ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

business model of the company being different, it cannot be treated as a comparable. 9. We have considered rival submissions and perused materials on record. As could be seen from Page–18 of the Transfer Pricing Officer’s order, he has applied certain filters for selecting comparables from the data bases. One of the filter applied by the Transfer Pricing

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

pricing order passed by Additional Commissioner of\nIncome-tax (Transfer Pricing) - 1(3), Mumbai is beyond jurisdiction -\nThe ground was not pressed\n1. Reference to the Additional Commissioner of Income-Tax (Transfer\nPricing) - 1(3), Mumbai and the transfer pricing order under section\n92CA(3) of the Act passed by the Additional Commissioner of Income-Tax\n(Transfer Pricing

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

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

income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 sale of pharmaceutical products. With respect to the benchmarking

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

income filter applied by the Transfer Pricing Officer. Further, drawing our attention to the website extract of the company, he submitted, it provides digital content service which is in the nature of ITES as per CBDT Notification no.S.O. 890(E) dated 26th September 2000. Thus, he submitted, the company being functionally different cannot be treated as comparable. In support

ACIT CIRCLE 5(1)(1), MUMBAI vs. M/S ESSAR SHIPPING LIMITED, MUMBAI

In the result, appeal filed by the learned AO is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm M/S Essar Shipping Limited Acit, Circle 5(1)(1) Essar House, 11, R.No.568, Aaykar Bhavan, Vs. Kk Marg, Mahalaxmi, M.K. Road, Mumbai-400 020 Mumbai-400 034 (Appellant) (Respondent) Pan No. Aacce3707D

transfer pricing provisions envisage computation of income from specified international transactions of receipt or expenditure, ofcourse with reference to the stated price of such transactions. This is completely in contrast to Chapter-XII G, where the stated price of the transaction has no relevance to the computation of income of qualifying ships, which is based on the weight

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 Officer has power under the statute to determine the arm's length price of international transaction on estimate basis by weighing in the business expediency factor. In our considered opinion the legal principle on the issue is quite clear. As could be seen from the scheme of the Income

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

Transfer Pricing Officer was added back to the income of the assessee in the draft assessment order. Though, the assessee raised objections before learned DRP mainly with regard to selection/rejection of comparables, however, learned DRP did not find merit in the objections of the assessee. 12. Before us, the dispute is mainly confined to the selection/rejection of comparables. Hereinafter

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

Business and Profession', of Rs.6,43,439/-, as computed under Chapter XIIG of the Income tax Act, 1961 (i.e. Tonnage Tax Scheme). An adjustment was proposed by the Transfer Pricing

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 adjustment on account of commission paid to the A.E. from income from advertisement sales at ` 15,23,923, and advertisement sales–website at ` 75,881 totaling to ` 15,99,804, under the new business