbai-400001 Pan: Aaacm3484F ...... Appellant Vs. Dcit-2(3), Room No. 552, Aayakar Bhavan, M.K. Marg, Mumbai-400020. ..... Respondent Acit Circle-2(3)(1), Room No. 552, 5Th Floor, Aayakar Bhavan, M.K. Marg, Mumbai-400020. ..... Appellant Vs. Tech Mahindra Limited, C/O Marriott Hotels India Pvt. Ltd. Gateway Building, Apollo Bunder, Mumbai-400001 Pan: Aaacm3484F ..... Respondent Appellant/Assessee By : Sh. J.D. Mistri / Sh. Harsh Kapadia Respondent/Revenue By : Sh. K.C. Kanojia- Cit-Dr

return of income on 23-09-2010 (in assessment order this date is written as 04-10-2010). The assessee had entered certain international transaction with its AEs within the meaning of sec 92B of the Act. The said transaction was duly reported by the assessee in form no 3CEB

Infiniti Retail Ltd, Mumbai vs. ITO 11(3)(4), Mumbai

losses. The case of the Appellant was selected for scrutiny. During the assessment proceedings, the Assessing Officer noted that the Appellant has entered into international transactions with its Associated Enterprises (AEs) and therefore, a reference was made under Section 92CA(1) to the Transfer Pricing Officer (TPO) for the determination ... Length Price (ALP) of the international transactions. The TPO, ITA. No. 461/Mum/2015 Assessment Years: 2011-12 vide order, dated 23.01.2015 passed under Section 92CA(3) of the Act, proposed transfer pricing adjustment of INR 58,99,019/- including the following two transfer pricing adjustments: Sr. No. Particulars Amount

Abbott India Ltd (As Successor to Solvay Pharma India Ltd), Mumbai vs. Addl CIT RG 7(2), Mumbai

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

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2007-08 Abott India Limited Addl. Cit-Range 7(2) Unit 3-4, Corporate Park, Aayakar Bhavan, M.K. Sion-Trombay Road, Chembur, Vs. Marg, Mumbai-400 071. Mumbai-400 020 Pan No. Aaacu 9269 Q Appellant Respondent Assessee By : Shri. Madhur Agrawal, Adv. Revenue By : Shri Yogesh Kamat, Cit Dr Date Of Hearing : 22/09/2022 Date Of Pronouncement : 30/11/2022

made by the learned Assessing Officer while determining the arm's length price u/s.143(3) r.w.s. 144C of the Act, in respect of the international transaction of import of Active 4 ABOTT INDIA LIMITED Pharmaceutical Ingredients (APIs) entered into by the appellant during the year ended 31 March ... grossly erred in rejecting the application of Transactional Net Margin Method (TNMM) as the most appropriate method used by the assessee for benchmarking the International transactions in respect of imports of APIs from its Associated Enterprise (AEs). Further learned Commissioner of Income-Tax (Appeals) also erred in not considering

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

ACIT CC-43, Mumbai vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

Roha Dyechem P. Ltd, Mumbai vs. ACIT Cen Cir 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

Roha Dyechem Pvt.Ltd., Mumbai vs. ACIT-Central Circle 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

Roha Dyechem Pvt.Ltd., Mumbai vs. ACIT-Central Circle 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

Roha Dyechem P. Ltd, Mumbai vs. ACIT Cen Cir 43, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

ACIT Cen Ci-43 vs. Roha Dyechem P. Ltd, Mumbai

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

facts in brief qua the issue in dispute are that in view of international transactions of sale of finished goods and interest received reported by the assessee, the learned Assessing Officer referred the matter for determination of arm‟s length price of those transactions to the learned Transfer Pricing Officer ... learned TPO in his order dated 15/12/2006 proposed adjustment of ₹ 1, 31, 05, 679 - in respect of international transactions of sale of finished goods, whereas with regard to interest transactions, he observed that assessee had advanced loans to 9 Associated Enterprises (AEs), and charged interest in respect

DCIT-2(2)(1), Mumbai vs. The Indian Hotels Company Ltd., Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

case of the Assessee was selected for scrutiny. During the assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference under Section 92CA(3) of the Act was made to the Transfer Pricing Officer (TPO) for determination ... Arms Length Price (ALP) of the International Transactions. The TPO, vide order dated 30.01.2015, passed under Section 92CA(3) of the Act proposed aggregate transfer pricing adjustments of INR 179,61,83,140/- which was incorporated by the Assessing Officer in the Draft Assessment Order, dated 31.03.2015 passed under Section

The Indian Hotels Company Ltd., Mumbai vs. DCIT Cir. 2(2)(1), Mumbai

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

case of the Assessee was selected for scrutiny. During the assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference under Section 92CA(3) of the Act was made to the Transfer Pricing Officer (TPO) for determination ... Arms Length Price (ALP) of the International Transactions. The TPO, vide order dated 30.01.2015, passed under Section 92CA(3) of the Act proposed aggregate transfer pricing adjustments of INR 179,61,83,140/- which was incorporated by the Assessing Officer in the Draft Assessment Order, dated 31.03.2015 passed under Section