ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

transfer pricing issues for the A.Y 2005-06 and 2008-09 stands disposed off and allowed for statistical purposes. 6.0 Ground No.9 of the assess’s appeal for the A.Y 2005-06 is on obsolete stock: The AO proposed for addition of Rs.2,21,08,585/- on account of provisions made by the assessee for obsolete stocks. The assessee filed

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

transfer pricing issues for the A.Y 2005-06 and 2008-09 stands disposed off and allowed for statistical purposes. 6.0 Ground No.9 of the assess’s appeal for the A.Y 2005-06 is on obsolete stock: The AO proposed for addition of Rs.2,21,08,585/- on account of provisions made by the assessee for obsolete stocks. The assessee filed

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

INTERNATIONAL FLAVOURS & FRAGRANCES INDIA PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHENNAI

In the result, the appeal filed by the assessee is allowed

108 (Bonn), wherein the Hon'ble High Court of Bombay in para 13 (refer para 13 in page no. 37 of case law paper book on jurisdictional grounds) held that 13. “We, therefore, hold that in order to exercise power under sub-section (1) of section 263 there must be material before the Commissioner to consider that the order passed

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

price. A pair of shoes consist of two major parts (i) upper and (ii) sole. These parts are manufactured by both the units and then the finished goods are delivered to NIKE. The detailed production process was submitted before the lower authorities (Page 141 of paperbook). 12. It is submitted that LU1 was manufacturing various shoe models and was operating

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

In the result, the appeal of the assessee is allowed

108. We have perused the terms of the BTA and observe that the net consideration of Rs.110,03,66,310/- was mutually agreed upon between the assessee and the transferee company on the basis of revaluation of the assets and liabilities. As evident from Annexure–l to the BTA, the aggregate value of assets transferred, including stock-in-trade

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

price whichever is lower. The appellant contended that the stand of the AO is not correct also the statement recorded during the survey has no evidentiary value. The appellant also submitted that this component of stock difference does not represent the value of any excess quantity of stock found during the course of survey in relation to the stock register

DCIT CORPORATE CIRCLE 3(2), CHENNAI vs. VERIZON DATA SERVICES PVT. LTD., CHENNAI

In the result, the appeal of the Revenue is allowed

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.3090/Chny/2017 ("नधा"रण वष" / Assessment Year: 2013-14) Vs M/S. Verizon Data Services Pvt. The Deputy Commissioner Of Income Tax, Ltd., 9Th Floor, Altius Block, Corporate Circle -3(2), Chennai – 34. Olympia Tech Park, Plot No.1, Sidco Industrial, Guindy, Chennai – 600 032. Pan: Aabcv 1758N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri M. Srinivasa Rao, Cit ""यथ" क" ओर से/Respondent By : Shri Sriram Seshadhri, Ca

transfer pricing adjustment on account of the delayed realization of invoices from AEs has been upheld. The ld. DR contended that the order in the case of Kusum Healthcare Pvt. Ltd. (supra), has been passed without considering the amendment to section 92B carried out by the Finance Act, 2012 with retrospective effect from 1.4.2002, which has been duly taken into

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

Transfer Pricing Officer's order u/s 92CA(3). The ld. AR argued that the 5% of the price variation as mentioned in the CBDT’s circular No.12/2001 dated 23.08.2001, is to be applied for the wholesome transactions with the Associated Enterprise (AE) and not on each transaction with the AE. The Id.AR has further contended that the TPO ought