ACIT-2(2)(1), MUMBAI vs. M/S. J K SHAH EDUCATION PVT LTD, MUMBAI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

section 92B(2) by holding that “human capital” related intangibles are also intangibles assets qualifying for depreciation. From explanation to section

ACIT-2(2)(1), MUMBAI vs. M/S. J K SHAH EDUCATION PVT LTD, MUMBAI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

section 92B(2) by holding that “human capital” related intangibles are also intangibles assets qualifying for depreciation. From explanation to section

ACIT-2(2)(1), MUMBAI vs. M/S. J K SHAH EDUCATION PVT LTD, MUMBAI

Bench: Shri Kuldip Singh & Shri Amarjit Singh

section 92B(2) by holding that “human capital” related intangibles are also intangibles assets qualifying for depreciation. From explanation to section

DY.CIT 7(1) (1) , MUMBAI vs. M/S. MATTEL TOYS (INDIA) PVT. LTD, MUMBAI

In the result, the appeal of the Revenue is dismissed, whereas,

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2012-13 Dy. Cit, Circle-7(1)(1), M/S Mattel Toys (India) Pvt. Ltd., Room No. 126, 1St Floor, Phoenix House, B-Wing, 4Th Floor, Vs. Aayakar Bhavan, M.K. Road, 462, Senapati Bapat Marg, Lower Mumbai-400020. Parel, Mumbai-400013. Pan No. Aaccm 2563 P Appellant Respondent

depreciation on unused plant and machinery of ₹1,73,829/- on unused plant and machinery of -. Further, the Assessing Officer vide order u/s 154 dated 30.03.2017 rectified the Assessing Officer vide order u/s 154 dated 30.03.2017 rectified the Assessing Officer vide order u/s 154 dated 30.03.2017 rectified the stment and added further sum of ₹36,86,308/- transfer pricing adjustment

KANSAI NEROLAC PAINTS LIMITED (ERSTWHILE KNOWN AS GOODLASS NEROLAC PAINTS LIMITED),MUMBAI vs. ADDL. CIT, RANGE 6 (2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

depreciation of Rs.17,11,188 @ 60% [Para 3, pg.2]. The AO has also observed that the Assessee’s representative agreed for this disallowance as per note sheet entry dated 16.09.2011. On appeal, the CIT(A) upheld the disallowance. 6. The Ld.AR of the assessee submitted that in fact the assessee did not agree for the disallowance. The assessee had only

KANSAI NEROLAC PAINTS LIMITED (ERSTWHILE KNOWN AS GOODLASS NEROLAC PAINTS LIMITED),MUMBAI vs. ADDL CIT, RANGE 6 (2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

depreciation of Rs.17,11,188 @ 60% [Para 3, pg.2]. The AO has also observed that the Assessee’s representative agreed for this disallowance as per note sheet entry dated 16.09.2011. On appeal, the CIT(A) upheld the disallowance. 6. The Ld.AR of the assessee submitted that in fact the assessee did not agree for the disallowance. The assessee had only

KANSAI NEROLAC PAINTS LTD,MUMBAI vs. DCIT RG 6(2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

depreciation of Rs.17,11,188 @ 60% [Para 3, pg.2]. The AO has also observed that the Assessee’s representative agreed for this disallowance as per note sheet entry dated 16.09.2011. On appeal, the CIT(A) upheld the disallowance. 6. The Ld.AR of the assessee submitted that in fact the assessee did not agree for the disallowance. The assessee had only

M/S. KANSAI NEROLAC PAINTS LTD.,MUMBAI vs. DCIT RG. - 6(3), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

depreciation of Rs.17,11,188 @ 60% [Para 3, pg.2]. The AO has also observed that the Assessee’s representative agreed for this disallowance as per note sheet entry dated 16.09.2011. On appeal, the CIT(A) upheld the disallowance. 6. The Ld.AR of the assessee submitted that in fact the assessee did not agree for the disallowance. The assessee had only

DCIT RG. - 6(3), MUMBAI vs. M/S. KANSAI NEROLAC PAINTS LTD., MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

depreciation of Rs.17,11,188 @ 60% [Para 3, pg.2]. The AO has also observed that the Assessee’s representative agreed for this disallowance as per note sheet entry dated 16.09.2011. On appeal, the CIT(A) upheld the disallowance. 6. The Ld.AR of the assessee submitted that in fact the assessee did not agree for the disallowance. The assessee had only

THE BOMBAY DYEING & MFG. CO. LTD,MUMBAI vs. DCIT RG 2(1)(1), MUMBAI

Bench: Sri Mahavir Singh, Jm & Sri N K Pradhan, Am The Bombay Dyeing & Mfg. Co. Dy. Commissioner Of Limited Income Tax, Range- Neville House, J.N. Heradia Marg, 2(1)(1), Mumbai Vs. Ballard Estate, Mumbai-400 001 Room No.561, Aayakar Pan No.Aaact2328K Bhavan, Mumbai-400 020

92B of the Act which defines the term "international transaction" used in section 92(1) of the Act as under: - 29 The Bombay Dyeing & Mfg. Co. Limited (A.Y:2012-13) "International transaction means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts

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

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

Section 92B of the Act. 3. On facts and circumstances of the case and in law, the Hon'ble CIT(A) has erred in not appreciating that provision of corporate guarantee is primarily a shareholder service and has no bearings on the profits, income, losses or assets of associated enterprise. 4. The Hon'ble CIT(A) has erred in facts