FIRMENICH AROMATICS (INDIA) P.LTD,MUMBAI vs. ACIT CIR 4(2), MUMBAI

In the result this ground of appeal is allowed

Bench: Shri Pawan Singh & Shri S. Rifaur Rahman(Virtual Hearing In Virtual Court No.2)

Method (TNMM). The assessee has shown its profit margin @ 4.29%. The assessee treated itself as a tested party. Operating profit / income was considered for profit level indicator (PLI). The assessee selected following four comparable company for comparison of its benchmarking; Sr. No Comparables company Margin % Year 1 Bhagat Aromatic Ltd 4.54 Multiple year data 2 Everest Flavours Ltd 0.70 March

PERPUTO CONTENT MANAGEMENT P.LTD,MUMBAI vs. ITO 9(2)(4), MUMBAI

Appeal stands partly allowed for statistical purposes

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./I.T.A. No.2215 & 2216/Mum/2015 (िनधा"रणवष" / Assessment Years: 2008-09 & 2009-10) Perputo Content Management Pvt. Ltd. Income Tax Officer 9(2)(4) C/O V.N.Deodhar & Co. Mumbai-400 020 बनाम/ 4/3 ‘Radha’,1St Floor Vs. Shastri Hall, Grant Road(W) Mumbai-400 007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aadcp-6770-G (अपीलाथ"/Appellant) (""थ" / Respondent) : Revenue By : V.Jenardhanan,Ld.Dr Assessee By : Milin Thakore,Ld.Ar सुनवाईकीतारीख/ : 24/04/2018 Date Of Hearing घोषणाकीतारीख / : 27 /04/2018 Date Of Pronouncement

condonation of delay, took us through chronology of the events to support his stand in the following manner:- Sr. Event date /Reference Particulars Page Affidavit No. No. of para no. Paper book 1 April / May 2010 Termination of all employed staff and shut down of operations, since 1-2 5c Perputo Inc. (the sole customer of Perputo Content Management Private

PERPUTO CONTENT MANAGEMENT P.LTD,MUMBAI vs. ITO 9(2)(4), MUMBAI

Appeal stands partly allowed for statistical purposes

Bench: Shri Saktijit Dey, Jm & Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./I.T.A. No.2215 & 2216/Mum/2015 (िनधा"रणवष" / Assessment Years: 2008-09 & 2009-10) Perputo Content Management Pvt. Ltd. Income Tax Officer 9(2)(4) C/O V.N.Deodhar & Co. Mumbai-400 020 बनाम/ 4/3 ‘Radha’,1St Floor Vs. Shastri Hall, Grant Road(W) Mumbai-400 007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aadcp-6770-G (अपीलाथ"/Appellant) (""थ" / Respondent) : Revenue By : V.Jenardhanan,Ld.Dr Assessee By : Milin Thakore,Ld.Ar सुनवाईकीतारीख/ : 24/04/2018 Date Of Hearing घोषणाकीतारीख / : 27 /04/2018 Date Of Pronouncement

condonation of delay, took us through chronology of the events to support his stand in the following manner:- Sr. Event date /Reference Particulars Page Affidavit No. No. of para no. Paper book 1 April / May 2010 Termination of all employed staff and shut down of operations, since 1-2 5c Perputo Inc. (the sole customer of Perputo Content Management Private

DCIT CEN CIR 8(1), MUMBAI vs. ALLCARGO LOGISTICS LTD, MUMBAI

In the result the appeal filed by the revenue is dismissed

Bench: Shri G. S. Pannu & Shri Pawan Singhdcit. Cc -8(1), M/S Allcargo Logistics Ltd. Room No. 656, 6Th Floor, 5Th Floor, Diamond Square, Cst Aayakar Bhavan, M. K. Road, Vs. Ropad, Kalina, Santacruz(E), Mumbai-400020 Mumbai-400098 Pan: Aacca2894D (Appellant) (Respondent)

condonation of delay, the delay in filing the Cross Objection by assessee is allowed. 4. Brief facts of the case are that the assessee is a flagship company of M/s Allcargo Group and is engaged in the business of logistic services provider in domestic as well as in international markets. The assessee is a leading “Less than a Container Load

SPRIT INFRAPOWER & MULTIVENTURES PRIVATE LIMITED,MUMBAI vs. PCIT-8, MUMBAI

The appeal of the assessee is allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

TP Adjustment) of Rs. 5,30,00,590/-. The PCIT on verification of records noticed that the assessee has claimed depreciation on goodwill to the tune of Rs. 11,49,27,522/-. The PCIT further noticed that the goodwill on which the assessee has claimed depreciation under the Act is not reflected in the balance-sheet and that the assessee

ASST CIT 10(3)(2), MUMBAI vs. PANGEA3 LEGAL DATABASE P.LTD, MUMBAI

Appeal stands dismissed whereas the assessee’s appeal stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Saktijit Dey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

condone the delay and proceed for adjudication of appeal on merits. 2.1 The Ld. Authorized Representative for Assessee [AR], Shri Rajan Vora, at the outset submitted that Ground Nos. 1 to 3 of assessee’s appeal would be general in nature whereas the assessee is not pressing ground nos. 4.2, 5.2 to 5.4. Assessment Year

PANGEA LEGAL DATABASE SYSTEMS PRIVATE LIMITED,MUMBAI vs. ACIT , 10(3)(2), MUMBAI

Appeal stands dismissed whereas the assessee’s appeal stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Saktijit Dey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

condone the delay and proceed for adjudication of appeal on merits. 2.1 The Ld. Authorized Representative for Assessee [AR], Shri Rajan Vora, at the outset submitted that Ground Nos. 1 to 3 of assessee’s appeal would be general in nature whereas the assessee is not pressing ground nos. 4.2, 5.2 to 5.4. Assessment Year

TOKHEIM INDIA PVT. LTD.,MUMBAI vs. INCOME TAX OFFICER 15(3)(1), MUMBAI

The appeal of the assessee is allowed, and appeal of the Assessing Officer is dismissed

Bench: Shri Saktijit Dey, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 6601/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2013-14)

condone the delay and proceed to hear the appeal. 3. At the time of hearing Ld AR submitted that assessee has filed the grounds of appeal in which assessee is pressing only ground No. 2 all other grounds are not pressed. Accordingly, we dismiss the ground No. 1, 3 and 4 as not pressed. 4. The brief facts relating

RANDOX LABORATORIES (INDIA) P.LTD,MUMBAI vs. ITO 7(2)(1) OR CIT(A) 7, MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

method, the other issue relating to computation of margin of comparables under TNMM does not require adjudication. Further, we direct the Assessing Officer / Transfer Pricing Officer to adopt the correct purchase figure as debited to the Profit & Loss account after due verification. 14. In the result, assessee’s appeal is allowed. IT(TP)A no.1568/Mum./2015 Revenue’s Appeal

ASST CIT 12(4), MUMBAI vs. TATA CONSULTANCY SERVICES LTD ( FORMLERY M.S, TCS BUSINESS TRANSFORMATION SOLUTION LTD), BANGALORE

In the result, the plea of assessee under rule 27 of the Tribunal

Bench: Sri Mahavir Singh, Jm & Sri Nk Pradhan, Am Asst. Commissioner Of Tata Consultancy Services Ltd. Income Tax, Large Tax (Formerly M/S Tcs Payer Unit, Business Transformation Centre-1 28Th Floor, World Vs. Solutions Ltd.) Trade Centre, Cuffe Parade, Sjm Towers, 18, Sheshadri Mumbai-400 005 Road, Gandhinagar, Bangalore-560 009 Pan No.Aacp8925G Appellant .. Respondent

delay cannot be condone, against the order of CIT(A), challenging the same on few comparables by invoking the Rule 27 of the Tribunal Rules, which we allow now. 6. Now we will take up the appeal of Revenue and the arguments raised by assessee under rule 27 of the Tribunal Rules. 7. Brief facts are that during the year

ACIT, MUMBAI vs. DNJ CREATION LLP, MUMBAI

In the result, grounds of appeal raised by revenue are dismissed

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing)

delay in filing such C.O. is condoned. Now, adverting to merits of the case in accordance with various grounds of appeal raised by respective parties. Now adverting to the merits of the case. 6. We have heard the submissions of both the parties on merits and have gone through the orders of lower authorities carefully. With the consent of parties

MAHINDRA HOMES P. LTD.,MUMBAI vs. ITO, RANGE-7(2)(1), MUMBAI

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

Bench: Us That The Issues In Asst Year 2016-17 May Be Taken As The Lead Case & The Decision Rendered Thereon Would Apply With Equal Force For The Asst Year 2017-18 Also In View Of Identical Facts Except With Variance In Figures.

delay in filing of appeal is condoned for the Asst Year 2016-17 and admitted for adjudication. 3. Both the parties mutually agreed before us that the issues in Asst Year 2016-17 may be taken as the lead case and the decision rendered thereon would apply with equal force for the Asst Year 2017-18 also in view

M/S. MAHINDRA HOMES PVT. LTD,MUMBAI vs. ADDL/JT/DY/ACIT/ITO/NFAC, MUMBAI

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

Bench: Us That The Issues In Asst Year 2016-17 May Be Taken As The Lead Case & The Decision Rendered Thereon Would Apply With Equal Force For The Asst Year 2017-18 Also In View Of Identical Facts Except With Variance In Figures.

delay in filing of appeal is condoned for the Asst Year 2016-17 and admitted for adjudication. 3. Both the parties mutually agreed before us that the issues in Asst Year 2016-17 may be taken as the lead case and the decision rendered thereon would apply with equal force for the Asst Year 2017-18 also in view

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

condonation of delay stands allowed. 3. As the facts are identical in the instant appeals, we hereby pass a consolidated order by taking ITA No. 4935/Mum/2025 for AY 2017-18 as the lead year. For sake of convenience, grounds raised by revenue for AY 2017-18 are extracted as under:- 1. "Whether on the fact and circumstances of the case

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

condonation of delay stands allowed. 3. As the facts are identical in the instant appeals, we hereby pass a consolidated order by taking ITA No. 4935/Mum/2025 for AY 2017-18 as the lead year. For sake of convenience, grounds raised by revenue for AY 2017-18 are extracted as under:- 1. "Whether on the fact and circumstances of the case

ASSISSTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

condonation of delay stands allowed. 3. As the facts are identical in the instant appeals, we hereby pass a consolidated order by taking ITA No. 4935/Mum/2025 for AY 2017-18 as the lead year. For sake of convenience, grounds raised by revenue for AY 2017-18 are extracted as under:- 1. "Whether on the fact and circumstances of the case

GULF ENERGY MARITIME SERVICE P.LTD,MUMBAI vs. ITO 8(1)(4), MUMBAI

In the result, the appeal is allowed

condone the delay and proceed to decide the matter on merits I.T.A. No.3812/Mum/2015 Assessment year: 2011-12 Page 2 of 7 3. None appeared for the assessee but, having regard to the narrow compass of material facts within which the short issue requiring our adjudication is set out, we have considered it appropriate to proceed ex parte qua the assessee

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

TP)- 23.12.2019 143(3) 2016-17 Revenue C/S/250/202 2(1)(1), 2- Mumbai 23/1051775 042(1) 31 1891/Mum/2023 ITBA/NFA 31.03.2023 DCIT-1(1)(2), 28.12.2019 143(3) 2017-18 Assessee C/S/250/202 Mumbai 2- 23/1051775 738(1) 32 2046/Mum/2023 ITBA/NFA 31.03.2023 DCIT-1(1)(2), 28.12.2019 143(3) 2017-18 Revenue C/S/250/202 Mumbai 2- 23/1051775 738(1) 33 1892/Mum/2023 ITBA/NFA