DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

92A, 92B, 92C, 92D and 92E, unless the context otherwise requires,— ……… i) "arm's length price" means a price which is applied or proposed to be applied in a transaction between persons other than associated enterprises, in uncontrolled CO Nos. 257 & 258 /Mum/2024 M/s. JSW Steel Coated Products Limited ii) conditions; 32. The definition of ALP, as reproduced above, speaks

THE DY CIT, CIRCLE-4(1)(2),, AHMEDABAD vs. VODAFONE WEST LIMITED,, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

house property'. It is,\ntherefore, directed to be considered as eligible for deduction u/s.80IA of\nthe Act.\"\nIn view of the above decision of the Co-ordinate Bench of the Tribunal,\nexclusion of cell site sharing revenue of INR.0.81 Crores from the business\nincome while computing deduction under Section 80IA of the Act cannot be\nsustained. Therefore, the Assessing Officer

ADITYA BIRLA NUVO LTD (SINCE AMALGAMATED WITH GRASIM INDUSTRIES LIMITED),MUMBAI vs. DCIT CC-1(4) EARLIER WITH ACIT(LTU) 1, MUMBAI

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER &\nSMT RENU JAUHRI, ACCOUNTANT MEMBER\nITA No.563/Mum/2018\n(Assessment Year :2013-14)\nAditya BirlaNuvo Ltd. Vs. Dy. CIT, Central Circle – 1(4)\n(Since Amalgamated with\nGrasim Industries Limited)\nA2 Aditya Birla Centre, S. K.\nAhire Marg, Worli, Mumbai\nEarlier with Asst. CIT(LTU) 1\nRoom No. 902, Old CGO\nBuilding, 9th Floor, M. K. Road,\nMumbai-400 020\nPAN/GIR No.AAACI1747H\n(Appellant) .. (Respondent)\nITA No.1885/Mum/2018\n(Assessment Year :2013-14)

92A, 92B, 92C, 92D and 92E, unless the context otherwise requires,—\n(i) ………\n(ii) \"arm's length price\" means a price which is applied or proposed to be applied in a\ntransaction between persons other than associated enterprises, in uncontrolled\nconditions;\n32. The definition of ALP, as reproduced above, speaks of two conditions. Firstly, the\ntransaction must be between

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, C.O. filed by assessee is\ndismissed as infructuous

92A, 92B, 92C, 92D and 92E, unless the context otherwise\nrequires,-\ni)\n\"arm's length price\" means a price which is applied or proposed to be applied in a\ntransaction between persons other than associated enterprises, in uncontrolled\nconditions;\nii) conditions;\n32. The definition of ALP, as reproduced above, speaks of two conditions. Firstly,\nthe transaction must be between

VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

house property'. It is,\ntherefore, directed to be considered as eligible for deduction u/s.80IA of\nthe Act.\"\nIn view of the above decision of the Co-ordinate Bench of the Tribunal,\nexclusion of cell site sharing revenue of INR.0.81 Crores from the business\nincome while computing deduction under Section 80IA of the Act cannot be\nsustained. Therefore, the Assessing Officer

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. ()

House, G.K. Marg, Lower Power, Mumbai-400 013 PAN : AAACG1376N ASSESSEE RESPONDENT Present for the Assessee Mrs.Aarti Vissanji Present for the Department Shri. Rajesh Pardeshi, JCIT Date of hearing 17/11/2023 Date of pronouncement 04/12/2023 2 Kansai Nerolac Paints Limited I.T.A. No.3384&3385/Mum/2014 I.T.A. No.3642/Mum/2016 and I.T.A. No.4562&4607/Mum/2017 O R D E R Per Padmavathy S, AM: These appeal filed

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. ()

House, G.K. Marg, Lower Power, Mumbai-400 013 PAN : AAACG1376N ASSESSEE RESPONDENT Present for the Assessee Mrs.Aarti Vissanji Present for the Department Shri. Rajesh Pardeshi, JCIT Date of hearing 17/11/2023 Date of pronouncement 04/12/2023 2 Kansai Nerolac Paints Limited I.T.A. No.3384&3385/Mum/2014 I.T.A. No.3642/Mum/2016 and I.T.A. No.4562&4607/Mum/2017 O R D E R Per Padmavathy S, AM: These appeal filed

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. ()

House, G.K. Marg, Lower Power, Mumbai-400 013 PAN : AAACG1376N ASSESSEE RESPONDENT Present for the Assessee Mrs.Aarti Vissanji Present for the Department Shri. Rajesh Pardeshi, JCIT Date of hearing 17/11/2023 Date of pronouncement 04/12/2023 2 Kansai Nerolac Paints Limited I.T.A. No.3384&3385/Mum/2014 I.T.A. No.3642/Mum/2016 and I.T.A. No.4562&4607/Mum/2017 O R D E R Per Padmavathy S, AM: These appeal filed

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. ()

House, G.K. Marg, Lower Power, Mumbai-400 013 PAN : AAACG1376N ASSESSEE RESPONDENT Present for the Assessee Mrs.Aarti Vissanji Present for the Department Shri. Rajesh Pardeshi, JCIT Date of hearing 17/11/2023 Date of pronouncement 04/12/2023 2 Kansai Nerolac Paints Limited I.T.A. No.3384&3385/Mum/2014 I.T.A. No.3642/Mum/2016 and I.T.A. No.4562&4607/Mum/2017 O R D E R Per Padmavathy S, AM: These appeal filed

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. ()

House, G.K. Marg, Lower Power, Mumbai-400 013 PAN : AAACG1376N ASSESSEE RESPONDENT Present for the Assessee Mrs.Aarti Vissanji Present for the Department Shri. Rajesh Pardeshi, JCIT Date of hearing 17/11/2023 Date of pronouncement 04/12/2023 2 Kansai Nerolac Paints Limited I.T.A. No.3384&3385/Mum/2014 I.T.A. No.3642/Mum/2016 and I.T.A. No.4562&4607/Mum/2017 O R D E R Per Padmavathy S, AM: These appeal filed

SAI SHIPPING COMPANY PVT LTD,MUMBAI vs. INCOME TAX OFFICER/NFAC, DELHI

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

92A) are international transactions in terms of section 92B, the same needs to be verified. On perusal of records, it was found that the assessee had determined arm's length price of above international transactions through submission of report in form 3CEB u/s 92E. As regards Corporate Guarantee of Rs. 24.25 crore given by the assessee is concerned

TATA CHEMICALS LTD,MUMBAI vs. DCIT - 2 (3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

92A\n(2)(i) which reads as under:-\n(i) The goods or articles manufactured or processed by one enterprise are\nsold to the other enterprise or to the persons specified by the other enterprise,\nand the prices and other conditions relating thereto are influenced by such\nother enterprise.\n18. If M/s. Torrent Power Ltd. (TPL) is purely supplying

M/S EDELWEISS RURAL & CORPORATE SERVICES PRIVATE LIMITED (EARLIER KNOW AS M/S EDELWEISS COMMODITIES SERVICES LIMITED),MUMBAI vs. ACIT CENTRAL CIRCLE-1(2), MUMBAI, MUMBAI

In the result, appeal of the assessee for A

House Mumbai – 400 020 Off CST Road Kalina, Santacruz (East) Mumbai PAN/GIR No.AAKCS7311R (Appellant) .. (Respondent) Assessee by Shri Jitendra Jain Revenue by Shri Manoj Kumar Date of Hearing 01/08/2022 Date of Pronouncement 26/08/2022 आदेश / O R D E R PER M. BALAGANESH (A.M): These appeals in ITA No.1040/Mum/2022 & 1041/Mum/2022 for A.Y.2012-13 & 2015-16 arise out of the order

M/S EDELWEISS RURAL & CORPORATE SERVICES PRIVATE LIMITED ,MUMBAI vs. JCIT CENTRAL CIRCLE-1(2), MUMBAI, MUMBAI

In the result, appeal of the assessee for A

House Mumbai – 400 020 Off CST Road Kalina, Santacruz (East) Mumbai PAN/GIR No.AAKCS7311R (Appellant) .. (Respondent) Assessee by Shri Jitendra Jain Revenue by Shri Manoj Kumar Date of Hearing 01/08/2022 Date of Pronouncement 26/08/2022 आदेश / O R D E R PER M. BALAGANESH (A.M): These appeals in ITA No.1040/Mum/2022 & 1041/Mum/2022 for A.Y.2012-13 & 2015-16 arise out of the order

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLYUT WORLDWIDE (INDIA) PVT. LTD.), MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

92A to 92F, is purpose-built to\nensure that arm's-length determinations respond sensitively to market conditions that\nmay change from one year to the next. The Commissioner's presumption of factual\ncontinuity is the antithesis of that statutory instructions and construction.\n1. 4. The Commissioner's approach also nullifies the analytical sequencing mandated by\nIndian and international guidance

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.) , MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

92A to 92F, is purpose-built to\nensure that arm's-length determinations respond sensitively to market conditions that\nmay change from one year to the next. The Commissioner's presumption of factual\ncontinuity is the antithesis of that statutory instructions and construction.\n1. 4. The Commissioner's approach also nullifies the analytical sequencing mandated by\nIndian and international guidance

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI, MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.), MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

92A to 92F, is purpose-built to ensure that arm's-length determinations respond sensitively to market conditions that may change from one year to the next. The Commissioner's presumption of factual continuity is the antithesis of that statutory instructions and construction.\n1. 4. The Commissioner's approach also nullifies the analytical sequencing mandated by Indian and international guidance