PROCTER & GAMBLE HOME PRODUCTS P.LTD,MUMBAI vs. DCIT 3(3)(1), MUMBAI

The appeals of the assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am Aayakr Apila Sam./ Ita No. 1095/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2012-13) Aayakr Apila Sam./ Ita No. 1096/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 1097/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2014-15)

house hold care, beauty care, feminine care and other products in India, Nepal, Bhutan and other markets as agreed between the assessee and its AEs. The 6 | P a g e ITAs No.1095-1097/Mum/2019 assessee filed its returned income for the AY 2012-13 declaring total income at nil and the return of income was selected for scrutiny by issuing notice

PROCTER & GAMBLE HOME PRODUCTS P.LTD,MUMBAI vs. DCIT 3(3)(1), MUMBAI

The appeals of the assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am Aayakr Apila Sam./ Ita No. 1095/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2012-13) Aayakr Apila Sam./ Ita No. 1096/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 1097/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2014-15)

house hold care, beauty care, feminine care and other products in India, Nepal, Bhutan and other markets as agreed between the assessee and its AEs. The 6 | P a g e ITAs No.1095-1097/Mum/2019 assessee filed its returned income for the AY 2012-13 declaring total income at nil and the return of income was selected for scrutiny by issuing notice

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

House, B-Wing, 4th floor, Room No. 126, 1st floor, Vs. 462, Senapati Bapat Marg, Aayakar Bhavan, Lower Parel, M.K. Road, Mumbai-400013. Mumbai-400020. PAN No. AACCM 2563 P Appellant Respondent : Assessee by Mr. Ketan Ved, AR Revenue by : Mr. Jitendra Kumar, Sr. DR : Date of Hearing 07/11/2022 : Date of pronouncement 29/12/2022 M/s Mattel Toys (India

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

section under which ESOP expenditure is allowable under the Income Tax Act 1961 ('Act). The only provision where a company can claim the expenditure is section 37 of the ActHence, it is pertinent to test the conditions mentioned in section 37 in order to conclude whether the expenditure is allowable? Section 37 of the Act Page

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

92D, which in turn gives effect to the arm's-length mandate of section 92C.\nRead as an integrated scheme, the provisions translate the arm's-length principle into an\nevidentiary rule: an enterprise that pays its affiliate for services must be able to\ndemonstrate, with primary documents, what exactly was done, in what quantity and at\nwhat cost

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

92D, which in turn gives effect to the arm's-length mandate of section 92C. Read as an integrated scheme, the provisions translate the arm's-length principle into an evidentiary rule: an enterprise that pays its affiliate for services must be able to demonstrate, with primary documents, what exactly was done, in what quantity and at what cost

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

92D, which in turn gives effect to the arm's-length mandate of section 92C.\nRead as an integrated scheme, the provisions translate the arm's-length principle into an\nevidentiary rule: an enterprise that pays its affiliate for services must be able to\ndemonstrate, with primary documents, what exactly was done, in what quantity and at\nwhat cost

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

DCIT CIR 3(3), MUMBAI vs. SIRO CLINPHARM P.LTD, MUMBAI

In the result, appeal of the assessee is allowed

92D and 92E, "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 or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such

SIRO CLINPHARM P. LTD,MUMBAI vs. DCIT CIR 3(3), MUMBAI

In the result, appeal of the assessee is allowed

92D and 92E, "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 or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 14 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16. The argument of the ld AR is that the assessee's case would get covered under the exception

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 14 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16. The argument of the ld AR is that the assessee's case would get covered under the exception

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 14 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16. The argument of the ld AR is that the assessee's case would get covered under the exception

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 14 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16. The argument of the ld AR is that the assessee's case would get covered under the exception

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. 14 ITA 3747, 3751, 3753, 3752 and 5677/Mum/2024 Cornerstone Ondemand Limited 16. The argument of the ld AR is that the assessee's case would get covered under the exception