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16 results for “disallowance”+ TP Methodclear

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Key Topics

Addition to Income4Section 1443Transfer Pricing3TP Method3Section 37(1)2

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

ITA 1592/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh20 Jan 2022AY 2014-15

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

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

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

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

In the result, appeal of the assessee is partly allowed

ITA 253/CHANDI/2016[2011-12]Status: Disposed
ITAT Chandigarh
20 Jan 2022
AY 2011-12

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

For Appellant: Sh.K.M Gupta, Adv., Sh. NishantFor Respondent: Sh. Vikram Batra, CIT-DR
Section 144

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

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

ITA 227/CHANDI/2017[2010-11]Status: DisposedITAT Chandigarh26 Oct 2021AY 2010-11

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 221/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 222/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 228/CHANDI/2017[2011-12]Status: DisposedITAT Chandigarh26 Oct 2021AY 2011-12

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 47/CHANDI/2018[2013-14]Status: DisposedITAT Chandigarh26 Oct 2021AY 2013-14

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 242/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 225/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 220/CHANDI/2017[2008-09]Status: DisposedITAT Chandigarh26 Oct 2021AY 2008-09

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 226/CHANDI/2017[2009-10]Status: DisposedITAT Chandigarh26 Oct 2021AY 2009-10

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 1495/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh26 Oct 2021AY 2015-16

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 219/CHANDI/2017[2007-08]Status: DisposedITAT Chandigarh26 Oct 2021AY 2007-08

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

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

ITA 1500/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh26 Oct 2021AY 2014-15

disallowed. 33. Before us the submissions made before the authorities below were reiterated stating that the provision so claimed represented additional liability on account of VAT in respect of sale of finished goods made by the assessee which was provided as per estimate of such market claims by the dealers or distributors. The contention of the ld. counsel

M/S CENTRIENT PHARMACEUTICALS INDIA PRIVATE LIMITED,NAWANSHAHAR vs. ADDITINAL/JOINT/DEPUTY/ASSTT. C.IT,ITO,NEAC, DELHI

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

ITA 102/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh18 Jun 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Darpan Kirpalani, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 144

method and determined ALP of the transaction as Nil. The TPO has further observed that no independent party would have made a similar payment in uncontrolled circumstances. We find that this issue is perennial in nature, the TPO has been consistently making TP adjustment in respect of corporate services fee for similar reasons. The co-ordinate bench in appeal

DCIT, C-1(1) , CHANDIGARH vs. M/S FIDELITY INFORMATION SERVICES INDIA PVT. LTD., CHANDIGARH

In the result, the cross-objection filed by the assessee is dismissed

ITA 1328/CHANDI/2019[2014-15]Status: DisposedITAT Chandigarh07 Jun 2024AY 2014-15

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vishal Kalra, Advocate and Ms. Sumisha, C.AFor Respondent: Shri Rohit Sharma, CIT DR
Section 37(1)

TP order; the APA Authority, while determining the mark-up as 16.60%. Thus, it is not once but the cost-plus mark-up reimbursement has been verified by the lower authorities at various stages, i.e., TPO, APA and CIT(A). 9.15 It was submitted that the Hon'ble Tribunal while passing the order for assessment years