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., 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

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

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

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer III, Chennai(TPO) u/s 92CA(1) of the Act for determining the Arm's Length Price. By his order dated 16.03.2006 u/s 92CA(3) the TPO fixed the Arm's Length Price as Rs.243.45 Crores (Correct amount Rs.239.54 Crores), as against the value of sales admitted by the appellant as Rs.206.91 Crores, and the short fall

ACIT, CHENNAI vs. M/S. MASCON GLOBAL LTD., CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer III, Chennai(TPO) u/s 92CA(1) of the Act for determining the Arm's Length Price. By his order dated 16.03.2006 u/s 92CA(3) the TPO fixed the Arm's Length Price as Rs.243.45 Crores (Correct amount Rs.239.54 Crores), as against the value of sales admitted by the appellant as Rs.206.91 Crores, and the short fall

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer III, Chennai(TPO) u/s 92CA(1) of the Act for determining the Arm's Length Price. By his order dated 16.03.2006 u/s 92CA(3) the TPO fixed the Arm's Length Price as Rs.243.45 Crores (Correct amount Rs.239.54 Crores), as against the value of sales admitted by the appellant as Rs.206.91 Crores, and the short fall

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

Transfer Pricing Officer III, Chennai(TPO) u/s 92CA(1) of the Act for determining the Arm's Length Price. By his order dated 16.03.2006 u/s 92CA(3) the TPO fixed the Arm's Length Price as Rs.243.45 Crores (Correct amount Rs.239.54 Crores), as against the value of sales admitted by the appellant as Rs.206.91 Crores, and the short fall

COOK INDIA MEDICAL DEVICES PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

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

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita No.3137/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14

transfer pricing adjustment amounting to Rs.1,05,28,594/-. 4.1. The Ld. AO/TPO/ DRP have erred, in law and in facts, by rejecting the foreign AEs as the tested party and selecting the Appellant as the tested party. 4.2. The Ld. AO/TPO/DRP has erred, in laws and facts, by rejecting transaction net margin method as the most appropriate method

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

63,29,522. On a reference to the Transfer Pricing Officer (‘TPO”), the TPO found ,inter alia , that the assessee entered into international transactions with its Associated Enterprises (“AE”) M/s Daleworld Limited, Cyprus by way of subscribing to the OFCDs issued by Daleworld Limited, Cyprus at the rate of 2 percent interest per annum and with an option to convert

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

63,29,522. On a reference to the Transfer Pricing Officer (‘TPO”), the TPO found ,inter alia , that the assessee entered into international transactions with its Associated Enterprises (“AE”) M/s Daleworld Limited, Cyprus by way of subscribing to the OFCDs issued by Daleworld Limited, Cyprus at the rate of 2 percent interest per annum and with an option to convert

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

63,29,522. On a reference to the Transfer Pricing Officer (‘TPO”), the TPO found ,inter alia , that the assessee entered into international transactions with its Associated Enterprises (“AE”) M/s Daleworld Limited, Cyprus by way of subscribing to the OFCDs issued by Daleworld Limited, Cyprus at the rate of 2 percent interest per annum and with an option to convert

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

63,29,522. On a reference to the Transfer Pricing Officer (‘TPO”), the TPO found ,inter alia , that the assessee entered into international transactions with its Associated Enterprises (“AE”) M/s Daleworld Limited, Cyprus by way of subscribing to the OFCDs issued by Daleworld Limited, Cyprus at the rate of 2 percent interest per annum and with an option to convert

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section) and for those in which the farm is supplied concrete from a factory. Construction Operations: Erecting wind turbines requires the efforts of many skilled construction workers. The work begins before the turbine components arrive on site: construction laborers and construction equipment operators are responsible for building local access roads and the foundations that support the turbines. Based

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section) and for those in which the farm is supplied concrete from a factory. Construction Operations: Erecting wind turbines requires the efforts of many skilled construction workers. The work begins before the turbine components arrive on site: construction laborers and construction equipment operators are responsible for building local access roads and the foundations that support the turbines. Based

PANASONIC CORPORATION,HARYANA vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Transfer Pricing Officer as provided under Section 92CA(4) of the Act. 21. Now, coming to merit of the appeal, the Assessing Officer disallowed the claim of the assessee only on the ground that the assessee received assessee fee for technical service. The Assessing Officer and DRP also found that the technical knowledge 13 I.T.A. No.1483/Chny/17 was made available

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPUR vs. SRI SHANMUGAVEL MILLS PRIVATE LIMITED, TIRUPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

price at which TNEB supplies electricity to its end consumers and asserted thus that the transfer of electricity from the captive windmills to the textile division of the assessee company has been at arm’s length. However, the TPO carried out FAR analysis of the assessee & the TNEB, and rejected the Sri Shanmugavel Mills Pvt. Ltd :: 3 :: method