← All Phrases

“international transaction”

Transfer PricingSection 92BSection 92B3,408 judgments

The decision most relied on for international transaction is Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT (374 ITR 118), cited in 499 judgments on BharatTax.

Leading authorities on international transaction

Sony Ericsson Mobile Communications India Pvt. Ltd. v. CIT
374 ITR 118 · 2015 · High Court
499
citing judgments

The existence of an international transaction for Advertising and Marketing Promotion (AMP) expenditure requires the revenue to discharge the burden of proof. An explanation inserted under Section 92B does not automatically make AMP expenditure an international transaction.

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.

India Vs. Azadi Bachao Andolan 263 ITR 706 (SC); and Vodafone International Holdings B.V v. Union of India
341 ITR 1 · 2012 · Supreme Court
295
citing judgments

Legitimate tax planning is permissible, allowing taxpayers to arrange their affairs to minimize tax liabilities while respecting the "look at test" for transaction genuineness and the separate entity principle in corporate taxation. The source of funds for treaty-beneficial structures does not automatically invalidate the transaction.

Maruti Suzuki India Ltd. v. CIT
381 ITR 117 · 2016 · High Court
220
citing judgments

The Bright Line Test (BLT) is not a recognized method under the Income-tax Act and Rules for benchmarking advertising, marketing, and promotion (AMP) expenses or for determining the existence of an international transaction or its Arm's Length Price. The Revenue must first establish the existence and price of an international transaction before seeking an ALP adjustment.

Vodafone India Services (P.) Ltd. v. Union of India
368 ITR 1 · 2014 · High Court
172
citing judgments

The issue of shares and share premium is a capital account transaction, not an income-generating event, therefore Chapter X (Transfer Pricing) provisions are not attracted to deem notional or hypothetical income from such transactions.

Sir Kikabhai Premchand v. CIT
24 ITR 506 · 1953 · Supreme Court
156
citing judgments

One cannot make a taxable profit or loss from transactions with oneself, as profit only arises from dealings with external third parties, even when transferring assets between different accounts or divisions of the same entity.

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.

Bausch & Lomb Eye Care (India) Pvt. Ltd. v. Additional CIT
381 ITR 227 · 2016 · High Court
127
citing judgments

The existence of an international transaction must be established before its arm's length price can be determined. An alleged 'excessive' AMP expenditure cannot unilaterally expand the scope of an international transaction if its existence is contested.

Judgments citing international transaction

Greenland Finance and Leasing P. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal of the Assesse in ITA No

ITA 1295/DEL/2019[2010-11]Status: DisposedITAT Delhi06 Jan 2025AY 2010-11

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 250(6)Section 92CSection 92C(3)Section 92D

That on the facts and circumstances of the case and in law, the Ld. CIT (A) erred in confirming the addition in respect of international transaction of provision of contract Research and Development ('R&D') services by relying on the order passed by the Ld. TPO/Ld. AO under Section 92CA ... /143(3) of the Act. 3. The Ld. CIT(A)/Ld. AO/Ld. TPO erred on facts and in law in holding that the international transaction pertaining to provision of contract R&D service does not satisfy the arm's length principle envisaged under the Act and in doing so have

Greenland Finance and Leasing P. Ltd., Delhi vs. ITO, New Delhi

In the result, the appeal of the Assesse in ITA No

ITA 1294/DEL/2019[2009-10]Status: DisposedITAT Delhi06 Jan 2025AY 2009-10

Bench: Shri Vikas Awasthy & Shri Manish Agarwalm/S Wrigley India Private Dcit, Limited Circle-27(2), 206, Okhla Industrial Vs. New Delhi. Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent) Joint Cit (Osd), M/S Wrigley India Private Circle-27(2), Limited, New Delhi Vs. 206, Okhla Industrial Estate, Phase Iii, New Delhi-110020 Pan-Aaacw1789P (Appellant) (Respondent)

Section 250(6)Section 92CSection 92C(3)Section 92D

That on the facts and circumstances of the case and in law, the Ld. CIT (A) erred in confirming the addition in respect of international transaction of provision of contract Research and Development ('R&D') services by relying on the order passed by the Ld. TPO/Ld. AO under Section 92CA ... /143(3) of the Act. 3. The Ld. CIT(A)/Ld. AO/Ld. TPO erred on facts and in law in holding that the international transaction pertaining to provision of contract R&D service does not satisfy the arm's length principle envisaged under the Act and in doing so have

Novateur Electrical and Digital Systems Private Limited, Mumbai vs. ACIT - 10(3)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 2767/MUM/2019[2011-12]Status: DisposedITAT Mumbai31 Dec 2024AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawalassessment Year: 2011-12

For Appellant: Shri Rajan Vora and Nikhil Tiwari, CAFor Respondent: Shri Pankaj Kumar, CIT DR
Section 143(3)Section 144C(3)Section 153Section 32Section 43(1)

issued notice u/s.143(2) on 02.08.2012 in the name of Legrand itself. Thus, two separate scrutiny assessment proceedings were initiated. Both the companies had international transactions and therefore both had filed their respective Form 3CEB in compliance with the transfer pricing regulations. In case of both, respective ld. Assessing Officers ... transfer pricing adjustments for the purpose of making addition of Rs.6,65,357/- on account of adjustment made in ALP in respect of international transactions with AEs. Subsequent to the draft assessment order, final assessment order was passed u/s.143(3) r.w.s. 144C(3), dated 20.04.2015 by DCIT

Uber India Systems Private Limited (As Successor to Uber India Research and Development Private Limited), Hyderabad vs. DCIT., Circle-8(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 581/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Jehangir D MistriFor Respondent: : Ms. M.Narmada, CIT-DR
Section 144B(1)Section 144C(13)Section 92D

additional transfer pricing adjustment of INR 7.5 Crs. The Appellant prays that for computing arm's length price, only operating cost for the international transaction i.e., 133.6 Crs should be considered in cost base. 15. Without prejudice, the Appellant prays that transfer pricing adjustment be reduced proportionately, to the extent ... made to the Learned Transfer Pricing Officer (“Ld. TPO”) to determine the Arm’s Length Price (“ALP”) of the international transactions of the assessee with its associates. The Ld. TPO vide his order dated 31.07.2021 suggested total transfer pricing adjustment of Rs.29,56,00,291/-. Thereafter, the Ld. AO passed

Zuari Cement Limited, Kadapa vs. DCIT Circle -1, Nellore

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

ITA 502/HYD/2022[2018-19]Status: DisposedITAT Hyderabad30 Dec 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Deepak Chopra, Advocate and Shri Nitin Narang,C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 144C(5)Section 92D

erred on the facts and in law in making the TP adjustment of INR 56,38,26,985 in respect of the international transactions. Ground on Rejection of the bonafide TP Documentation/Economic Analysis maintained by the Appellant 4. That the Transfer Pricing Officer ("TPO") and DRP erred on the facts ... Rules, 1962 ("the Rules") and proceeded to make the TP addition based on re-determination of the arm's length price ("ALP") of the international transactions. Grounds on Rejection of combined Transactional Net Margin Method ("TNMM") selected as Most Appropriate Method ("MAM") by the Appellant and adopting Comparable Uncontrolled Price

Deputy Commissioner of Income Tax, (Exemptions), Circle-1, Bengaluru vs. Rashtrotthana Parishat, Bengaluru

In the result, the appeal filed by the Revenue is allowed

ITA 1666/BANG/2024[2017-18]Status: HeardITAT Bangalore30 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

For Appellant: Ms. Neera Malhotra CIT-D.RFor Respondent: Sri Prakash Shridhar Hegde, CA
Section 11Section 11(6)Section 250Section 270ASection 274

length price determined by the Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e)the amount of undisclosed income referred to in section 271AAB ... failure to record any receipt in books of account having a bearing on total income; and (f)failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply. (10)The tax payable

Deputy Commissioner of Income Tax, Nashik vs. Chakrahar Contractors and Engineers Private Limited, Jalgaon

In the result, both the appeals of the Revenue are

ITA 1940/PUN/2024[2021-22]Status: DisposedITAT Pune26 Dec 2024AY 2021-22

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB ... 1940/PUN./2024 (e) failure to record any receipt in books of account having a bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply

Deputy Commissioner of Income Tax, Nashik vs. Chakradhar Contractors and Engineers Private Limited, Jalgaon

In the result, both the appeals of the Revenue are

ITA 1939/PUN/2024[2020-21]Status: DisposedITAT Pune26 Dec 2024AY 2020-21

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

For Appellant: Shri Sanket M JoshiFor Respondent: Shri Amol Khairnar, CIT-DR
Section 131Section 143Section 143(1)(a)Section 143(2)Section 270ASection 270A(3)(i)Section 270A(6)(a)Section 270A(9)

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB ... 1940/PUN./2024 (e) failure to record any receipt in books of account having a bearing on total income; and (f) failure to report any international transaction or any transaction deemed to be an international transaction or any specified domestic transaction, to which the provisions of Chapter X apply

Mikuni India Private Limited, Alwar vs. Principal Commissioner of Income Tax, PCIT

12. In view of the above discussion, we find merit in this appeal, when the assessment order dated 27

ITA 745/JPR/2024[2017-18]Status: DisposedITAT Jaipur26 Dec 2024AY 2017-18

Bench: passing the impugned order, Learned PCIT issued notice to the assessee, as Learned PCIT found that the Assessing Officer, while framing the above said assessment and the making addition, did not initiate penalty proceedings 270A of the Act. Learned PCIT was of the view that penalty proceedings were to be initiated under the said provision on account of misreporting of income, which came to be added by the Assessing Officer to the total income of the assessee company. It being a Transfer Pri

For Appellant: Shri Abhishek Agarwal, C.A. (Through V.C.) &For Respondent: Ms. Alka Gautam (CIT)
Section 143(3)Section 144C(5)Section 194C(5)Section 263Section 270ASection 92CSection 94C

placed on the decision dated 20.2.2023 in Anjis Developers Private Limited vs. PCIT, ITA No. 959/MUM/2022. 6. Admittedly, the assessee company entered into various international transactions with its Associate Enterprises; that the case was selected for scrutiny, and referred to Transfer Pricing Officer (in short “TPO”) u/s 92CA ... directed the Assessing Officer to enhance the income of the assessee by the said additions, keeping in view the international transactions relating to purchase and payment royalty. It is also true that at the same time, DCIT TP had observed “Assessing Officer may to examine the issue of initiation

Decathlon Sports India Private Limited, Bangalore, Karnataka vs. Deputy Commissioner of Income-Tax Circle 2(2)(1), Bengaluru, Karnataka

In the result appeal of the assessee is partly allowed as indicated

ITA 1874/BANG/2024[2020-2021]Status: DisposedITAT Bangalore26 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi

For Appellant: Shri Chavali Narayan, CA
Section 143(3)Section 92C

Appellant in accordance with the provision of the Act read with Income-tax Rules, 1962 (“the Rules”) and holding that the Appellant’s impugned international transactions pertaining to trading segment, payment of intra group services and trade receivables are not at arm’s length. SA No.60/Bang/2024 ... Page 4 of 37 The Ld. AO /TPO /DRP, erred by not restricting the quantum of TP adjustment proportionately to the value of the international transactions being disputed by the AO/TPO. The Ld. AO /TPO /DRP, erred in not acknowledging that the gross margins earned by the Appellant

Assistant Commissioner of Income Tax, Circle-2(1)(1), Ahmedabad vs. Kiri Industries Ltd, Ahmedabad

In the result, the appeal is allowed and the adjustment made in the intimation under section 143(1) dated August 13, 2017 denying carry forward of loss of Rs

ITA 1170/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad25 Dec 2024AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Tushar Hemani, Sr. Adv. & ShriFor Respondent: Shri A.P. Singh, CIT DR
Section 139Section 143(1)Section 143(1)(a)Section 92E

this case was 30.11.2016 and not 17.10.2016, as mistakenly noted by the CPC. The assessee pointed out that since the assessee was engaged in “international transactions” and it had to comply with provisions of Section 92E of the Act, it was required to submit Form 3CEB by 30.11.2016, and therefore ... date for filing return is November 30 of the assessment year. It was pointed out that the appellant had entered into an international transaction and filed Form 3CEB as pen-section 92E read with Rule 10E. Therefore, the due date for filing return for AY 2016-17 was November

Biocon Biologics Limited, Bangalore vs. The Assistant Commissioner of Income Tax, Circle 2(1)(1), Bangalore

ITA 1590/BANG/2024[2020-21]Status: DisposedITAT Bangalore23 Dec 2024AY 2020-21

Bench: Shri Prashant Maharishi & Shri Prakash Chand Yadavit(Tp)A No.1590/Bang/2024

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(3)Section 92Section 92C

March 2021 and tax was payable on Book profit tax. 3. This return was picked up for scrutiny and as assessee has entered into international transactions, a reference was made to the DCIT(TP), 1(1)(2) [Id. TPO] to determine the arm's length price (ALP) of various international ... transactions. The assessee has also entered into several specified domestic transactions. 4. The Id. TPO examined the international transactions. He found that as per Form no 3CEB there are several outstanding receivables from the Associated Enterprises however assessee did not benchmark them separately but stated there in that these

Reliance Industries Holdings Private Limited (the Appellant) Successor of M/S Ekansha Enterprises Pvt Ltd ), Mumbai vs. Commissioner of Income Tax (CIT)A-56, Mumbai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2992/MUM/2024[2012-13]Status: DisposedITAT Mumbai23 Dec 2024AY 2012-13

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 147Section 250Section 92ASection 92A(2)(j)Section 92BSection 92E

clause (d) of Explanation 2 to Section 147 were not fulfilled 6. failed to appreciate that the retrospective amendment to the definition of "international transaction" was inserted by Finance Act, 2012, which cannot be applied retro-actively to allege that income of the Appellant had escaped assessment ... filing of report u/s. 92E of the Act. Transfer pricing provisions could not apply in absence of any international transaction u/s. 92B of the Act: 7. erred in not appreciating that the Predecessor and BMPL were not Associated Enterprise u/s. 92A of the Act. 8. failed to appreciate that

Reliance Industries Holding Private Limited (the Appellant (Successor of M/S Ekansha Enterprises Private Limited), Mumbai vs. Commissioner of Income Tax Appeal (CIT)-56, Mumbai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2991/MUM/2024[2011-12]Status: DisposedITAT Mumbai23 Dec 2024AY 2011-12

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 147Section 250Section 92ASection 92A(2)(j)Section 92BSection 92E

clause (d) of Explanation 2 to Section 147 were not fulfilled 6. failed to appreciate that the retrospective amendment to the definition of "international transaction" was inserted by Finance Act, 2012, which cannot be applied retro-actively to allege that income of the Appellant had escaped assessment ... filing of report u/s. 92E of the Act. Transfer pricing provisions could not apply in absence of any international transaction u/s. 92B of the Act: 7. erred in not appreciating that the Predecessor and BMPL were not Associated Enterprise u/s. 92A of the Act. 8. failed to appreciate that

Reliance Industries Holdings Private Limited (the Appellant (Successor of M/S Ekansha Enterprises Pvt Ltd ), Mumbai vs. Commissioner of Income Tax (CIT )A-56, Mumbai

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 2990/MUM/2024[2009-10]Status: DisposedITAT Mumbai23 Dec 2024AY 2009-10

Bench: Shri Sandeep Gosain & Shri Omkareshwar Chidara

Section 143(3)Section 147Section 250Section 92ASection 92A(2)(j)Section 92BSection 92E

clause (d) of Explanation 2 to Section 147 were not fulfilled 6. failed to appreciate that the retrospective amendment to the definition of "international transaction" was inserted by Finance Act, 2012, which cannot be applied retro-actively to allege that income of the Appellant had escaped assessment ... filing of report u/s. 92E of the Act. Transfer pricing provisions could not apply in absence of any international transaction u/s. 92B of the Act: 7. erred in not appreciating that the Predecessor and BMPL were not Associated Enterprise u/s. 92A of the Act. 8. failed to appreciate that

Cummins Generator Technologies India Private Limited, Pune vs. The Assessment Unit, Income Tax Department, NFAC and the ACIT, Circle 1(1), Pune

In the result, appeal of the assessee is partly allowed

ITA 1641/PUN/2024[2020-21]Status: DisposedITAT Pune19 Dec 2024AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपीलसं. / Ita No.1641/Pun/2024 िनधा"रण वष" / Assessment Year: 2020-21 Cummins Generator V The Assessment Unit, Technologies India Pvt. Ltd., S Income Tax Department, Tower A, 6Th Floor, Cummins Nfac & The Acit, India Offie Campus, Balewadi, Circle-1(1), Pune. Pune – 411045. Pan: Aabcc1533E Appellant/ Assessee Respondent / Revenue Assessee By Shri Ketan Ved – Ar Revenue By Shir Prakash L Pathade – Cit(Dr) Date Of Hearing 05/12/2024 Date Of Pronouncement 19/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Assessing Officer Passed Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 Dated 07.06.2024; To Give Effect To The Order Of Dispute Resolution Panel Dated 18.05.2024. The Grounds Of Appeal Raised By The Assessee Are As Under : “1. Ground For Not Following The Directions Of The Hon'Ble Dispute Resolution Panel (Hereinafter Referred To As "Drp")

Section 143(3)Section 144BSection 92C

making an upward adjustment of INR 3,29,56,988/ to the total income of the Appellant by holding that international transaction of payment of royalty by the Appellant is not at arm's length. 2. General Ground: Transfer pricing adjustment ... erred in making an upward adjustment INR 3,29,56,988/- to the total income of the Appellant by wt holding that international transaction of payment of royalty by the Appellant is not at arm's length. 2.2 The Ld. AO/TPO pursuant to the directions

Limagrain India Private Limited, Hyderabad vs. DCIT, Circle -5(1), Hyderabad

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

ITA 464/HYD/2022[2018-19]Status: DisposedITAT Hyderabad19 Dec 2024AY 2018-19

Bench: Shri Manjunatha G. (Accountant Member), Shri K. Narasimha Chary (Judicial Member)

For Appellant: Shri R.Srinivasulu, ARFor Respondent: : Shri B.Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)Section 92C

revenue and operating cost of the Appellant at entity level to compute the Transfer Pricing adjustment, instead of restricting it to the value of international transaction. 4. Without prejudice to ground no.2, the Ld.AO/Hon'ble DRP erred in law and on facts in selecting functionally different companies while determining ... facts in making a transfer pricing adjustment of INR 6,56,70,952/-- by treating the ALP as Nil, in relation to the international transaction involving receipt of intra- group services by the Assessee from its Associated Entities (“AEs”) 6. The Ld.AO/Hon'ble DRP erred in law and on facts

Deputy Commissioner of Income Tax-Circle-4(1)(1), Bangalore vs. Eygbs (India) Private Limited, Bangalore

In the result, the appeal by the AO is dismissed

ITA 1586/BANG/2024[2017-18]Status: DisposedITAT Bangalore19 Dec 2024AY 2017-18

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 92C(4)

dated 20.5.2020 in ITA No.199/Bang/2015 allowing deduction u/s. 10AA on account of voluntary adjustment made to arm’s length price (ALP) of international transaction pursuant to the Advance Pricing Agreement (APA) without considering the fact that Special Leave Petition (SLP) of the ld. AO on this issue is pending before ... 10AA of Rs.62,57,52,277. The claim of assessee was that assessee entered into APA on 16.3.2016 and consequently the ALP of the international transaction was agreed with higher adjustment of Rs.9.50 crores. It is the claim of the assessee that adjusted APA is not an adjustment made

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-2, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 1783/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2015-16

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

case of the assessee. It was, however, stated that with respect to the issues raised regarding transfer pricing adjustment made to the international transactions entered into by the assessee there were some distinguishing facts/proposition of law which needed to be brought to the notice of the Bench/argued before the Bench ... applying the transfer pricing ('TP') provisions and making a TP adjustment of Rs.215,34,57,741 to the value of international transactions entered into by the Appellant with Hazira LNG Private Limited ('HLPL') in respect of rendering services in relation to operation of LNG storage and regasification. 1.2. The learned

Shell Global Solutions International B.V, Mumbai vs. The ACIT, Intl. Taxn.-1, Ahmedabad

In the result, the appeal of the assessee is partly allowed, while the CO filed by the Revenue is dismissed

ITA 2390/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad18 Dec 2024AY 2014-15

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarwith Co No.20/Ahd/2022 Assessment Year : 2014-15 & 1783/Ahd/2019 Assessment Year : 2015-16 Shell Global Solutions International B.V.,, Acit, International C/O. Bsr Associates & Llp Vs Taxation-1 903, Commerce House V Ahmedabad. Nr.Vodafone House Prahaladnagar Corporation Road, Ahmedabad. Pan : Aaics 3589 H (Applicant) (Responent) : Assessee By Shri S.N. Soparkar, Sr.Advocate & Shri Parin Shah, Ar : Dr. Darsi Suman Ratnam, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 05/09/2024 & 06/12/2024 घोषणा क" तारीख /Date Of Pronouncement: 18/12/2024

Section 143(3)Section 144C

case of the assessee. It was, however, stated that with respect to the issues raised regarding transfer pricing adjustment made to the international transactions entered into by the assessee there were some distinguishing facts/proposition of law which needed to be brought to the notice of the Bench/argued before the Bench ... applying the transfer pricing ('TP') provisions and making a TP adjustment of Rs.215,34,57,741 to the value of international transactions entered into by the Appellant with Hazira LNG Private Limited ('HLPL') in respect of rendering services in relation to operation of LNG storage and regasification. 1.2. The learned