PROCTER & GAMBLE HYGIENE & HEALTH CARE LTD.,MUMBAI vs. ADDL.C.I.T. CIR. 8(2), MUMBAI

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

Gain in terms of Sec.50B of the Income Tax Act, 1961.” P a g e | 20 6 Appeals Procter & Gamble Hygiene & Healthcare Pvt. Ltd. Vs. ACIT, Circle 8(2) 20. After referring the contents of the agreement and sale consideration provided in Schedule III the ld. CIT(A) stated that at para no. 3 of the agreement it is clearly

PROCTER & GAMBLE HYGIENE & HEALTH CARE LTD,MUMBAI vs. ADDL CIT CIR 8(2), MUMBAI

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

Gain in terms of Sec.50B of the Income Tax Act, 1961.” P a g e | 20 6 Appeals Procter & Gamble Hygiene & Healthcare Pvt. Ltd. Vs. ACIT, Circle 8(2) 20. After referring the contents of the agreement and sale consideration provided in Schedule III the ld. CIT(A) stated that at para no. 3 of the agreement it is clearly

ADDL CIT RG 8(2), MUMBAI vs. PROCTOR & GAMBLE HYGIENE & HEALTH CARE LTD, MUMBAI

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

Gain in terms of Sec.50B of the Income Tax Act, 1961.” P a g e | 20 6 Appeals Procter & Gamble Hygiene & Healthcare Pvt. Ltd. Vs. ACIT, Circle 8(2) 20. After referring the contents of the agreement and sale consideration provided in Schedule III the ld. CIT(A) stated that at para no. 3 of the agreement it is clearly

ADDL CIT RG 8(2), MUMBAI vs. PROCTOR & GAMBLE HYGINENE & HEALTH CARE LTD, MUMBAI

In the result the appeals of the revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T Varkey & Shri Amarjit Singhita No.3518 & 2277/Mum/2012 Procter & Gamble Hygiene Vs. Additional Cit Circle 8(2) & Healthcare Limited Mumbai -400020 P & G Plaza Cardinal Gracias Road, Chakkala, Andheri (East) Mumbai – 400009 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacp6332M Appellant .. Respondent

Gain in terms of Sec.50B of the Income Tax Act, 1961.” P a g e | 20 6 Appeals Procter & Gamble Hygiene & Healthcare Pvt. Ltd. Vs. ACIT, Circle 8(2) 20. After referring the contents of the agreement and sale consideration provided in Schedule III the ld. CIT(A) stated that at para no. 3 of the agreement it is clearly

THE DY CIT, CIRCLE-4(1)(2),, AHMEDABAD vs. VODAFONE WEST LIMITED,, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

Capital WIP.\"\n13). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\naddition made on account of Arm's Length Price of international transaction\nas under:\"\n13a). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\nadjustment made in respect of the determination of ALP for royalty\npayments for use of brands

VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

Capital WIP.\"\n13). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\naddition made on account of Arm's Length Price of international transaction\nas under:\"\n13a). \"The DRP, Ahmedabad has erred in law and on facts in deleting the\nadjustment made in respect of the determination of ALP for royalty\npayments for use of brands

DEPUTY COMMISSIONER OF INCOME TAX 1(1)(2), MUMBAI vs. HINDUSTAN UNILEVER LIMITED, MUMBAI

801B & 10B and are in no way dependent on\nthe said new industrial undertakings and therefore cannot be considered and\nallocated in arriving at the amount of profits derived from the said\nundertakings.\nExpenditure attributable to earning of tax-free income - Section 14A\ndisallowance\n4. erred in confirming disallowance under section 14A in respect of\nexpenditure in relation

HINDUSTAN UNILEVER LIMITED,MUMBAI vs. DY.CIT-1(1)(2), MUMBAI

801B & 10B and are in no way dependent on\nthe said new industrial undertakings and therefore cannot be considered and\nallocated in arriving at the amount of profits derived from the said\nundertakings.\nExpenditure attributable to earning of tax-free income - Section 14A\ndisallowance\n4. erred in confirming disallowance under section 14A in respect of\nexpenditure in relation

M/S. UNITED PHOSPHORUS LTD.,MUMBAI vs. DCIT CENT. CIR. - 38, MUMBAI

In the result, appeal of the revenue is partly allowed

Bench: Shri Amit Shukla & Shri Gagan Goyalm/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W), Mumbai – 400 052 Pan: Aaacu3440P ...... Appellant Vs. Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ..... Respondent Acit Cc -2 Dy. Commissioner Of Income Tax Central Circle-38 Mumbai ...... Appellant Vs. M/S. United Phosphorus Limited, Mumbai (Now Known As Uniphos Enterprises Ltd.) Uniphos House, 11-C.D. Marg Opp. Madhu Park Khar (W) Mumbai – 400 052 Pan: Aaacu3440P ...... Respondent (Now Known As Uniphos Enterprises Ltd.)

801B and 80HH of the Act was brought out i.e. "profits and gains derived from industrial undertakings" as found in Section 80HH of the Act with "profits and gains derived from any business of an industrial undertakings". In view of the difference in language of the two Sections, this Court held that interest on fixed deposits in the bank would

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(3), MUMBAI vs. M/S SAMSON MARITIME LTD, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

SAMSON MARITIME LIMITED,MUMBAI CITY vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

DY COMMISSIONER OF INCOME TAX (APPEAL)-53, MUMBAI vs. SAMSON MARITIME LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-5(3) , MUMBAI vs. M/S SAMSON MARITIME LTD, MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned

SAMSON MARITIME LIMITED,MUMBAI vs. DCIT, CC-5(3), MUMBAI

In the result, appeals of the Revenue are dismissed and appeals of the assessee are partly allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

801B of the Act, would also be incorrect. The claim of the assessee falls in this league as it says that if MSA has granted registration, the same is the final word for TTS. 5.2.2.3. The assessee has further tried to argue that the sec 3(41) of MSA has got no relevance as far as TTS is concerned