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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

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

price adjustment be made to the income of the assessee in relation to the said transaction. 41. Taking up first the issue of characterization of delayed payment of receivables beyond 60 days as international transactions u/s 92B of the Act, we find that the AO/TPO and the DRP both have relied upon the insertion of Explanation below section 92B

JANTA LAND PROMOTERS PVT LTD,MOHALI vs. THE PRINICIPAL COMMISSIONER OF INCOME TAX ,CHANDIGARH-1, CHANDIGARH

In the result, appeal of the Assessee is allowed

92B or a specified domestic transaction within the meaning of section 92BA of the Act. In the present case, the learned PCIT has failed to point out any such transaction entered into by the assessee. In the absence of any specific instance requiring reference for transfer pricing

M/S GLAXOSMITHKLINE CONSUMER HEALTHCARE LTD.,GURGAON vs. ACIT, CHANDIGARH

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

Bench: The I.T.A.T. Drawing Our Attention To The Facts Of The Case The Ld. Counsel For Assessee Pointed Out That The Assessee Was A Public Limited Company Incorporated Under The Companies Act, 1956 & 2 A.Y.2007-08

Transfer Pricing order for the relevant assessment year dated 29.10.2010, the TPO had undertaken benchmarking analysis on advertisement, marketing and promotional expenses ( in short referred to as ‘AMP’ expense) incurred by the assessee, applying bright line test and holding thereafter that any expenditure in excess of bright line was for the promotion of the brand/trade name which was owned