FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

transfer pricing adjustment on royalty payment to the AE. This ground is allowed.” 16. In this view of the matter and consistent with the view taken by the co- ordinate bench, we direct the AO / TPO to delete TP adjustment of Rs.3,96,90,306 in relation to payment of royalty for use of technical know how. 17. The next

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

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

Transfer Pricing Officer to compute the same. iv. With respect to the deduction under Section 80IB and 80IC of the Act, he upheld the disallowance to the extent of the sale of empty containers. He held that sale of scrap is not eligible for deduction as income derived from the industrial undertaking. v. With respect to the claim of depreciation

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

transfer pricing provision is applicable. 54 Viacom 18 Media Pvt. Ltd. 119. Considered the rival submissions and perused the material on record. We find that the issue arising out of the aforesaid ground of appeal has been decided by the Tribunal in assessee‟s own case in ACIT v/s M/s. Viacom 18 Media Pvt. Ltd., ITA no. 8406/Mum./2010, order

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer in this regard is misconceived, erroneous and incorrect. 3. Re : Disallowance of depreciation on goodwill: 3.1 The learned

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

depreciation of Rs. 7,17,193 on the\nwritten down value of assets being items included to block of assets\nof Computer, Plant and Machinery, Building consequent to\ndisallowance of revenue expenditure in the assessment orders of\n assessment year 2004-05, 2005- 06 and 2006-07.\n Assessment Year 2010-11\nGround 1 Transfer Pricing

SABMILLER INDIA LTD,MUMBAI vs. ASST CIT CIR 11(1)(2), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

Transfer Pricing Officer accepts that some services have been rendered, however, he has made a general observation that such services do not have any value and has proceeded to determine the arm's length price on a purely on ad–hoc basis. Whereas, the reading of the AAR ruling, referred to above, clearly demonstrate that highly specialized services, in fact

M/S. INDIA MEDTRONICS PVT.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(2),, BARODA

In the result, similarly the Assessee’s appeal is partly allowed

Bench: Shri Amit Shukla & Shri Gagan Goyal

Transfer Pricing Officer to delete the addition on account of excessive purchase price as it is already benchmarked once under TNMM/RPM, as under 69. However, learned Commissioner (Appeals), inadvertently dismissed the ground, whereas it was to be allowed following DRP direction. Hence, the based on the above order, adjustment on account of excessive purchase price amounting