M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

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

193 Taxman 97) has observed that the issue can be decided after the expert’s opinion on the point whether any human intervention is required for providing interconnected roaming services by other cellular operators. The relevant observations of the Hon’ble Supreme Court in para.7 to 10 are as under: “7. The problem which arises in these cases is that

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE DCIT (TDS), INDORE

Appeals are allowed

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

193 Taxman 97) has observed that the issue can be decided after the expert’s opinion on the point whether any human intervention is required for providing interconnected roaming services by other cellular operators. The relevant observations of the Hon’ble Supreme Court in para.7 to 10 are as under: “7. The problem which arises in these cases is that

M/S. BHATIA GLOBAL TRADING LTD.,INDORE vs. THE DCIT 1(1), INDORE

In the result, appeal of assessee is partly allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanibhatia Global Trading Ltd. Dcit 1(1) Through Official Liquidator Indore Old Cia Building, 1St Floor Vs. Opp. G.P.O. Residency Area, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aaacb6751 C Assessee By None Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 10.05.2023 Date Of Pronouncement 26 .07.2023

transfer pricing regulations 5. The TPO rejected the TP Study analysis of the assesse and carried out his own search for selecting comparable for determination of arm’s length price. The TPO selected three comparable companies for determination of arm’s length price against which the assessee has raised objection before the DRP which are reproduced

M/S. IDEA CELLULAR LIMITED,INDORE vs. THE CIT (TDS), BHOPAL

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

193 Taxman 97) has observed that the issue can be decided after the expert’s opinion on the point whether any human intervention is required for providing interconnected roaming services by other cellular operators. The relevant observations of the Hon’ble Supreme Court in para.7 to 10 are as under: “7. The problem which arises in these cases is that

IDEA CELLULAR LIMITED,INDORE vs. DCIT TDS, INDORE

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanim/S Vodafone Idea Ltd. Cit (Tds), बनाम/ (Formerly M/S Idea Bhopal Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent) M/S Vodafone Idea Ltd. Dcit/Jcit (Tds), बनाम/ (Formerly M/S Idea Indore Vs. Cellular Ltd.), 139-140, Electronics Complex, Pardeshipura, Indore (Assessee/Appellant) (Revenue/Respondent)

193 Taxman 97) has observed that the issue can be decided after the expert’s opinion on the point whether any human intervention is required for providing interconnected roaming services by other cellular operators. The relevant observations of the Hon’ble Supreme Court in para.7 to 10 are as under: “7. The problem which arises in these cases is that

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 5 1, BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

MAPAEX REMEDIES PVT LTD ,BHOPAL vs. THE DCIT -2- (1), BHOPAL , BHOPAL

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

MS MAPAEX REMEDIES PVT LTD,BHOPAL vs. ACIT 2 (1) BHOPAL, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -5(1), BHOPAL , BHOPAL, MADHYA PRADESH vs. MAPAEX REMEDIES PVT. LTD., BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE - 5(1), BHOPAL , BHOPAL MADHYA PRADESH vs. MAPAEX REMEDIES PVT LTD, BHOPAL MADHYA PRADESH

Appeals are dismissed

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

price. P&G has constructed factory building on land and also installed plant and machinery. The plant and machinery does not belong to assessee but to P&G. Reimbursement of expenses is also made by P&G. The assessee is working for P&G, not for anybody else. These factors clearly show that the assessee is just an operator

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT ( EXEMPTION CIRCLE) , BHOPAL

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL, MADHYA PRADESH vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

DEPUTY COMMISSIONER OF INCOME TAX(EXEMPTION), BHOPAL, BHOPAL vs. INDORE DEVELOPMENT AUTHORITY, INDORE

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting

INDORE DEVELOPMENT AUTHORITY ,INDORE vs. DCIT (EXEMPTION CIRCLE), BHOPAL

Appeals are allowed and revenue’s appeals

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

193 ITR 321 (SC). 11. Ld. counsel for the assessee also requested for admission of additional evidences under Rule 29 read with Rule 18(4) of the Appellate Tribunal Rules,1963 filed in support of the claim that the expenditure incurred under the City Environmental Development and Preservation Expenses are revenue in nature. The prayer made by the assessee requesting