DCIT, CIRCLE - 8(1), KOLKATA, KOLKATA vs. M/S. EIH LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

Bench: Shri P.M. Jagtap, Vice-(Kz) & Shri Satbeer Singh Godara

68,77,800/- being 2% of the value of international transactions of the assessee-company with its Associated Enterprises. 3. The penalty imposed by the Assessing Officer under section 271AA was challenged by the assessee in the appeal filed before the ld. CIT(Appeals) and after considering the submissions made on behalf of the assessee-company

DCIT, CIRCLE - 10, KOLKATA, KOLKATA vs. M/S. DIC INDIA LTD., KOLKATA

In the result, both appeals of Revenue stand dismissed

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

68,1514.00. With regard to the trading function, the TPO noted that while in case of purchases made from unrelated parties for making sales to unrelated parties, the gross level margin on sales was 23%. This he considered as the arm's length margin for trading activity in uncontrolled circumstances and selected the RPM as the most appropriate method

DCIT, CIRCLE - 10, KOLKATA, KOLKATA vs. D I C INDIA LTD., KOLKATA

In the result, both appeals of Revenue stand dismissed

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

68,1514.00. With regard to the trading function, the TPO noted that while in case of purchases made from unrelated parties for making sales to unrelated parties, the gross level margin on sales was 23%. This he considered as the arm's length margin for trading activity in uncontrolled circumstances and selected the RPM as the most appropriate method

N L C NALCO INDIA LTD PREVIOUSLY KNOWN AS ONDEO NALCO INDIA LTD.,KOLKATA vs. ACIT, CIR - 11, KOLKATA, KOLKATA

In the result, the appeal of assessee in ITA No

Bench: Shri Mahavir Singh, Jm& Shri Waseem Ahmed, Am]

68,90,427/- was written off through provision account and an amount of Rs.36,34,283/- was directly written off in the Profit and Loss Account for the relevant previous year relevant to this assessment year. It is a fact that assessee is engaged in the manufacture of various types of chemicals which are used inter alia in steel, paper

NLC NALCO INDIA LTD.,KOLKATA vs. ACIT, CIRCLE - 11, KOLKATA, KOLKATA

In the result, the appeal of assessee in ITA No

Bench: Shri Mahavir Singh, Jm& Shri Waseem Ahmed, Am]

68,90,427/- was written off through provision account and an amount of Rs.36,34,283/- was directly written off in the Profit and Loss Account for the relevant previous year relevant to this assessment year. It is a fact that assessee is engaged in the manufacture of various types of chemicals which are used inter alia in steel, paper

M/S. TEGA INDUSTRIES LIMITED,KOLKATA vs. D.C.I.T., CIRCLE-11(1), KOLKATA, KOLKATA

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

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Ble

68,548/- and addition of Rs.13,63,534/- towards corporate guarantee to Tega Chile. 7. Before us, the ld. Counsel for the assessee had made two fold contentions. Firstly, contending that the alleged transactions do not fall under the category of international transactions and, therefore, no TP adjustment was needed. Secondly, taking an alternative plea it is stated that even

DCIT, CIR-11(1), KOLKATA, KOLKATA vs. M/S. EPCOS INDIA PVT. LTD., KOLKATA

Appeal of the revenue is dismissed

Bench: Sri J. Sudhakar Reddy & Sri Aby T. Varkey) Assessment Year: 2005-06 Deputy Commissioner Of Income Tax, Circle-11(1), Kolkata……..........….…..........…........Appellant Vs. M/S. Epcos India Pvt. Ltd............................………………..................................……………..........Respondent Kulia Kanchrapara Road Kalyani, Nadia Pin – 741 251 [Pan : Aaace 4000 H] Appearances By: Shri Sanjay Paul, Addl. Cit D/R & Shri Supriyo Pal, Jcit, Sr. D/R, Appearing On Behalf Of The Revenue. Smt. Rituparna Sinha, Fca & S.C. Giri C.A., Appeared On Behalf Of The Assessee. Date Of Concluding The Hearing : January 15Th, 2020 Date Of Pronouncing The Order : July 10Th, 2020 Order Per J. Sudhakar Reddy, Am :-

92D of the Income-tax Act, 1961, read with rule 10D of the Income-tax Rules, 1962 which is filed with the Ld. TPO during the course of proceedings under section 92CA(3) of the Income-tax Act, 1961.  It is stated in paragraph no. 9 that the assessee has not purchased the same raw materials / components

M/S. PHILIPS INDIA LIMITED (FORMERLY PHILIPS ELECTRONICS INDIA LITD.),KOLKATA vs. ACIT, CIRCLE - 12(2), KOLKATA , KOLKATA

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

Bench: Hon’Ble Shri A.T.Varkey, Jm & Hon’Ble Shri M.Balaganesh, Am ] I.T.A No. 2489/Kol/2017 Assessment Year : 2013-14 M/S Philips India Ltd. -Vs- Acit, Circle-12(2), Kolkata (Formerly Philips Electronics India Ltd.) [Pan: Aabcp 9487 A] (Appellant) (Respondent)

92D read with Rule 10D of the Act. 7.2. The assessee submitted the details of AMP expenditure for the financial year 2012-13 as under:- Media Spend Agency Fees Lighting 22,59,34,147 14,61,97,113 Consumer lifestyle 31,74,94,505 5,23,20,770 Health care 67,85,293 96,76,586 Corporate

DCIT, CIR-12(2), KOLKATA, KOLKATA vs. M/S PHILIPS INDIA LTD., KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

section 32 of the Act read with Rule 5 of the Rules, depreciation @ 30% would be available if the following conditions are satisfied: i) Moulds are owned by the assessee; ii) Moulds re used for the purpose of assessee’s business; and iii) Moulds are exclusively used in the rubber / plastic factory (b) In the instant case, moulds were

M/S PHILIPS INDIA LTD.,KOLKATA vs. DCIT, CIR-12(2), KOLKATA, KOLKATA

Bench: Shri N.V.Vasudevan & Shri Waseem Ahmed

section 32 of the Act read with Rule 5 of the Rules, depreciation @ 30% would be available if the following conditions are satisfied: i) Moulds are owned by the assessee; ii) Moulds re used for the purpose of assessee’s business; and iii) Moulds are exclusively used in the rubber / plastic factory (b) In the instant case, moulds were