ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

reopened by issuing notice under section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing

VODAFONE INDIA LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-8(3)(2), MUMBAI

transferring pre-paid talk time and connections and\naccordingly the discount extended was not income earned by the\ndistributors.\n7.2. In the Draft Assessment Order, dated 31/03/2015, the Assessing\nOfficer proposed disallowance under Section 40(a)(ia) of the Act\non the upfront discount extended to the pre-paid distributors by\nterming the arrangement as 'Principal to Agent instead

DCIT CC 4(4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX- CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT CC 4 (4), MUMBAI, MUMBAI vs. SANMAN TRADE IMPEX LIMITED, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

SANMAN TRADE IMPEX LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-CENTRAL CIRCLE 4(4), MUMBAI, MUMBAI

In the result, appeals of the Revenue are dismissed dismissed whereas appeals of the assessee are partly allowed appeals of the assessee are partly allowed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

reopening of the assessment and therefore, contention of the contention of the assessee are liable to be rejected assessee are liable to be rejected. 12.3 We have heard rival submission o We have heard rival submission of the parties and perused the f the parties and perused the relevant material on record. In our opinion, the contention raised by relevant

DCIT 8(3)(2), MUMBAI vs. M/S VODAFONE IDEA LIMITED (EARLIER KNOWN AS VODAFONE INDIA LIMITED WHICH NOW STANDS MERGED WITH IDEA CELLULAR LIMITED (ICL) AND CONSEQUENTLY KNOWN AS VODAFONE IDEA LIMITED), MUMBAI

transferring pre-paid talk time and connections and\naccordingly the discount extended was not income earned by the\ndistributors.\n7.2. In the Draft Assessment Order, dated 31/03/2015, the Assessing\nOfficer proposed disallowance under Section 40(a)(ia) of the Act\non the upfront discount extended to the pre-paid distributors by\nterming the arrangement as 'Principal to Agent instead

ACIT, MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

assessment proceedings, the ld TPO computed interest on these NCCPS by re-characterizing it as loan. but omitted to disallow the capital loss on redemption on NCCPS. 10.2 The Assessing Officer reopened the assessment on this issue by recording reasons as under: Reliance Industries Ltd 59 ITA No. 3705/MUM/2024 & CO No. 153/MUM/2024 "2.3. Further, it was observed that while computing

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reopened on the ground that income had escaped assessment on a certain issue, the Assessing Officer could not make an assessment or reassessment on another issue which came to his notice during the proceedings. This interpretation will no longer hold the field after the insertion of the Explanation 3 by the Finance (No. 2) Act, 2009. However, the Explanation

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reopened on the ground that income had escaped assessment on a certain issue, the Assessing Officer could not make an assessment or reassessment on another issue which came to his notice during the proceedings. This interpretation will no longer hold the field after the insertion of the Explanation 3 by the Finance (No. 2) Act, 2009. However, the Explanation

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

reopened on the ground that income had escaped assessment on a certain issue, the Assessing Officer could not make an assessment or reassessment on another issue which came to his notice during the proceedings. This interpretation will no longer hold the field after the insertion of the Explanation 3 by the Finance (No. 2) Act, 2009. However, the Explanation

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed

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

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed

M/S. SOHAM ESTATE,MUMBAI vs. DCIT, CC-1, THANE

transfer pricing. In such circumstances, the Division Bench of this Court, set aside the assessment order by observing that the Court was unable to understand how the Assessing Officer could, at all, exercise the jurisdiction and enter upon an inquiry on the reopening