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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

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

section 37 at : INR 201,663 and Transfer Pricing adjustments of at INR 1,48,48,492 & INR 40,96

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

section 37 at : INR 201,663 and Transfer Pricing adjustments of at INR 1,48,48,492 & INR 40,96

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

section 37 at : INR 201,663 and Transfer Pricing adjustments of at INR 1,48,48,492 & INR 40,96

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

section 37 at : INR 201,663 and Transfer Pricing adjustments of at INR 1,48,48,492 & INR 40,96

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 46 of the Foreign Exchange Management Act, 1999 (42 of 1999) and in consultation with the Reserve Bank, the Central Government, having considered it necessary in the public interest, hereby makes the following further amendment in the Foreign Exchange Management (Current Account Transactions) Rules, 2000, namely: 1. (1) These rules may be called the Foreign Exchange Management (Current Account

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 46 of the Foreign Exchange Management Act, 1999 (42 of 1999) and in consultation with the Reserve Bank, the Central Government, having considered it necessary in the public interest, hereby makes the following further amendment in the Foreign Exchange Management (Current Account Transactions) Rules, 2000, namely: 1. (1) These rules may be called the Foreign Exchange Management (Current Account

DCIT, CHENNAI vs. POLARIS CONSULTING & SERVICES P LTD., CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

96,93,518/- was allocated to the subsidiary segment. 21. The Ld. Sr. counsel for the assessee further submitted that the Transfer Pricing Officer rejected the benchmarking done by the assessee in the transfer pricing documentation. The TPO accepted Transaction Net Margin Method as most appropriate method in benchmarking the international transaction. However, the TPO 13 I.T.A. No.1218, 765 & 615/Mds/16

POLARIS SOFTWARE LAB LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

96,93,518/- was allocated to the subsidiary segment. 21. The Ld. Sr. counsel for the assessee further submitted that the Transfer Pricing Officer rejected the benchmarking done by the assessee in the transfer pricing documentation. The TPO accepted Transaction Net Margin Method as most appropriate method in benchmarking the international transaction. However, the TPO 13 I.T.A. No.1218, 765 & 615/Mds/16

POLARIS CONSULTING & SERVICES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

96,93,518/- was allocated to the subsidiary segment. 21. The Ld. Sr. counsel for the assessee further submitted that the Transfer Pricing Officer rejected the benchmarking done by the assessee in the transfer pricing documentation. The TPO accepted Transaction Net Margin Method as most appropriate method in benchmarking the international transaction. However, the TPO 13 I.T.A. No.1218, 765 & 615/Mds/16

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

Transfer Pricing order u/s.92CA(3) of the Act for the AY 2013-14 was completed after the conclusion of the search, wherein the TPO proposed TP downward adjustment of Rs.407.25 crores on the imports from MIPP. The TPO did not propose any adjustment on the receipt of share capital reported in the Form 3CEB. The assessee had filed appeal against

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

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