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938 results for “transfer pricing”+ Deemed Dividendclear

Sorted by relevance

Mumbai938Delhi508Kolkata190Bangalore188Ahmedabad149Chennai135Hyderabad103Chandigarh96Cochin80Pune63Jaipur45Raipur31Indore25Lucknow22Calcutta17Surat15SC13Agra9Karnataka9Visakhapatnam8Cuttack7Telangana5Varanasi5Rajkot4Guwahati3Jodhpur2Panaji2Rajasthan2Orissa1Ranchi1Nagpur1A.K. SIKRI ROHINTON FALI NARIMAN1Jabalpur1Amritsar1Allahabad1

Key Topics

Section 14A119Addition to Income62Disallowance51Section 143(3)47Section 115J37Section 69C30Section 1120Deduction16Section 143(2)15

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

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

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

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

Section 143(3)Section 144C(5)

Dividend paid 77,457,379 Other method Total 1,42,15,38,501 10 Purchase of raw materials 122,057,695 TNMM 11 Payment of Rent 2,820,000 Other Method 12 Payment of managerial 21,146,231 Other Method remuneration / professional fee Total 146,023,926 5 ITA 6081/Mum/2018 3. The assessee has filed its return of income

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: Disposed

Showing 1–20 of 938 · Page 1 of 47

...
Section 6815
Section 10(1)15
Transfer Pricing14
ITAT Mumbai
05 May 2017
AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

dividend income was disallowed on account of the overhead expenses incurred towards administrative expenses. On this aspect, we find that the Assessing Officer has adequately brought out that during the year assessee has undertaken activities, which involve taking investment decisions and, therefore, some amount of management/administrative costs are liable to be attributed to such activity. Considering the entirety of circumstances

M/S. MERCATOR LTD,MUMBAI vs. THE DY CIT 5(2), MUMBAI

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

ITA 7278/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Dec 2022AY 2010-11

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

For Appellant: Mr.Nikhil Tiwari.ARFor Respondent: Mr.KrishnaKumarMishra.DR
Section 143(3)Section 14ASection 250

deem fit be granted. Each of the above 29/Mum/2018 & CO No. 21/Mum/2019 M/s. Mercator Ltd, Mumbai. ground is independent and without prejudice to one another. The Appellant craves leave to add, to alter, to amend or to delete any or all of the above grounds of appeal, at or prior to hearing of the appeal, so as to enable your

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

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

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

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

transfer pricing regulations do not apply to the assessee, to the extent of operations carried out through operating qualifying ships, since the assessee is a company registered under the Tonnage Tax Scheme ('TTS') provided under the Act. The facts in the year under consideration are not different from those in assessment years 2007-08 and 2011-12, where the very

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

ITA 1218/MUM/2021[2016-17]Status: DisposedITAT Mumbai24 Nov 2023AY 2016-17

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

Section 92CSection 92C(3)

deemed receivable is clearly tantamount to applying transfer pricing provision to notional transaction, which is beyond TPO's jurisdiction as prescribed under section 92CA. Hence, the said proposal is bad in law, void-ab-initio and non-est in the eyes of law. Page No. 18 ITA NO. 752 & 2541/MUM/2022 (A.Y. 2017-18 & 2018-19) Thomas Cook (India) Limited

PRUDENTIAL PROCESS MANAGEMENT SERVICES INDIA P.LTD,MUMBAI vs. DCIT RG 10(3), MUMBAI

In the result, the assessee’s appeal is allowed for statistical purpose and the Revenue’s appeal and cross objection by the assessee stands dismissed

ITA 1274/MUM/2014[2009-10]Status: DisposedITAT Mumbai13 Apr 2018AY 2009-10

Bench: Shri Shamim Yahya, Am & Shri Pawan Singh, Jm आयकर अपील सं./I.T.A. No. 1274/Mum/2014 ("नधा"रण वष" / Assessment Year: 2009-10) & Co No. 102/Mum/2014 (Arising Out Of Ita No. 2131/Mum/2014) ("नधा"रण वष" / Assessment Year: 2009-10) Prudential Process Management The Dy. Commissioner Of Income Services India Private Limited, Tax, Range-10(3), बनाम/ Prudential Centre Avenue, Aayakar Bhavan, M. K. Road, Vs. Hiranandani Business Park, Mumbai-400 020 Powai, Mumbai-400 076 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aaccp 7204 Q (Assessee) (Revenue) : & आयकर अपील सं./I.T.A. No. 2131/Mum/2014 ("नधा"रण वष" / Assessment Year: 2009-10) The Dy. Commissioner Of Income Prudential Process Management Tax, Range-10(3), Services India Private Limited, बनाम/ Room No. 451, 4Th Floor, Prudential Centre Avenue, Vs. Aayakar Bhavan, M. K. Road, Hiranandani Business Park, Mumbai-400 020 Powai, Mumbai-400 076 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aaccp 7204 Q (Revenue) : (Assessee) : Shri Percy J. Pardiwala/ Assessee By Shri Madhur Agrawal Revenue By : Shri Jayant Kumar/ Shri V. Jenardhanan सुनवाई क" तार"ख / : 21.12.2017 & 23.03.2018 Date Of Hearing घोषणा क" तार"ख / : 13.04.2018 Date Of Pronouncement

For Respondent: Shri Jayant Kumar/
Section 143(3)Section 50BSection 92C

dividends; to the assessee company. As already discussed and established that the assessee company was posting good profits on the said business there was no need for it to undervalue the company and transfer the same to Capita India Pvt. Ltd. at a price much below the market rate. Therefore, there is a definite and certain Connection between the transaction

DCIT CIR 6(1), MUMBAI vs. AEGIS LTD, MUMBAI

In the result, whereas appeal of the assessee is partly allowed, that of the Revenue is dismissed

ITA 1209/MUM/2015[2010-11]Status: DisposedITAT Mumbai08 Feb 2017AY 2010-11

Bench: Shri G.S.Pannu & Shri Sandeep Gosainaegis Limited, Essar Techno Park, Old Swan Mill Compound, Lbs Marg, Kurla (W), Mumbai 400 070 Pan:Aaace 8354Q ...... Appellant

For Appellant: S/Shri Rajan Vora/For Respondent: Shri N.K.Chand
Section 143(3)Section 92CSection 92C(2)

dividend. The Transfer Pricing Officer also observed that assessee had a running account with the said associated enterprise, in terms of which monies were being advanced as and when the need arose. Considering the nature and frequency of transactions in the running account with the associated enterprise, the Transfer Pricing Officer inferred that the loan and not as subscription

AEGIS LTD,MUMBAI vs. DCIT RG 5(1), MUMBAI

In the result, whereas appeal of the assessee is partly allowed, that of the Revenue is dismissed

ITA 7694/MUM/2014[2010-11]Status: DisposedITAT Mumbai08 Feb 2017AY 2010-11

Bench: Shri G.S.Pannu & Shri Sandeep Gosainaegis Limited, Essar Techno Park, Old Swan Mill Compound, Lbs Marg, Kurla (W), Mumbai 400 070 Pan:Aaace 8354Q ...... Appellant

For Appellant: S/Shri Rajan Vora/For Respondent: Shri N.K.Chand
Section 143(3)Section 92CSection 92C(2)

dividend. The Transfer Pricing Officer also observed that assessee had a running account with the said associated enterprise, in terms of which monies were being advanced as and when the need arose. Considering the nature and frequency of transactions in the running account with the associated enterprise, the Transfer Pricing Officer inferred that the loan and not as subscription

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

ITA 1518/MUM/2025[2018-19]Status: DisposedITAT Mumbai30 Dec 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Girish Agrawal

For Appellant: Shri Porus Kaka, Sr. Advocate and Shri Manish Kumar Kanth, AdvocateFor Respondent: Shri Ajay Chandra, CIT DR
Section 1Section 92CSection 92C(3)

transferred company, i.e., Tata Sons Ltd. He also pointed out to the difference in logo and trade mark as noted by ld. TPO in his order. It was thus, contended that brand of “Tata Consultancy Services” is owned by the assessee and not by Tata Sons Ltd. Thus, assessee has got its own brand value and has incorporated its valuation

M/S. STRIDES ARCOLAB LTD.,NAVI MUMBAI vs. ITO - 10(3)(4), MUMBAI

In the result, assessee’s cross objection is partly allowed

ITA 641/MUM/2007[2003-2004]Status: DisposedITAT Mumbai29 Apr 2016AY 2003-2004

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri Nitesh JoshiFor Respondent: Shri N.K. Chand
Section 115JSection 35

Transfer Pricing Officer to compute the interest on the interest free advances paid to the A.E. Ground no.5, is partly allowed. 41. In the result, assessee’s appeal is partly allowed. ITA no.274/Mum./2007 – Department’s Appeal C.O. no.121/Mum./2007 – Assessee’s Cross Objection 42. Ground no.1, in Department’s appeal corresponding to ground raised by the assessee

ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2862/MUM/2009[2006-07]Status: DisposedITAT Mumbai30 Nov 2022AY 2006-07

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ACIT CEN CI-43 vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 10/MUM/2009[2004-2005]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-2005

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4293/MUM/2009[2002-03]Status: DisposedITAT Mumbai30 Nov 2022AY 2002-03

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2863/MUM/2009[2007-08]Status: DisposedITAT Mumbai30 Nov 2022AY 2007-08

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4294/MUM/2009[2004-05]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-05

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 4295/MUM/2009[2007-08]Status: DisposedITAT Mumbai30 Nov 2022AY 2007-08

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2859/MUM/2009[2002-03]Status: DisposedITAT Mumbai30 Nov 2022AY 2002-03

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

ITA 2860/MUM/2009[2004-05]Status: DisposedITAT Mumbai30 Nov 2022AY 2004-05

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

Section 143Section 143(3)Section 153ASection 80HSection 80ISection 92C

deem it necessary to enter into this controversy and express our view as regards the same.” 10.10 The Tribunal in the case of the assessee for assessment year 2010-11 in ITA No. 1991/Mum/2016 on the issue of interest rate to be charged in case of international transactions of the loan, held as under: "4.2 In appeal

HINDUSTAN DORR-OLIVER LTD,MUMBAI vs. ACIT-10(1)(1), MUMBAI

The appeal is dismissed

ITA 7116/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Apr 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm The Asst. Commissioner Of Hindustan Dorr-Oliver Ltd. Income Tax, 10(1)(1), Chakala, Andheri (E), R.No.209, Vs. Mumbai-400 009 Aayakar Bhavan, M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaach0964P

For Appellant: NoneFor Respondent: Shri Dr. Yogesh Kamat, CIT DR
Section 143(3)Section 144C(13)Section 40A(2)Section 40A(2)(b)Section 92(2)Section 92BSection 92C

dividend income of Rs. 1,12,635/-and claimed same as exempt u/s 10 (34) of the act stopped the assessing officer asked the assessee that why disallowance u/s 14 A of the act read with rule 8D should not be made. Assessee submitted of working of disallowance under section 14A of the act of Rs. 69,53,433/- under

TATA CHEMICALS LTD,MUMBAI vs. ADDL CIAT 2(3), MUMBAI

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

ITA 120/MUM/2013[2008-09]Status: DisposedITAT Mumbai10 Nov 2023AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 144C(5)Section 14ASection 43BSection 80

Transfer Pricing Officer / Assessing Officer. The observation of the Ld. DRP is reproduced below: - 3.3 Directions: We have considered the relevant facts and the contentions of the assessee and find that the AO has made an addition on account of expenditure u/s.14A. This is evidence enough that the AO is not satisfied with the calculation of the estimation