THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings. Reasons to believe recorded by the ld. Assessing Officer does not advert to any fresh tangible material which has come in his possession after the conclusion of the original assessment proceedings. They only make reference to the Assessment Order for AY 2014-15 and notes to account to the financial statement which in no way constitute fresh tangible

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings. Reasons to believe recorded by the ld. Assessing Officer does not advert to any fresh tangible material which has come in his possession after the conclusion of the original assessment proceedings. They only make reference to the Assessment Order for AY 2014-15 and notes to account to the financial statement which in no way constitute fresh tangible

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

reassessment proceedings. Reasons to believe recorded by the ld. Assessing Officer does not advert to any fresh tangible material which has come in his possession after the conclusion of the original assessment proceedings. They only make reference to the Assessment Order for AY 2014-15 and notes to account to the financial statement which in no way constitute fresh tangible

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

SHELL INDIA MARKETS P.LTD,MUMBAI vs. CIT LTU, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri R.C. Sharma (A.M.) & Shri Pawan Singh (Jm) Shell India Markets Pvt Ltd Vs Commissioner Of Income-Tax- Trent House, First Floor, Large Tax Units (Ltu) G-Block, Plot No.C-60, Mumbai Bandra Kurla Complex, Bandra (E) Mumbai-400 051 Pan : Aaics1404P Appellant Respondednt

3) r.w.s. 147. The Ld.AR submits that the AO, after considering the explanation furnished by the assessee has passed the assessment order after his full satisfaction though there is no reference about the examination of issue in the assessment order. The Ld.AR submits that once the AO raised query, queries raised by AO was duly replied and AO passed

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISE LIMITED,HYDERABAD vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED ,MUMBAI vs. THE PCIT(CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED,MUMBAI vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED,MUMBAI vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED,TELANGANA vs. THE PCIT,(CENTRAL)-MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED ,TELAGANA vs. THE PCIT (CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISES LIMITED,TELANGANA vs. THE PCIT (CENTRAL),MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

SOMA ENTERPRISE LIMITED,MUMBAI vs. THE PCIT (CENTRAL), MUMBAI-1, MUMBAI

In the result, all the appeals of the assessee are partly allowed

147 of the Act dated 05/12/2017. In this reassessment, TDS credit of Rs.48,55,95,799/- was granted to the assessee as against Rs.48,60,04,836/- already granted by the ld. AO vide 154 order dated 03/09/2014. 5.5. Subsequently the second search u/s.132 of the Act took place in the premises of the assessee alongwith ABIL group on 21/07/2017

DCIT(IT)-2(2)(2), AIR INDIA BUILDING vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

In the result, appeals by the revenue are accordingly dismissed\nand those by the assessee are allowed

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered

DCIT(IT) - 2(2)(2), AIR INDIA BUILDING vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

92C of tlie Income-tax Act, 1961 ('The Act'). Based on the said study, having regard to commercial\nand cronomic lactors, the amount paid/payable or received receivable in respect of the above transaction has been computed by the assessee, having regard\nto the arm's length price.\nNuto'st Seeneding to the assestre, the above mentioned transactione has been entered