DCIT (LTU) 2, MUMBAI vs. ASIAN PAINTS LTD, MUMBAI

disallowance made by the AO under section 14A read with Rule\n8D of the Rules. Accordingly, the same is directed to be deleted. As a result,\nground no.1 raised in assessee's appeal is allowed.”\n10. In the present case, it is evident from the record that the AO without\nrecording any satisfaction regarding the claim of the assessee

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

section 92C(1). of the method prescribed under section 92C(1). 38. The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice prevailing in the in the diamond industry separate identity of the diamond

ASIAN PAINTS LTD,MUMBAI vs. ASST CIT LTU, MUMBAI

disallowance only to the extent of expenditure\npertaining to home improvement and decor business. As a result, ground no.2\nraised in assessee's appeal is partly allowed.\n20. The issue arising in ground no.3, raised in assessee's appeal, pertains to\ntransfer pricing adjustment on account of non-recovery of charges for\nproviding the letter of comfort/support.\n21. The brief

ASIAN PAINTS LTD,MUMBAI vs. ASST CIT (LTU) 2, MUMBAI

disallowance made by the AO under section 14A read with Rule\n8D of the Rules. Accordingly, the same is directed to be deleted. As a result,\nground no.1 raised in assessee's appeal is allowed.”\n10. In the present case, it is evident from the record that the AO without\nrecording any satisfaction regarding the claim of the assessee

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

disallowance of Rs. 29,47,184, referred to in ground 2 above.\n3.2. Without prejudice to 3.1 above, the relief should be granted in\n assessment year 2010-2011 wherein the Company has reversed\nprovision of Rs. 66,71,400 and offered the same for tax.\nThe Appellant therefore prays that it be appropriately allowed the\ndeduction under section 10A/10B

DCIT (LTU) 2, MUMBAI vs. ASIAN PAINTS LTD, MUMBAI

disallowance only to the extent of expenditure\npertaining to home improvement and decor business. As a result, ground no.2\nraised in assessee's appeal is partly allowed.\n20. The issue arising in ground no.3, raised in assessee's appeal, pertains to\ntransfer pricing adjustment on account of non-recovery of charges for\nproviding the letter of comfort/support.\n21. The brief

TELEPERFORMANCE GLOBAL SERVICES P. LTD.,MUMBAI vs. THE ADDL/JT/DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT DENTRE,, DELHI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Us, First We Would Like To Address Ground No.2 Wherein The Assessee Has Submitted That The Order Of The Ld. Tpo U/S.92Ca(3) Of The Act Dated 01/11/2019 Is Barred By Limitation & Hence, Invalid In Law.

disallowance u/s.14A of the Act of Rs.7,84,950/-. The assessee preferred objections before the ld. DRP. The ld. DRP issued directions u/s.144C(5) of the Act on 20/03/2021. Pursuant to the directions of the ld. DRP, the ld. AO passed the final assessment order u/s.143(3) r.w.s. 144C(13) of the Act on 17/04/2021 which is same

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P. LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

disallowance under section 14A is concerned, DRP reduced the amount from Rs. 27,16,560/- to Rs. 10,00,000/-. Being aggrieved with this order of AO, passed to comply with the directions of DRP, the assessee preferred appeal before ITAT. 8. We have gone through the draft assessment order, order of TPO under section 92CA (3), directions

HSBC SECURITIES AND CAPITAL MARKETS (I) P.LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

disallowance under section 14A is concerned, DRP reduced the amount from Rs. 27,16,560/- to Rs. 10,00,000/-. Being aggrieved with this order of AO, passed to comply with the directions of DRP, the assessee preferred appeal before ITAT. 8. We have gone through the draft assessment order, order of TPO under section 92CA (3), directions

DCIT 4(1), MUMBAI vs. HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P.LTD, MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

disallowance under section 14A is concerned, DRP reduced the amount from Rs. 27,16,560/- to Rs. 10,00,000/-. Being aggrieved with this order of AO, passed to comply with the directions of DRP, the assessee preferred appeal before ITAT. 8. We have gone through the draft assessment order, order of TPO under section 92CA (3), directions

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

disallowance originally made by the assessee has been accepted therefore learned dispute resolution panel cannot issue any direction. The objection of the assessee was dismissed. 08. Based on that the final assessment order was passed by the learned assessing officer on 25/1/2015 determining the total income of the assessee at ₹ 2,053,640,239/–. Assessee is aggrieved

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

disallowance originally made by the assessee has been accepted therefore learned dispute resolution panel cannot issue any direction. The objection of the assessee was dismissed. 08. Based on that the final assessment order was passed by the learned assessing officer on 25/1/2015 determining the total income of the assessee at ₹ 2,053,640,239/–. Assessee is aggrieved

GREAVES COTTON LTD,MUMBAI vs. ASST CIT 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

disallowance originally made by the assessee has been accepted therefore learned dispute resolution panel cannot issue any direction. The objection of the assessee was dismissed. 08. Based on that the final assessment order was passed by the learned assessing officer on 25/1/2015 determining the total income of the assessee at ₹ 2,053,640,239/–. Assessee is aggrieved

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

disallowance originally made by the assessee has been accepted therefore learned dispute resolution panel cannot issue any direction. The objection of the assessee was dismissed. 08. Based on that the final assessment order was passed by the learned assessing officer on 25/1/2015 determining the total income of the assessee at ₹ 2,053,640,239/–. Assessee is aggrieved

SITEL INDIA LTD,MUMBAI vs. DCIT RG 8(3), MUMBAI

In the result, appeal by the assessee is allowed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

disallowed shall, for the purposes of clause (c) of this sub-section, be deemed to represent the income in respect of which particulars have been concealed or inaccurate particulars have been furnished, unless the assessee proves to the satisfaction of the Assessing Officer or the Commissioner (Appeals) or the Principal Commissioner or Commissioner that the price charged or paid

KAYBEE P.LTD,MUMBAI vs. ITO 10(1)(3) (ERSTWHILE JURIDICTIONAL ITO 8(2)(2), MUMBAI

In the result, ground no.6 is allowed for statistical purpose

Bench: Shri R.C. Sharma & Shri Pawan Singhm/S Kaybee Private Limited Ito-10(1)(3) 301, ‘A’ Wing, Solaris-1, Room No. 25 B, Ground Saki Vihar Road, Andheri (E), Vs. Floor, Aayakar Bhavan, Mumbai-400072. Mumbai (Erstwhile Pan: Aaack1715H Jurisdictional Ito-8(2)(2), Mumbai. Appellant Respondent M/S Kaybee Private Limited Ito-10(1)(3) 301, ‘A’ Wing, Solaris-1, Room No. 25 B, Ground Saki Vihar Road, Andheri (E), Vs. Floor, Aayakar Bhavan, Mumbai-400072. Mumbai (Erstwhile Pan: Aaack1715H Jurisdictional Ito-8(2)(2), Mumbai. Appellant Respondent Appellant By : Shri Madhur Agarwal (Advocate) Respondent By : Shri Jayant Kumar With Shri V. Jenerdhanan (Cit-Dr) Date Of Hearing : 28.05.2018 Date Of Pronouncement : 08.08.2018

disallowance of expenses was deleted. Therefore, further aggrieved by the order of ld. CIT(A), the assessee has filed the present appeal before us. 4. We have heard the ld. AR of the assessee and ld. DR for the Revenue and perused the material available on record. Ground No.1 relates to non- issuance of show-cause notice under section

DCIT 5(2)(1), MUMBAI vs. KARP IMPEX P.LTD, MUMBAI

In the result, all the appeals of Revenue are dismissed

Bench: Sri Mahavir Singh, Jm & Sri Ramit Kochar, Am

92D to maintain and produce documentation as called for by the TPO. Therefore, the assessee's Instant case is a fit case for levy of penalty uls 271G for failure to furnish Information or document in respect of segmental accounts relating to transactions made with AEs and non AEs for determination of arms length price of international transactions as required

DCIT 5(2)(1), MUMBAI vs. INTERJWEL P.LTD, MUMBAI

In the result, all the appeals of Revenue are dismissed

Bench: Sri Mahavir Singh, Jm & Sri Ramit Kochar, Am

92D to maintain and produce documentation as called for by the TPO. Therefore, the assessee's Instant case is a fit case for levy of penalty uls 271G for failure to furnish Information or document in respect of segmental accounts relating to transactions made with AEs and non AEs for determination of arms length price of international transactions as required