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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

107; (iv) TNM method working for the last three years submitted to the Transfer Pricing Officer vide letter dated 07/10/2011, placed at pages 110 of the Paper Book. The Ld. Representative for the assessee pointed out that the above information was submitted at the instance of the Transfer Pricing Officer himself, which clearly demonstrates that the TNM method workings have

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

107. The DRP confirmed the Transfer Pricing Officer‟s action. 108. Before us, the learned A.R. for the assessee submitted that the Transfer Pricing Officer failed to appreciate that the arm's length principle is based on comparison of the conditions in a controlled transaction with the conditions in transaction between two independent enterprises i.e., uncontrolled transaction. He further submitted

SABMILLER INDIA LTD,MUMBAI vs. ASST CIT CIR 11(1)(2), MUMBAI

In the result, Revenue’s appeal is dismissed

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

section 92 of the Act, he submitted, it empowers the Assessing Officer to determine the arm's length price of benefit, service or facilities. He submitted, there is no restriction imposed on the Transfer Pricing Officer to only determine the arm's length price or cost of expenditure allocated. He submitted, the cost or expenditure allocated or apportioned

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

In the result, appeal of the assessee is allowed

section 92B by the Finance Act, 2012, with retrospective effect from 01.04.2002. Accordingly with such amendment now there is no dispute that the “Guarantee” is an international transaction. iv. The appellant in its submission has relied upon the decision of the Hon’ble ITAT Hyderabad Bench in the case of Four Soft Limited (142 TTJ 358). In this regard

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

In the result, appeal of the assessee is allowed

section 92B by the Finance Act, 2012, with retrospective effect from 01.04.2002. Accordingly with such amendment now there is no dispute that the “Guarantee” is an international transaction. iv. The appellant in its submission has relied upon the decision of the Hon’ble ITAT Hyderabad Bench in the case of Four Soft Limited (142 TTJ 358). In this regard

DCIT RG 8(2), MUMBAI vs. INDIA MEDTRONIC P. LTD, BARODA

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

107 ITD 141 (Gang.)(SB). Thus, he submitted, the issue has to be restored back to the Assessing Officer / Transfer Pricing Officer for undertaking a fresh benchmarking by applying RPM. Without prejudice, he submitted, the comparables selected by the assessee under TNMM are not good comparables. Therefore, if TNMM is accepted as the most appropriate method, the issue relating

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

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

price at which the shares are issued to the employees in order to compensate the payout obligation which might arise on ESOP shares either at buyback or at liquidation. 9.10 Allowability of ESOP expense in the income Tax Act- There is no specific section under which ESOP expenditure is allowable under the Income Tax Act 1961 ('Act). The only provision

DCIT CIR 1, THANE vs. LAXCESS INDIA P.LTD, THANE

In the result, the appeal of the assessee

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

section 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in agreement with the working made by the assessee. The agreement with the working made by the assessee. The agreement with the working made

LANXESS INDIA P.LTD,THANE vs. DCIT CIR 1, THANE

In the result, the appeal of the assessee

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

section 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in 92C(2) of the IT Act is concerned, we are not in agreement with the working made by the assessee. The agreement with the working made by the assessee. The agreement with the working made