BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, DDIT/ADIT (INTERNATIONAL TAXATION), CIRCLE -1, DEHRADUN

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

transfer pricing documentation by applying the Transactional Net Margin Method (‘TNMM’). Since the profit margin of the assessee at 33.95% was higher than the median margin of 10.16% earned by the comparable companies, the transaction was considered to be at arm’s length. The TPO, however, relying upon the orders for the earlier years, rejected the TNMM method applied

BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17

transfer pricing adjustment of interest payment on loan. 8. We have heard ld. Sr. Counsel as well as ld. DR and carefully perused the orders of the authorities below on this issue as well asthe decision of this Tribunal in assessee’s own case for the preceding assessment years. At the outset we note that this Tribunal for the assessment

KARAM SAFETY PRIVATE LIMITED,SITARGANJ vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

pricing addition of Rs. 78.97 crores; (ii) Secondly, under the approved scheme of amalgamation, the transferee has assumed the liabilities of the transferor company, including tax liabilities; (iii) Thirdly, the consequence of the scheme of amalgamation approved under Section 394 of the Companies Act 1956 is that the amalgamating company ceased to exist. In Saraswati Industrial Syndicate Ltd., the principle

KARAM SAFETY PRIVATE LIMITED,UDHAM SINGH NAGAR vs. THE INCOME TAX OFFICER, WARD-2(3)(5), UDHAM SINGH NAGAR

In the result, both the appeals of the assessee are allowed and that of the Stay Applications are dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

pricing addition of Rs. 78.97 crores; (ii) Secondly, under the approved scheme of amalgamation, the transferee has assumed the liabilities of the transferor company, including tax liabilities; (iii) Thirdly, the consequence of the scheme of amalgamation approved under Section 394 of the Companies Act 1956 is that the amalgamating company ceased to exist. In Saraswati Industrial Syndicate Ltd., the principle

WEATHERFORD OIL TOOLS M.E. LTD.,NOIDA vs. DCIT, CIRCLE- 2, INTERNATIONAL TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS ME LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS M E LTD.,DEHRADUN vs. DCIT, CIRCLE- 2, INTL. TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

WEATHERFORD OIL TOOLS ME LTD.,DEHRADUN vs. ACIT, CIRCLE- II, INTERNATIONAL TAXATION, DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services

ACIT, CIRCLE- II, INTERNATIONAL TAXATION , DEHRADUN vs. WEATHERFORD OIL TOOLS M.E. LTD., DEHRADUN

Bench: Sh. Satbeer Singh Godara & Sh. M. Balaganesh

transfer pricing regulations. Ground No. 4 That Ld CIT(A) erred in law and on facts by failing to appreciate that the functional profile of the Appellants PE is even below a low risk distributor and that the Appellants PE does not assume title of the goods sold in India and merely provides low end coordination support services