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

Transfer Pricing Officer, we do not intend to deal with the acceptability or otherwise of the rest of the comparables disputed before us under ITES segment and leave the issue relating to comparability of these comparables open for adjudication if they arise in any other assessment year in future. 84. Ground no.7, of this appeal is identical to ground no.6

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer

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

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

100% owned by ATL-Mauritius and, therefore, the transactions amongst them cannot be considered as between unrelated entities, and the same are not uncontrolled transactions. Therefore, on this singular aspect the action of the Transfer Pricing Officer in selecting RPM as the most appropriate method is wholly inappropriate and wrong. So however, we find that the Transfer Pricing Officer

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

100. The Transfer Pricing Officer erroneously interpreted the CBDT circular no.742 r/w Circular no.765, and was of the opinion that the commission should have been paid @ 10% and accordingly, the Transfer Pricing Officer made adjustment @ 5%. 101. Before us, the learned A.R. for the assessee submitted that under old business model, the assessee was also earning 15% commission from A.Es

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

DCIT CIR 3(1), MUMBAI vs. GLOBE OP FINANCIAL SERVICES (INDIA) P. LTD, MUMBAI

In the result, Department’s appeal is partly allowed for statistical purposes

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

section 143(3) adding the amount of ` 2,62,84,830. Being aggrieved of the assessment order so passed, the assessee preferred appeal before the first appellate authority. 4. The learned Commissioner (Appeals), after considering the submissions of the assessee and on a perusal of the material on record, accepted the contention of the assessee that two companies selected

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

In the result, appeal of the assessee is allowed

transfer pricing in United States because it is a service but because it is covered by the specific definition discussed above. As a matter of fact, David S Miller, in a paper titled 'Federal Income Tax Consequences of Guarantees; A Comprehensive Framework for Analysis' published in the 'The American Lawyer Vol. 48, No. 1 (Fall