“international transaction”

Hindusthan Unilever Ltd, Mumbai vs. Dy CIT Range 1(1)(2), Mumbai

In the result, the appeal filed by the assessee and Revenue are partly

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

facts and in the circumstances of the case the Ld. CIT(A) has erred in allowing additional ground without appreciating that the international transactions of the assessee were very small in comparison with the total turnover of the assessee and that comparison at the entity level therefore implied that controlled ... Ground Nos. (ii) to (vi). 15. Ground Nos. (vii) to (xviii) are related to Transfer Pricing adjustment made by TPO/AO on various items of international transactions. The Ld. DR supported the order passed by the AO/TPO. 15.1. The assessee had selected TNM Method as most appropriate method and bench marked

Skillnet Solutions India Private Limited, Mumbai, Maharashtra vs. Deputy Commissioner of Income Tax, Mumbai, Maharashtra

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

dated 21 August 2024, erred in confirming the adjustment of INR 114,172,508/- by virtue of computation of arm's length price of international transaction of rendering of software consultancy and support services to AE vide its impugned order dated 06 September 2024. 2. Unjust/Erroneous rejection of the segmental

Assistant Commissioner of Income Tax-3-1-1, Mumbai vs. Ms. Samsonite South Asia Pvt. Ltd., Mumbai

In the result the appeal filed by the assessee stands dismissed

Bench: Beena Pillai & Shri Prabhash Shankarassessment Year: 2011-12

response to statutory notices, the assessee filed requisite details as clause for. The Ld. AO noted that assessee had entered into international transaction with its associated enterprise and accordingly a reference was made u/s. 92CA to the transfer pricing office (hereinafter referred as Ld. TPO). 2.3. Upon receipt ... furnish the details of the transaction in form 3CEB. On perusal of the details furnished by the assessee, the Ld. TPO analysed the international transaction and came to the conclusion that the same was an arm’s length. The Ld. TPO vide order dated 31/10/2014 passed the order u/s. 92CA

Indorama Ventures Oxides Ankleshwar Private Limited, Mumbai vs. DCIT, Circle 14(1)(1), Mumbai

In the result, the appeal of the assessee bearing ITA No

Bench: Shri. B.R. Baskaran & Shri. Anikesh Banerjee

call option with Indorama Netherlands BV which were embedded in the CCD subscription agreement dated 30 December 2019 and the same construed as an international transaction 3.3. On the facts and in the circumstances of the case and in law, the Ld. AO under the directions ... under the directions of the Ld. DRP erred in holding that purchase of surfactants business of HPL by the Appellant was a ‘deemed international transaction under section 928(2) of the IT Act 4.3. On the facts and in the circumstances of the case and in law, the Ld. TPO/Ld

Deutsche India Pvt. Ltd.(Earlier Known As 'Dboi Global Services Pvt. Ltd.), Mumbai vs. ACIT-1(3)(1), Mumbai

In the result, the appeal by the assessee is partly allowed for 16

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

erred in not demonstrating that the motive of the Appellant was to shift profits outside India by manipulating the prices charged in its international transactions; a pre-requisite condition to make any adjustment under the provision of Chapter X of the Act. Deutsche India Pvt Ltd h. Without prejudice ... erred in computing the transfer pricing adjustment on all the transactions of the Appellant instead of restricting it to the international transaction, i.e., transaction with non-resident associated enterprises. i. Without prejudice, on the facts and in the circumstances of the case