JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEEL LIMITED,MUMBAI vs. ACIT,CC-46, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

144C(3) r.w.s 153A r.w.s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') on 30.05.2014 is barred by limitation under the provisions of the Act, and the same is void ab initio” 2. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that

LINTAS INDIA P.LTD,MUMBAI vs. ASST CIT CIR 3(2)(1), MUMBAI

The appeal is allowed with the same directions

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Acit Cir 3(2)(1) Lintas India Private Limited It Office, R.No. 608, 6 Th 15Th Floor, Express Towers, Floor, Aayakar Bhavan, Nariman Point, Vs. M.K. Road, Mumbai-400021 Mumbai-400020 (Appellant) (Respondent) Pan No. Aaacl0124F Lintas India Private Addl/Joint/Deputy/Acit/Income- Limited 15Th Floor, Express Tax Officer, National Faceless Vs. Towers, Nariman Point, Appeal Centre, Delhi Mumbai-400 021 (Appellant) (Respondent) Pan No. Aaacl0124F Assessee By : Shri Ajit Jain & Siddhesh Chaugule Revenue By : Dr. Yogesh Kamat, Cit Dr Date Of Hearing: 13.09.2022 Date Of Pronouncement: 09/12/2022

Section 144C (5) of the Act on 11thSeptember 2018. The ground no.1 with respect to the adjustment on account of payment of intra group services, the learned Dispute Resolution Panel followed its own direction in assessee‟s case for A.Y. 2012-13 and 2013-14 and upheld the adjustment proposed by the learned Transfer Pricing Officer. With respect

LINTAS INDIA PRIVATE LIMITED,MUMBAI vs. NFAC, DELHI , DELHI

The appeal is allowed with the same directions

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Acit Cir 3(2)(1) Lintas India Private Limited It Office, R.No. 608, 6 Th 15Th Floor, Express Towers, Floor, Aayakar Bhavan, Nariman Point, Vs. M.K. Road, Mumbai-400021 Mumbai-400020 (Appellant) (Respondent) Pan No. Aaacl0124F Lintas India Private Addl/Joint/Deputy/Acit/Income- Limited 15Th Floor, Express Tax Officer, National Faceless Vs. Towers, Nariman Point, Appeal Centre, Delhi Mumbai-400 021 (Appellant) (Respondent) Pan No. Aaacl0124F Assessee By : Shri Ajit Jain & Siddhesh Chaugule Revenue By : Dr. Yogesh Kamat, Cit Dr Date Of Hearing: 13.09.2022 Date Of Pronouncement: 09/12/2022

Section 144C (5) of the Act on 11thSeptember 2018. The ground no.1 with respect to the adjustment on account of payment of intra group services, the learned Dispute Resolution Panel followed its own direction in assessee‟s case for A.Y. 2012-13 and 2013-14 and upheld the adjustment proposed by the learned Transfer Pricing Officer. With respect

VIDEOCON INDUSTRIES LTD,MUMBAI vs. DCIT RG 3(3)(2), MUMBAI

In the result assessee’s appeal is partly allowed

Bench: Shri R.C. Sharma & Shri Amit Shuklaassessment Year: 2011-12

3) r.w.s. 144C(13) in pursuance of direction given by the Dispute Resolution Panel (DRP) under section 144C(5) vide order dated 23.12.15. In various grounds of appeal, the assessee has raised following issues: i) Transfer pricing adjustment of Rs.46,94,26,016/- in respect of ‘Guarantee Commission’ and ‘Fee for Letter of Undertaking’ (Ground No.1.1 to 1.4). ii) Disallowance

ACIT -3(4) , MUMBAI vs. RELIANCE INDUSTRIES LTD, MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

144C (3) of the Act disallowed the claim of depreciation to the extent of Rs. 3,28,689. In appeal, learned CIT(A) vide impugned order confirmed the addition made by the AO following the earlier year’s decision. Being aggrieved, the assessee is in appeal before us. Reliance Industries Ltd. ITA No.579/Mum./2021 ITA No.1438/Mum./2021 14. We find

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ASSTT. CIT-CC-3(4), MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar, Vice Preside & Shri Sandeep Singh Karhail

144C (3) of the Act disallowed the claim of depreciation to the extent of Rs. 3,28,689. In appeal, learned CIT(A) vide impugned order confirmed the addition made by the AO following the earlier year’s decision. Being aggrieved, the assessee is in appeal before us. Reliance Industries Ltd. ITA No.579/Mum./2021 ITA No.1438/Mum./2021 14. We find

DCIT, CIR-14(1)(2), MUMBAI vs. M/S. EKTA EVEGLADE HOMES PVT LTD.,, MUMBAI

In the result, the ground raised by the revenue is allowed

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SMT. RENU JAUHRI (Accountant Member)

144C(3) of the Act for A.Y. 2016-17, all the assessment orders were passed on 23/01/2019. 2. Considering the appeal record we find that the Ld.CIT(A) passed a combined order related to A.Ys 2012-13 to 2016-17. The appeals filed by the revenue and cross objection filed by the assesseeonly related to A.Ys

DCIT(CC)-8(3) , MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

In the result, the cross-objection of the assessee is partly\nallowed, whereas the appeal of the Revenue is dismissed

144C(3) of the Act on 15.06.2017 wherein the total\nincome was assessed under normal provisions of the Act at\nRs.21,73,79,550/- and book profit u/s 115JB of the Act at\nRs.92,66,70,763/-.\n2.1 Subsequently, the Assessing Officer recorded reasons to\nbelieve that income escaped assessment and issued notice

LUPIN LTD.,MUMBAI vs. THE DY CIT, CIRCLE-3(4), MUMBAI

In the result, the appeal of the assessee in I

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

section 143(3) r.w.s. 144C(13), depreciation was disallowed on certain unverified purchases and expenses which were capitalized in the books of accounts. The AO called on the assessee to furnish the depreciation on the written down value of the disallowed purchases for the year under consideration and accordingly disallowed the depreciation on said unverified purchases

ASSTT. CIT -CIRCLE-3(4), MUMBAI vs. M/S. LUPIN LTD., MUMBAI

In the result, the appeal of the assessee in I

Bench: Shri Pavan Kumar Gadale, Jm & Ms Padmavathy S, Am

section 143(3) r.w.s. 144C(13), depreciation was disallowed on certain unverified purchases and expenses which were capitalized in the books of accounts. The AO called on the assessee to furnish the depreciation on the written down value of the disallowed purchases for the year under consideration and accordingly disallowed the depreciation on said unverified purchases

ITO 9(3)(2), MUMBAI vs. STERLING OIL RESOURCES P.LTD, MUMBAI

In the result, the appeal of the Assessing Officer is dismissed and the appeal of the assessee is allowed

144C (5) of the Act] grossly erred, in law and in facts, in not allowing the benefit of arm's length range of +/- 5% provided in proviso to sec 92C(2) of the Act for computing the transfer pricing adjustment.” 3. Briefly stated, the relevant material facts, and developments leading to this dispute before us, are like this. The assessee