ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

ACIT, CHANDIGARH vs. M/S GLAXO SMITHKLINE ASIA PVT. LTD., GURGAON

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. DCIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

M/S GLAXOSMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,GURGAON vs. ACIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

M/S GLAXO SMITHKLINE ASIA PVT. LTD.,NABHA vs. DCIT, C-4(1), CHANDIGARH

In the result, all the appeals of the assessee and the Revenue, stand partly allowed for statistical purposes

TP study. analysis of comparable companies undertaken at the time of preparation of transfer pricing study, then under such circumstances, the TPO should not have undertaken a fresh search and considered a fresh set of the TPO comparable companies. In fact, has cherry picked only the companies with higher margins in order to predetermined result and rejected the said companies

DSM SINOCHEM PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHR vs. DCIT, CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018(िन.व.2014-15) ITA NO.253/Chd./2026 (A.Y.2011-12) ITA NO.1592/Chd./2018 (A.Y.2014-15) payment in uncontrolled circumstances. We find that this issue is perennial

M/S DSM SINOCHEM PHARMACEUTICALS INDIA PVT. LTD. ,TOANSA vs. DCIT, C-1(1), CHANDIGARH

In the result, appeal of the assessee is partly allowed

Bench: Shri N.K. Saini, Vice- & Shri Vikas Awasthyआअसं. 253/ चंडीगढ़/2016(िन.व. 2011-12)

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar 4 आअसं.253/ चंडीगढ़/2016(िन.व.2011-12) आअसं.1592/ चंडीगढ़/2018(िन.व.2014-15) ITA NO.253/Chd./2026 (A.Y.2011-12) ITA NO.1592/Chd./2018 (A.Y.2014-15) payment in uncontrolled circumstances. We find that this issue is perennial