ORCHID CHEMICALS AND PHARMACEUTICALS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal is allowed in the terms indicated above

transfer pricing issue have been made in the case of those Indian pharmaceutical companies and then dropped. The issue has not at all been examined by the Department in their cases. Apparently the transactions of such pharmaceutical companies with the North Star have not been reported by them as an international transaction in the report in Form 3 CEB under

K.P.R.MILL LIMITED ,CHENNAI vs. ACIT CORPORATE CIRCLE 2 , COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.1915/Mds/2017 "नधा"रण वष" / Assessment Year : 2013-14

Transfer Pricing Officer drastically reduced the tax incentive provided for captive power plant omitting to consider the auditor’s report filed under Section 92E

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

price of the equipment purchased are at arm's length in accordance with Section 92E of the Act. The appellant filed the return of income for the AY 2010-11 to AY 2015-16 declaring total income as under:\nAsst Year Date of filing Returned Income/(Loss) Book profits u/s.\nof ROI under 115JB of the Act\nnormal\nprovisions\n2010

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 and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction, the TPO, inter alia, observed as follows: Section 92B of the Income

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 and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction, the TPO, inter alia, observed as follows: Section 92B of the Income

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 and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction, the TPO, inter alia, observed as follows: Section 92B of the Income

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 and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction, the TPO, inter alia, observed as follows: Section 92B of the Income

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 and that income from an international transaction, as is the mandate of section 92, is to be computed having regard to arm’s length price. As regards the contention of the assessee that ‘brand building’, even if that be so, is not an international transaction, the TPO, inter alia, observed as follows: Section 92B of the Income

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

price of the equipment purchased are at arm's length in accordance with Section 92E of the Act. The appellant filed the return of income for the AY 2010-11 to AY 2015-16 declaring total income as under:\nAsst Year\nDate of filing\nReturned\nIncome/(Loss)\nBook\nprofits u/s.\n115JB of the Act\nof ROI\nunder\nnormal\nprovisions\n2010

INDIA PISTONS LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE-2(3), CHENNAI

In the result, the appeals of the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos.2207 & 2208/Chny/2017 "नधा"रण वष" /Assessment Years : 2004-05 & 2004-05. M/S.India Pistons Ltd, Vs. The Assistant Commissioner Arjay Apex Centre, Of Income Tax, No.24, College Road, Corporate Circle 2(3) Chennai 600 026. Chennai 600 034. [Pan Aaaci 1439E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing study and therefore it was not required to maintain and produce data regarding comparables. Form 3CEB which is the audit report prescribed under Section 92E

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED(ERSTWHILE EXCELLENCE DATA RESEARCH PRIVATE LIMITED),CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-17(1), HYDERABAD

In the result, appeal of the assessee is partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.13/Hyd/2018 िनधा"रण वष"/Assessment Year: 2013-14 V. M/S. Cognizant Technology- The Acit, Solutions India Pvt. Ltd., Circle-17(1), 9Th Floor, (As Successor In Interest Of Erstwhile Excellence Data Signature Towers, Opp: Botanical Garden, Research Pvt. Ltd.), 6Th Floor, New No.165, Old No.110, Kondapur, Hyderabad. Menon Eternity Building, St. Mary’S Road,Alwarpet, Chennai-600 018. [Pan: Aabce 4933 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 92E, assessee furnished report in Form 3CED, wherein, it adopted Transactional Net Margin Method (TNMM) with a PLI of OP/OC with a margin of 23.23%. And the assessee has selected 9 comparables with a weighted average operating margin of comparable companies at 12.21%. 4. Since there was international transactions, AO made reference to Transfer Pricing

INLOGIC TECHNOLOGIES PRIVATE LIMITED,CHENNAI vs. DCIT CORP. CIRCLE 1(1) , CHENNAI

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

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 3323/Chny/2024 िनधा"रण वष" / Assessment Year: 2021-22

Section 92A(2)(j). However, Mr. Vinogopal Ramayah resigned from his position at Medtech Global Ltd on June 1, 2020. Hence, after June 1, 2020, Medtech Global Ltd was no longer an AE of Inlogic Technologies. 5. During the FY 2020-21, the assessee has provided software development services to Medtech Global Ltd, Australia amounting to Rs.10.95 Crores. However

FAIVELEY TRANSPORT TECHNOLOGIES INDIA PVT. LTD.,HOSUR vs. ACIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

92E 6. The Company filed the ITR and all the applicable audit reports before the due date and the same was correctly disclosed in the ITR. Please find attached the relevant pages of the ITR -6 form for your reference. (Annexure 5) 7. Therefore, it is eligible to claim the deduction of Rs.43,89,60,086 u/s 80-IC since

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

transferred to professional fee account on completion of service. The assessee further submitted that the advance is a very small amount as compared to the aggregate professional fees. Apart from the above, alternatively the Id. AR submitted that the advance received during the assessment year under consideration was only 2,79,161/- which may be added to the income

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

transferred to professional fee account on completion of service. The assessee further submitted that the advance is a very small amount as compared to the aggregate professional fees. Apart from the above, alternatively the Id. AR submitted that the advance received during the assessment year under consideration was only 2,79,161/- which may be added to the income

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

transferred to professional fee account on completion of service. The assessee further submitted that the advance is a very small amount as compared to the aggregate professional fees. Apart from the above, alternatively the Id. AR submitted that the advance received during the assessment year under consideration was only 2,79,161/- which may be added to the income