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54 results for “transfer pricing”+ Section 92Cclear

Sorted by relevance

Mumbai409Delhi266Hyderabad56Kolkata54Bangalore49Chennai36Ahmedabad32Pune22Visakhapatnam11Jaipur10Indore8Dehradun6Surat4Cochin3Nagpur3Cuttack3Raipur2Amritsar2Panaji1Guwahati1Chandigarh1

Key Topics

Section 92C58Section 143(3)44Transfer Pricing40Addition to Income32Section 14A27Section 15425Section 144C(5)24Disallowance24Section 25022Section 115J

STAR PAPER MILLS LTD.,KOLKATA vs. D.C.I.T., CIRCLE - 4(1), KOLKATA, KOLKATA

In the result, appeal of the assessee is allowed

ITA 424/KOL/2022[2018-2019]Status: DisposedITAT Kolkata10 Jul 2023AY 2018-2019

Bench: Dr. Manish Borad, Hon’Ble & Shri Sonjoy Sarma, Hon’Blei.T.A. No. 424/Kol/2022 Assessment Year: 2018-19 Star Paper Mills Ltd. Dcit, Circle-4(1), Kolkata Duncan House Vs 31, N.S. Road Kolkata - 700001 [Pan : Aaecs0759B] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Akkal Dudhewala, Fca Revenue By : Shri G. Hukugha Sema, Cit D/R सुनवाई क" तारीख/Date Of Hearing : 13/04/2023 घोषणा क" तारीख /Date Of Pronouncement: 10/07/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Assistant Commissioner Of Income Tax, Circle- 4(1), Kolkata (Hereinafter The “Ld. Cit(A)”) Dt. 20/06/2022, Passed U/S 144C(13) Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2018-19 Which Is Arising Out Of The Directions Of The Dispute Resolution Panel -2, New Delhi (Hereinafter Referred To As The ‘Ld. Drp) U/S 144C(5) Of The Act Dt. 29/04/2022. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That On The Facts & In The Circumstances Of The Case & In Law, The Ao/Tpo In Complete Disregard Of The Binding Precedent In Assessee'S Own Case For 2

For Appellant: Shri Akkal Dudhewala, FCAFor Respondent: Shri G. Hukugha Sema, CIT D/R
Section 144C(13)Section 144C(5)Section 80

Showing 1–20 of 54 · Page 1 of 3

20
Section 80I18
Comparables/TP15
Section 92B

section 92C, the arm's length price in relation to an international transaction shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely: (a) comparable uncontrolled price method, by which,-- (i) the price charged or paid for property transferred

DCIT, KOL. , KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 286/KOL/2023[2019-20]Status: DisposedITAT Kolkata14 Dec 2023AY 2019-20

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.286/Kol/2023 Assessment Year: 2019-20 Dcit, Kolkata.................................................................................Appellant Vs. Rungta Mines Ltd.................................................……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata – 700017. [Pan: Aabcr6463N] Appearances By: Shri Raman Garg, Cit-Dr, Appeared On Behalf Of The Appellant. Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing :October 18, 2023 Date Of Pronouncing The Order : December 14, 2023 आदेश / Order संजय गग", "या"यकसद"य"वारा/ Per Sanjay Garg: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 20.01.2023 Of The Commissioner Of Income Tax (Appeals)-22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Revenue In This Appeal Has Taken The Following Grounds Of Appeal: “1. That On The Facts & Circumstances Of The Case, The Ld. Cit(A) Has Erred In Not Appreciating That Arm'S Length Price & Fair Market Value Are Two Different Concepts & The Role Of The Tpo Is Limited To Determination Of Arm'S Length Price

Section 250Section 80Section 80ISection 92BSection 92F

transfer of such goods or services is a specified domestic transaction referred to in section 92BA. 8.1 A perusal of the Explanation to Section 80IA(8) would reveal that in case of specified domestic transactions as referred to section 92BA of the Act, the market value will be the arm’s length price as in clause (ii) of section

DCIT CC-1(3),KOLKATA, KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 801/KOL/2023[2017-18]Status: DisposedITAT Kolkata15 Dec 2023AY 2017-18

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.801&802/Kol/2023 Assessment Years: 2017-18 & 2018-19 Dcit, Cc-1(3), Kolkata …….........................................................……Appellant Vs. Rungta Mines Ltd..........................................……........……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata- 700017. [Pan: Aabcr6463N] Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. Dutta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 20, 2023 Date Of Pronouncing The Order : December 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 31.05.2023 Of The Commissioner Of Income Tax (Appeals) – 22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Facts & Issues Involved In Both The Appeals Are Common & The Same Have Been Heard Together, Therefore, These Are Being Adjudicated By This Common Order. Ita No.801/Kol/2023 Is Taken As The Lead Case. 2. Ita No.801/Kol/2023 – The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 250Section 80Section 80ISection 92BSection 92F

transfer of such goods or services is a specified domestic transaction referred to in section 92BA. 8.1 A perusal of the Explanation to Section 80IA(8) would reveal that in case of specified domestic transactions as referred to section 92BA of the Act, the market value will be the arm’s length price as in clause (ii) of section

DCIT, CC-1(3), KOLKATA, KOLKATA vs. RUNGTA MINES LIMITED, KOLKATA

In the result, the appeal of the revenue stands dismissed

ITA 802/KOL/2023[2018-19]Status: DisposedITAT Kolkata15 Dec 2023AY 2018-19

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A Nos.801&802/Kol/2023 Assessment Years: 2017-18 & 2018-19 Dcit, Cc-1(3), Kolkata …….........................................................……Appellant Vs. Rungta Mines Ltd..........................................……........……...…..…..Respondent 8A, Express Tower, 42A, Shakespeare Sarani, Kolkata- 700017. [Pan: Aabcr6463N] Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. Dutta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 20, 2023 Date Of Pronouncing The Order : December 15, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 31.05.2023 Of The Commissioner Of Income Tax (Appeals) – 22, Kolkata (Hereinafter Referred To As The ‘Cit(A)’) Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Facts & Issues Involved In Both The Appeals Are Common & The Same Have Been Heard Together, Therefore, These Are Being Adjudicated By This Common Order. Ita No.801/Kol/2023 Is Taken As The Lead Case. 2. Ita No.801/Kol/2023 – The Assessee In This Appeal Has Taken The Following Grounds Of Appeal:

Section 250Section 80Section 80ISection 92BSection 92F

transfer of such goods or services is a specified domestic transaction referred to in section 92BA. 8.1 A perusal of the Explanation to Section 80IA(8) would reveal that in case of specified domestic transactions as referred to section 92BA of the Act, the market value will be the arm’s length price as in clause (ii) of section

ACIT, CC- 3(4), KOLKATA , KOLKATA vs. M/S. HIMATSINGKA SEIDE LIMITED , BANGALORE

In the result, appeal of the assessee in IT(SS)A No

ITA 785/KOL/2018[2008-09]Status: DisposedITAT Kolkata15 Mar 2024AY 2008-09

Bench: Shri Sanjay Garg & Shri Girish Agrawalit(Ss)A No.17/Kol/2018 Assessment Year: 2008-09 Himatsingka Seide Ltd. Deputy Commissioner Of 10/24, Kumara Krupa Road, High Vs. Income Tax, Central Circle- Grounds, Bangalore-560001. Xvi, Kolkata. (Pan: Aaach3507N) (Appellant) (Respondent) & It(Ss)A No.20/Kol/2018 Assessment Year: 2008-09 Assistant Commissioner Of Himatsingka Seide Ltd. Vs. Income-Tax, Central Circle-3(4), Kolkata. (Appellant) (Respondent) & Assessment Year: 2008-09 Assistant Commissioner Of Himatsingka Seide Ltd. Vs. Income-Tax, Central Circle-3(4), Kolkata. (Appellant) (Respondent)

For Appellant: Shri Nageswar Rao, Sr. AdvocateFor Respondent: Shri Abhijit Kundu, CIT, DR
Section 143(3)Section 14ASection 153ASection 271Section 92C

92C to the Transfer Pricing Officer. Further, sub-section (2) of section 92CA requires that Transfer Pricing Officer shall serve

M/S. TDK INDIA PRIVATE LIMITED (FORMERLY KNOWN AS EPCOS INDIA PRIVATE LIMITED),NADIA vs. DCIT, CIRCLE - 11(1) , KOLKATA

In the result appeal of the assessee for Assessment Year 2014-15 is partly allowed for statistical purposes and appeal of the assessee for Assessment Year 2015-16, is allowed

ITA 1998/KOL/2019[2015-16]Status: DisposedITAT Kolkata22 Aug 2023AY 2015-16

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 143(3)Section 144C(13)Section 92C

transfer pricing methodology, was without any basis and hence, was not sustainable. In the instant case, TPO was authorised to determine, by order in writing, the arm's length price of an international transaction in accordance with section 92C

M/S. TDK INDIA PRIVATE LIMITED (FORMERLY KNOWN AS EPCOS INDIA PRIVATE LIMITED),NADIA vs. DCIT, CIRCLE - 11(1) , KOLKATA

In the result appeal of the assessee for Assessment Year 2014-15 is partly allowed for statistical purposes and appeal of the assessee for Assessment Year 2015-16, is allowed

ITA 2646/KOL/2018[2014-15]Status: DisposedITAT Kolkata22 Aug 2023AY 2014-15

Bench: Dr. Manish Borad & Shri Sonjoy Sarma]

Section 143(3)Section 144C(13)Section 92C

transfer pricing methodology, was without any basis and hence, was not sustainable. In the instant case, TPO was authorised to determine, by order in writing, the arm's length price of an international transaction in accordance with section 92C

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

ITA 1501/KOL/2019[2012-13]Status: DisposedITAT Kolkata27 Apr 2023AY 2012-13

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R
Section 143(3)Section 14A

price of the international transaction at Nil value without applying any of the methods prescribed under sub-sections (1) and (2) of section 92C of the I.T. Act. The AO, in the instant case, had not disallowed the expenditure under section 37 of the I.T. Act but only adopted the ALP determined by the TPO in his order. We find

D.C.I.T,CIRCLE-9(1), KOLKATA vs. M/S APOLLO GLENEAGLES HOSPITAL, KOLKATA

In the result, appeal of the Revenue for AY 2012-13 is dismissed

ITA 1639/KOL/2019[2013-14]Status: DisposedITAT Kolkata27 Apr 2023AY 2013-14

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Ble

For Appellant: Ms. Vandana Bhandari, FCA and Shri SaibalFor Respondent: Shri G. Hukuga Sema, CIT, D/R
Section 143(3)Section 14A

price of the international transaction at Nil value without applying any of the methods prescribed under sub-sections (1) and (2) of section 92C of the I.T. Act. The AO, in the instant case, had not disallowed the expenditure under section 37 of the I.T. Act but only adopted the ALP determined by the TPO in his order. We find

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

ITA 1854/KOL/2016[2012-13]Status: DisposedITAT Kolkata13 Feb 2023AY 2012-13

Bench: Dr. Manish Borad & Sonjoy Sarma

Section 143(3)Section 14ASection 92B

Transfer Pricing Officer by his order dated October 28, 2016 again regarded the corporate guarantee as an international transaction and proposed an adjustment at the rate of 200 bps aggregating to Rs. 2,64,43,540/-. The order of the TPO was confirmed by the DRP by its order dated April 28, 2017 and the adjustment was adopted

M/S TATA GLOBAL BEVERAGES LIMITED,KOLKATA vs. THE DCIT, CIRCLE-4(2), KOLKATA, KOLKATA

In the result, the appeals filed by the assessee for AY 2012-

ITA 1899/KOL/2017[2013-14]Status: DisposedITAT Kolkata13 Feb 2023AY 2013-14

Bench: Dr. Manish Borad & Sonjoy Sarma

Section 143(3)Section 14ASection 92B

Transfer Pricing Officer by his order dated October 28, 2016 again regarded the corporate guarantee as an international transaction and proposed an adjustment at the rate of 200 bps aggregating to Rs. 2,64,43,540/-. The order of the TPO was confirmed by the DRP by its order dated April 28, 2017 and the adjustment was adopted

M/S. LINDE INDIA LIMITED (FORMERLY BOC INDIA LIMITED),KOLKATA vs. DCIT, CIRCLE 12(1), KOLKATA, KOLKATA

In the result, the appeal of the assessee bearing ITA No

ITA 381/KOL/2017[2012-13]Status: DisposedITAT Kolkata19 Feb 2024AY 2012-13

Bench: Dr. Manish Borad & Shri Anikesh Banerjee

Section 143(3)Section 144CSection 154Section 92CSection 92C(3)

Transfer Pricing Officer, without recording his objective satisfaction as prescribed under section 92CA and/or recording that any of the conditions prescribed in section 92C

M/S. PHILIPS INDIA LIMITED (SUCCESSOR TO ERSTWHILE PHILIPS SOFTWARE CENTRE PVT. LTD.),KOLKATA vs. D.C.I.T./A.C.I.T.(TRANSFER PRICING) - 2, KOLKATA, KOLKATA

In the result, appeal of the assessee in ITA No

ITA 33/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Blei.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/S. Philips India Limited Joint Commissioner Of Income-Tax 3Rd Floor, Tower A Vs (Transfer Pricing-Ii), Bangalore [Presently Deputy Dlf Park, 08 Block Af Commissioner/Assistant Major Arterial Road Commissioner Of Income-Tax New Town Transfer Pricing 2, Kolkata Kolkata - 700156 [Pan : Aabcp9487A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan K. Ved, A.R. Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 13/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Sanjay Garg: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”), Even Dt. 15/11/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2004-05. 2. The Sole Issue Raised In Both The Appeals Is Relating To The Maintainability Of The Appeals Before The Ld. Cit(A) Against The Rectification Orders Passed By The Transfer Pricing Officer (In Short “Tpo”) U/S 154 R.W. Sub-Section (5) To Section 92Ca Of The Act. The Ld. Cit(A) Vide Impugned Orders Has Dismissed The Appeals Of The Assessee Holding That As Per The Provisions Of Section 246A Of The Act, Order U/S 92Ca Or Its Rectification Order U/S 154 Of The Act Passed By The Tpo Is 2

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 154Section 246ASection 250Section 92C

92C to the Transfer Pricing Officer. ………………. (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him under sub- section

M/S. PHILIPS INDIA LIMITED (SUCCESSOR TO ERSTWHILE PHILIPS SOFTWARE CENTRE PVT. LTD.),KOLKATA vs. D.C.I.T./A.C.I.T. (TRANSFER PRICING) - 2, KOLKATA, KOLKATA

In the result, appeal of the assessee in ITA No

ITA 32/KOL/2023[2004-2005]Status: DisposedITAT Kolkata11 Jun 2024AY 2004-2005

Bench: Shri Sanjay Garg, Hon’Ble & Shri Girish Agrawal, Hon’Blei.T.A. No. 32 & 33/Kol/2023 Assessment Year: 2004-05 M/S. Philips India Limited Joint Commissioner Of Income-Tax 3Rd Floor, Tower A Vs (Transfer Pricing-Ii), Bangalore [Presently Deputy Dlf Park, 08 Block Af Commissioner/Assistant Major Arterial Road Commissioner Of Income-Tax New Town Transfer Pricing 2, Kolkata Kolkata - 700156 [Pan : Aabcp9487A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Ketan K. Ved, A.R. Revenue By : Shri Rakesh Kumar Das, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 13/03/2024 घोषणा क" तारीख /Date Of Pronouncement: 11/06/2024 आदेश/O R D E R Per Sanjay Garg: The Present Appeals Are Directed At The Instance Of The Assessee Against The Separate Orders Of The National Faceless Appeal Centre (Hereinafter The “Ld. Cit(A)”), Even Dt. 15/11/2022, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2004-05. 2. The Sole Issue Raised In Both The Appeals Is Relating To The Maintainability Of The Appeals Before The Ld. Cit(A) Against The Rectification Orders Passed By The Transfer Pricing Officer (In Short “Tpo”) U/S 154 R.W. Sub-Section (5) To Section 92Ca Of The Act. The Ld. Cit(A) Vide Impugned Orders Has Dismissed The Appeals Of The Assessee Holding That As Per The Provisions Of Section 246A Of The Act, Order U/S 92Ca Or Its Rectification Order U/S 154 Of The Act Passed By The Tpo Is 2

For Appellant: Shri Ketan K. Ved, A.RFor Respondent: Shri Rakesh Kumar Das, CIT, D/R
Section 154Section 246ASection 250Section 92C

92C to the Transfer Pricing Officer. ………………. (5) With a view to rectifying any mistake apparent from the record, the Transfer Pricing Officer may amend any order passed by him under sub- section

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

In the result, the appeal filed by the assessee is partly allowed

ITA 1875/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Dec 2025AY 2020-2021

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 143(3)Section 144Section 144C(5)Section 92BSection 92CSection 92C(3)

transfer pricing proceedings) are void-ab-Initio as the conditions of section 92C(3) of the Act have not been

DCIT, CIR-4(1), KOLKATA, KOLKATA vs. M/S MCLEOD RUSSEL INDIA LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2279/KOL/2019[2014-15]Status: DisposedITAT Kolkata07 Jul 2023AY 2014-15

Bench: Shri Rajpal Yadav, Vice- & Shri Rajesh Kumar

Section 92C

transfers of the tea leaves at the end of the year. It gives fluctuating results on quarterly basis, which is not a correct method for determining the income of any assessee. Therefore, we find merit in the order of the ld. CIT(Appeals) and this fold of contention of the Revenue taken up specifically in Ground No. 6 is rejected

M/S TDK INDIA LIMITED (FORMERLY KNOWN AS EPCOS INDIA PVT. LTD.),KOLKATA vs. DCIT, CIR. -11(1), KOLKATA

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

ITA 203/KOL/2021[2016-17]Status: DisposedITAT Kolkata22 Jan 2025AY 2016-17

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 144C(5)Section 92C

transfer pricing methodology, was without any basis and hence, was not sustainable. In the instant case, TPO was authorised to determine, by order in writing, the arm's length price of an international transaction in accordance with section 92C

DCIT, CIRCLE-6(1), KOLKATA vs. M/S. IFB AGRO INDUSTRIES LTD., KOLKATA

In the result, both the appeals filed by the revenue in ITA No

ITA 491/KOL/2019[2014-15]Status: DisposedITAT Kolkata09 Feb 2024AY 2014-15

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

transfer price of power for the eligible unit is reduced by Rs 2,26,20,150/-. 3.4. Accordingly, the assessee was asked to compute the profit of the eligible unit forthe deduction claimed u/s 80IA of the IT Act,1961.The assessee submitted the sametaking into account the sell price of the unit at Rs 3.23 per unit and the profitability

DCIT, CIRCLE-6(1), KOLKATA vs. M/S. IFB AGRO INDUSTRIES LTD., KOLKATA

In the result, both the appeals filed by the revenue in ITA No

ITA 490/KOL/2019[2013-14]Status: DisposedITAT Kolkata09 Feb 2024AY 2013-14

Bench: Dr. Manish Borad&Shri Anikesh Banerjee]

Section 143(3)Section 14ASection 250Section 80ISection 92C

transfer price of power for the eligible unit is reduced by Rs 2,26,20,150/-. 3.4. Accordingly, the assessee was asked to compute the profit of the eligible unit forthe deduction claimed u/s 80IA of the IT Act,1961.The assessee submitted the sametaking into account the sell price of the unit at Rs 3.23 per unit and the profitability

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

In the result, the appeal of the assessee is allowed

ITA 1960/KOL/2024[2020-2021]Status: DisposedITAT Kolkata11 Mar 2025AY 2020-2021

Bench: Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am M/S Philips India Limited Dcit, Circle 11(1) 3Rd Floor, Tower-A, Dlf Park, Aaykar Bhavan, P-7, 08 Block Af, Major Arterial Chowringhee Square, Road, New Town (Rajarhat), Vs. Kolkata-700069, Kolkata-700156, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aabcp9487A Assessee By : Shri Ketan Ved, Ar Revenue By : Shri A. Kundu, Cit Dr Date Of Hearing: 07.03.2025 Date Of Pronouncement : 11.03.2025

For Appellant: Shri Ketan Ved, ARFor Respondent: Shri A. Kundu, CIT DR
Section 92Section 92C

92C for PSC (G = E-F) 5,92,641 The AO computed 15.48% post Dispute Resolution Panel order by taking into account the following comparable companies:- Sr. Name of the company Appellant/ Transfer Margin (OP/OC) No. Pricing Officer comparable 1. Mindtree Ltd. TPO 12.66% 2. Great Software Laboratory Pvt. Ltd. TPO 15.48% 3. Sasken Technologies Ltd. TPO 17.20% 4. Sagarsoft