“international transaction”

Capitalg International Llc (Formerly Known As Gc Aisa L.L.C.), Mumbai vs. Assistant Commissioner of Income Tax Int Tax Circle 2(1)(1), Mumbai

same purchase price of Rs.101.47 Crores, that is, the price at which it has acquired from its AE. Thus, assessee had disclosed two international transactions during the year, firstly, sale and secondly, purchase of equity shares and CCPS of Girnar from its AE and was disclosed in the following manner ... report and TP Study Report has stated that proper information and documents as prescribed have been kept by the assessee in respect of the international transactions. Even though assessee failed to furnish the information and document which are vital factor to influence to determine the value of equity share

Deutsche Equities India Pvt. Ltd., Mumbai vs. Addl.C.I.T. RG. 4(1), Mumbai

case of the Assessee was selected for regular scrutiny. During the assessment proceedings, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference was made to the Transfer Pricing Officer for determination of Arm’s Length Price ... International Transactions undertaken by the Assessee with its AEs. Vide order dated, 31/10/2008, the Transfer Pricing Officer proposed Transfer Pricing Adjustment of INR 12,56,43,551/- in respect of Clearing House Trades (for short ‘CH Trades’) undertaken by the Assessee with its AEs. No transfer pricing adjustment was proposed

DCIT 4(1), Mumbai vs. Deutsche Equities India P.Ltd, Mumbai

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

case of the Assessee was selected for regular scrutiny. During the assessment proceedings, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference was made to the Transfer Pricing Officer for determination of Arm’s Length Price ... International Transactions undertaken by the Assessee with its AEs. Vide order dated, 31/10/2008, the Transfer Pricing Officer proposed Transfer Pricing Adjustment of INR 12,56,43,551/- in respect of Clearing House Trades (for short ‘CH Trades’) undertaken by the Assessee with its AEs. No transfer pricing adjustment was proposed

DCIT 14(3)(1), Mumbai vs. Tpg Capital India P. Ltd, Mumbai

In the result, appeal of the assessee bearing ITA 3132/Mum/2019is

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

disregarding the methodically prepared Transfer Pricing documentation submitted by the Appellant and in not appreciating that the arm's length price of the international transaction in relation to non-binding investment advisory services was appropriately determine 4. The CIT(A)/AO/TPO erred on facts and circumstances of the case ... assessee filed its return of income for A.Y. 2011-12 on dated 28.11.2011 declaring total income at Rs.3,81,92,398/-. Noticing international transactions during the year, the Id. AO referred the case of the assessee under section 92CA(1) of the Act to the Transfer Pricing Officer (in short

Assistant Commissioner of Income Tax- 4(2)(1), Mumbai vs. Gupshup Technology India Private Limited, Mumbai

In the result, the appeal of the revenue is dismissed

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Rs.15,66,05,766/-. The case was selected for scrutiny and the statutory notices were duly served on the assessee. Since the assessee had international transactions with its AE, reference was made to the Transfer Pricing Officer (TPO) to 3 ITA No. 2327/Mum/2024- Gupshup Technology India Pvt. Ltd. determine ... Arms Length Price (ALP) of the international transactions. The TPO vide order dated 30.01.2015 under section 92CA(3) of the Act made an adjustment towards Payment towards MNC services for an amount of Rs. 29,406,798. The Assessing Officer (AO) while passing order under section 143(3) r.w.s. 144C

Tpg Capital P. Ltd, Mumbai vs. DCIT 14(3)(1), Mumbai

In the result, appeal of the assessee bearing ITA 3132/Mum/2019is allowedand appeal of the revenue bearing ITA 3283/Mum/2019 is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjeetpg Capital India Private Limited Vs Deputy Commissioner Of 1004, The Capital, Plot No.C-70, Income-Tax, Circle-14(3)(1), Mumbai Room O.475, 4Th Floor, G-Block, Bandra Kurla Complex Bandra (East), Mumbai-400 051 Aayakar Bhavan, M.K. Road, Pan :Aabcn6660K Mumbai-400 020 Dcit-14(3)(1), Mumbai Vs Tpg Capital India Private Limited 1004, The Capital, Plot No.C-70, G-Block, Bandra Kurla Complex Bandra (East), Mumbai-400 051 Pan :Aabcn6660K

disregarding the methodically prepared Transfer Pricing documentation submitted by the Appellant and in not appreciating that the arm's length price of the international transaction in relation to non-binding investment advisory services was appropriately determine 4. The CIT(A)/AO/TPO erred on facts and circumstances of the case ... assessee filed its return of income for A.Y. 2011-12 on dated 28.11.2011 declaring total income at Rs.3,81,92,398/-. Noticing international transactions during the year, the ld. AO referred the case of the assessee under section 92CA(1) of the Act to the Transfer Pricing Officer (in short

DCIT (Ltu)-1, Mumbai vs. Aditya Birla Nuvo Ltd, Mumbai

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am Ι.Τ.Α. No. 5848/Mum/2017 (Assessment Year: 2012-13) Aditya Birla Nuvo Limited (Since Amalgamated With Grasim Industries Ltd.), Corporate Finance Division, A2, Aditya Birla Centre, A Wing, 2Nd Floor, S.K. Ahire Marg, Worli, Mumbai-400030. Pan: Aaaci1747H Vs. The Acit- Ltu-1, World Trade Centre, 29Th Floor, Centre-1, Cuffe Parade, Mumbai-400005. Appellant) : Respondent) Ι.Τ.Α. No. 5935/Mum/2017 (Assessment Year: 2012-13) The Dcit- Ltu-1, World Trade Centre, 29Th Floor, Centre-1, Cuffe Parade, Mumbai-400005. Aditya Birla Nuvo Limited (Since Amalgamated With Grasim Industries Ltd.), Corporate Finance Division, A2, Aditya Birla Centre, A Wing, 2Nd Floor, S.K. Ahire Marg, Vs. Worli, Mumbai-400030. Pan : Aaaci1747H Respondent) Appellant) Appellant/Assessee By : Shri Ronak Doshi / Riken Shah, Ar Revenue/Respondent By : Shri Ashish Kumar Agrawal, Sr. Dr. Date Of Hearing : 25.06.2024 Date Of Pronouncement : 01.07.2024 Order Per Padmavathy S, Am: These Cross Appeals By The Assessee & The Revenue Are Against The Order Of The Commissioner Of Income Tax (Appeals)-55, Mumbai Dated 27.06.2017 For

allowed on payment basis. Upholding the action of the TPO of treating corporate guarantee given to subsidiaries as international transaction and partly confirming the additions made by the TPO. Claim of Education and Secondary and Higher Education Cess as an allowable expenditure Re-computation of Dividend Distribution Tax ("DDT") liability ... duly served on the assessee. A reference was made to the Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the International Transaction the assessee is having with its Associated Enterprises (AE). The TPO passed an under section 92CA of the Act dated 29.01.2016 computing

Aditya Birla Nuvo Ltd (Since Amalgamated With Grasim Industries Limited), Mumbai vs. Asst CIT (Ltu) 1, Mumbai

In the result, appeal of the Revenue is dismissed

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

allowed on payment basis. 7 Upholding the action of the TPO of treating corporate guarantee given to subsidiaries as international transaction and_ partly confirming the additions made by the TPO. Additional Claim of Education and Secondary and Higher Education Cess as Ground No.1 an allowable expenditure Additional Re-computation ... duly served on the assessee. A reference was made to the Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the International Transaction the assessee is having with its Associated Enterprises (AE). The TPO passed an under section 92CA of he Act dated 29.01.2016 computing

DCIT (It) 2(2)(2), Mumbai vs. The Hongkong and Shanghai Banking Corp Ltd, Mumbai

In the result, the captioned appeals by the assessee are partly

Bench: Shri Narendra Kumar Billaiya, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm's length by the Id. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently

The Hongkong and Shanghai Banking Corporation Ltd, Mumbai vs. Addl DIT (It) -3, Mumbai

In the result, the captioned appeals by the assessee are partly allowed and that of the revenue are partly allowed

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm’s length by the ld. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently

DCIT (It) 2(2)(2), Mumbai vs. The Hongkong and Shanghai Banking Corp Ltd, Mumbai

In the result, the captioned appeals by the assessee are partly allowed and that of the revenue are partly allowed

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Raj Kumar Chauhan, Hon'Ble

Hongkong & Shanghai Banking Corporation Ltd., 14.14. It would be crucial to note that assessee had reflected more than 100 international transactions in form No.3CEB filed along with the return of income and the same were accepted to be at arm’s length by the ld. TPO. Admittedly these transactions include ... Norske Veritos A/S. v. Additional Director of Income Tax reported in 67 taxmann.com 16 (Mumbai Tribunal) wherein it was held that if the main international transactions have been benchmarked, then incidental transaction cannot be considered as a standalone transaction and an adjustment to that effect cannot be made independently