COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Transfer Pricing Regulations talk of individual transactions to be benchmarked. He submitted that the assessee made claim of ‘entity-level’ comparison before DRP also, but the DRP has over-ruled assessee’s claim with reasoning. Referring to Page 10 and 11 of DRP order, Ld. DR emphasized the reasoning given by DRP, Page 19 of 47 Computer Sciences Corporation India

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

justice. With due respect it is submitted that such an action ought to be held as fatal not only to the additions made but also fatal to the entire proceedings. It is submitted that the appellant has not been provided the copy of the said information and the relevant material even after the completion of reassessment proceedings

THE ACIT, CENTRAL-1, INDORE vs. M/S. MANISH AGRO TECH PVT. LTD., INDORE

In the result grounds of revenue for A

Bench: Shri Chandra Mohan Garg & Shri Bhagirath Mal Biyani

justice. With due respect it is submitted that such an action ought to be held as fatal not only to the additions made but also fatal to the entire proceedings. It is submitted that the appellant has not been provided the copy of the said information and the relevant material even after the completion of reassessment proceedings

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. THE ACIT-CIRCLE 2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

M/S. COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,INDORE vs. THE ASST. COMMISSIONER OF INCOME TAX-2(1), INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

Transfer Pricing Officer has followed the well searched formula and the data that simple year should have been taken into account. The Ld. DR submitted that the TPO has taken cognisance of the depreciation adjustment and relied upon the order of the TPO and the Assessing Officer. 11. We have heard both the parties and perused all the relevant material

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

ACIT(CENTRAL)-1, INDORE vs. SHRI PUNIT AGRAWAL, MHOW

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shrib.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made

THE ACIT, (CENTRAL)-1, INDORE vs. M/S. PRAKASH ASHPHLTING & TOLL HIGHWAY LTD., INDORE

Appeals are dismissed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

transferred from one side to another, addition under section 69C were not sustainable. Hon'ble Supreme Court in the case of Pr. CIT Vs. Vinita Chaurasia [2018] 98 Taxman.com 468 (SC) arising out of Order of HC in CIT Vs.VinitaChaurasia [2017] 82 Taxmann.com 153 dismissed the departmental SLP and affirm the very principle again that when a addition was made