MAHINDRA & MAHINDRA LTD,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, appeal by the assessee is partly allowed

Bench: Shri Shamim Yahya & Shri Ram Lal Negi

801C to Rs. 99,76,03,710 as against Rs. 359,67,62,865 claimed by the Appellant relating to the said unit. The said directions of the DRP are contrary to facts and the position in law and are in any event perverse and have been given without giving the Appellant an opportunity of being heard

GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD),MUMBAI vs. ADDL CIT LTU, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

capital in nature amounting to Rs. 15,23,25,727/- (Amount is wrong in Department Appeal, actual amount = 17,81,17,446/-) 15 Erred in restricting the ALP of guarantee fees in respect of corporate guarantee given to AE to 0.5% as against 2.42% as held by AO/TPO 16. Erred in restricting ALP of performance guarantee fees

ASST CIT (LTU) 1, MUMBAI vs. GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

capital in nature amounting to Rs. 15,23,25,727/- (Amount is wrong in Department Appeal, actual amount = 17,81,17,446/-) 15 Erred in restricting the ALP of guarantee fees in respect of corporate guarantee given to AE to 0.5% as against 2.42% as held by AO/TPO 16. Erred in restricting ALP of performance guarantee fees

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

capital infusion. Therefore, these are part of shareholder activities. The learned Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently

GODREJ CONSUMER PRODUCTS LTD,MUMBAI vs. ASST CIT CIR 14(1)(2), MUMBAI

In the result, the appeal filed by the assessee is hereby ordered to be partly allowed

801C of the Act claimed by the eligible units of the Appellant, by excluding transport subsidy, transport recoveries, claims received, miscellaneous income, sundry balances written back and net gain on exchange difference forming part of the 'Other Income of such eligible units and in reducing the deduction claimed accordingly. 2) The learned Dispute Resolution Panel erred in confirming the action

GRASIM INDUSTRIES LTD (SUCCESSOR TO ADITYA BIRLA NUVO LTD),MUMBAI vs. DY CIT CC 1 (4) , MUMBAI

In the result, appeal of the assessee for A

801C of IT. Act, 1961. The relevant finding of Hon'ble Apex Court is as under :- "Assistance by way of subsidies which are reimbursed on the incurring of costs relatable to a business, do not fall under the head "income from other sources", which is a residuary head of income that can be availed only if income does not fall

DY CIT CC 1 (4) , MUMBAI vs. M/S ADITYA BIRLA NUVO LTD (NOW MERGED EITH GRASIM INDUSTRIES LTD), MUMBAI

In the result, appeal of the assessee for A

801C of IT. Act, 1961. The relevant finding of Hon'ble Apex Court is as under :- "Assistance by way of subsidies which are reimbursed on the incurring of costs relatable to a business, do not fall under the head "income from other sources", which is a residuary head of income that can be availed only if income does not fall

DY CIT CC 1 (4), MUMBAI vs. M/S ADITYA BIRLA NUVO LTD ( NOW MERGED WITH GRASIM INDUSTRIAL LTD), MUMBAI

In the result, appeal of the assessee for A

801C of IT. Act, 1961. The relevant finding of Hon'ble Apex Court is as under :- "Assistance by way of subsidies which are reimbursed on the incurring of costs relatable to a business, do not fall under the head "income from other sources", which is a residuary head of income that can be availed only if income does not fall

GRASIM INDUSTRIES LTD (SUCCESSOR TO ADITYA BIRLA NUVO LTD) ,MUMBAI vs. DY CIT CC 1 (4) , MUMBAI

In the result, appeal of the assessee for A

801C of IT. Act, 1961. The relevant finding of Hon'ble Apex Court is as under :- "Assistance by way of subsidies which are reimbursed on the incurring of costs relatable to a business, do not fall under the head "income from other sources", which is a residuary head of income that can be availed only if income does not fall

GRASIM INDUSTRIES LTD (SUCCESSOR TO ADITYA BIRLA NUVO LTD) ,MUMBAI vs. DY CIT CC 1 (4) , MUMBAI

In the result, appeal of the assessee for A

801C of IT. Act, 1961. The relevant finding of Hon'ble Apex Court is as under :- "Assistance by way of subsidies which are reimbursed on the incurring of costs relatable to a business, do not fall under the head "income from other sources", which is a residuary head of income that can be availed only if income does not fall