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273 results for “transfer pricing”+ Section 111clear

Sorted by relevance

Mumbai273Delhi225Chennai83Bangalore73Hyderabad71Cochin57Jaipur54Chandigarh28Kolkata26Rajkot19Indore19SC18Raipur17Ahmedabad17Agra14Pune13Jodhpur12Visakhapatnam11Lucknow10Cuttack9Nagpur7Surat5Allahabad3Dehradun1Amritsar1Ranchi1D.K. JAIN JAGDISH SINGH KHEHAR1

Key Topics

Section 14A62Disallowance62Section 143(3)52Deduction45Addition to Income44Section 115J29Section 3520Depreciation20Section 4018

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)

111 to 114 of the order with the following observations: - Page No. 22 ITA NO. 752 & 2541/MUM/2022 (A.Y. 2017-18 & 2018-19) Thomas Cook (India) Limited “2) Whether the re-characterization of transaction and adjustment of interest is permissible for the year under consideration: a) The assessee totally ignored the basic tenet of transfer pricing as enshrined in section

DCIT 15(1)(2), MUMBAI vs. COLGATE PALMOLIVE (INDIA) LTD., MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 2799/MUM/2016[2011-12]Status: Disposed

Showing 1–20 of 273 · Page 1 of 14

...
Section 25017
Section 35D17
Transfer Pricing17
ITAT Mumbai
11 Apr 2023
AY 2011-12

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

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

111,900/–. For determination of the arm's-length price of international transaction, the learned transfer pricing officer passed the order under section

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 3488/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Apr 2023AY 2011-12

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

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

111,900/–. For determination of the arm's-length price of international transaction, the learned transfer pricing officer passed the order under section

COLGATE -PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 1977/MUM/2017[2012-13]Status: DisposedITAT Mumbai11 Apr 2023AY 2012-13

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

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

111,900/–. For determination of the arm's-length price of international transaction, the learned transfer pricing officer passed the order under section

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

ITA 75/MUM/2018[2013-14]Status: DisposedITAT Mumbai11 Apr 2023AY 2013-14

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

For Appellant: Shri Madhur AgrawalFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 115JSection 143(3)Section 144CSection 14ASection 80ISection 92C

111,900/–. For determination of the arm's-length price of international transaction, the learned transfer pricing officer passed the order under section

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

ITA 2266/MUM/2022[2017-18]Status: DisposedITAT Mumbai17 Apr 2023AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 115JSection 14ASection 928Section 92B

111 taxmann.com 94 in case of Swanand properties private limited was only with respect to applicability of provisions of section 43CA of The act for assessment year 2005 – 06 wherein it has been held that this provisions are applicable only with effect from 1/4/2014. Therefore, it does not help the case of the revenue. 046. Accordingly we hold that

MACROTECH DEVELOPRS LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

ITA 2239/MUM/2022[2018-19]Status: DisposedITAT Mumbai17 Apr 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 115JSection 14ASection 928Section 92B

111 taxmann.com 94 in case of Swanand properties private limited was only with respect to applicability of provisions of section 43CA of The act for assessment year 2005 – 06 wherein it has been held that this provisions are applicable only with effect from 1/4/2014. Therefore, it does not help the case of the revenue. 046. Accordingly we hold that

GREAVES COTTON LTD,MUMBAI vs. ASST CIT 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

ITA 1745/MUM/2016[2011-12]Status: DisposedITAT Mumbai25 Jul 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

transfer pricing adjustment of ₹ 2,678,899 is restored back to the file of the learned TPO/AO. 022. Coming to ground number B which is against the short- term capital gain treated as business income amounting to ₹ 23,870,858 on account of redemption of the units of the mutual fund. The fact shows that assessee is engaged

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

ITA 2069/MUM/2017[2012-13]Status: DisposedITAT Mumbai25 Jul 2023AY 2012-13

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

transfer pricing adjustment of ₹ 2,678,899 is restored back to the file of the learned TPO/AO. 022. Coming to ground number B which is against the short- term capital gain treated as business income amounting to ₹ 23,870,858 on account of redemption of the units of the mutual fund. The fact shows that assessee is engaged

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

ITA 7166/MUM/2017[2013-14]Status: DisposedITAT Mumbai25 Jul 2023AY 2013-14

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

transfer pricing adjustment of ₹ 2,678,899 is restored back to the file of the learned TPO/AO. 022. Coming to ground number B which is against the short- term capital gain treated as business income amounting to ₹ 23,870,858 on account of redemption of the units of the mutual fund. The fact shows that assessee is engaged

GREAVES COTTON LTD,MUMBAI vs. ASST CIT CIR 7(1)(1), MUMBAI

In the result appeal for assessment year 2012 –

ITA 6560/MUM/2018[2014-15]Status: DisposedITAT Mumbai25 Jul 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

For Appellant: Ms. Aarti Vissanji, Ms. Aastha &
Section 144CSection 35Section 92CSection 92C(3)Section 92F

transfer pricing adjustment of ₹ 2,678,899 is restored back to the file of the learned TPO/AO. 022. Coming to ground number B which is against the short- term capital gain treated as business income amounting to ₹ 23,870,858 on account of redemption of the units of the mutual fund. The fact shows that assessee is engaged

HSBC SECURITIES AND CAPITAL MARKETS (I) P.LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

ITA 702/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Mar 2023AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: Ms. Samruddhi Dhananjay Hande, Sr. DRFor Respondent: Sh. Porus Kaka / Tejas Mhatre
Section 143(3)Section 92CSection 92D

transfer pricing study report prepared and maintained as per section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules"). On the facts and in the circumstances of the case and in law, the TPO/AO erred in resorting to cherry-picking of comparables based on conjectures and surmises with complete disregard to the differences

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P. LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

ITA 4459/MUM/2014[2006-07]Status: DisposedITAT Mumbai10 Mar 2023AY 2006-07

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: Ms. Samruddhi Dhananjay Hande, Sr. DRFor Respondent: Sh. Porus Kaka / Tejas Mhatre
Section 143(3)Section 92CSection 92D

transfer pricing study report prepared and maintained as per section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules"). On the facts and in the circumstances of the case and in law, the TPO/AO erred in resorting to cherry-picking of comparables based on conjectures and surmises with complete disregard to the differences

DCIT 4(1), MUMBAI vs. HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P.LTD, MUMBAI

In the result, appeal filed by the assessee is allowed

ITA 1661/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Mar 2023AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: Ms. Samruddhi Dhananjay Hande, Sr. DRFor Respondent: Sh. Porus Kaka / Tejas Mhatre
Section 143(3)Section 92CSection 92D

transfer pricing study report prepared and maintained as per section 92D of the Act read with Rule 10D of the Income-tax Rules, 1962 ('the Rules"). On the facts and in the circumstances of the case and in law, the TPO/AO erred in resorting to cherry-picking of comparables based on conjectures and surmises with complete disregard to the differences

ACIT, MUMBAI vs. DNJ CREATION LLP, MUMBAI

In the result, grounds of appeal raised by revenue are dismissed

ITA 4329/MUM/2025[2017]Status: DisposedITAT Mumbai13 Feb 2026

Bench: Shri Pawan Singh& Shri Girish Agrawal(Physical Hearing)

Section 10ASection 143(3)Section 254(1)Section 92C

Transfer Pricing order u/s 92CA(3) and the consequential addition in the assessment order u/s 143(3) are untenable and unsustainable in law. 2. The Hon'ble CIT(A) erred in not adjudicating on the issue where the learned AO/TPO wrongly applied the differential OP/OR margin of 8.76% (11.70% minus 2.94%) on the entire operating revenue

CABOT INDIA LTD,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 1842/MUM/2016[2006-07]Status: DisposedITAT Mumbai21 Aug 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

DCIT, 1(1)(1), MUMBAI vs. CABOT INDIA LTD., NAVI MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 2595/MUM/2016[2010-11]Status: DisposedITAT Mumbai21 Aug 2023AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

ASST CIT 15(1)(2), MUMBAI vs. CABOT INDIA LTD, NAVI MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 1911/MUM/2016[2011-12]Status: DisposedITAT Mumbai21 Aug 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 7496/MUM/2012[2008-09]Status: DisposedITAT Mumbai21 Aug 2023AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

ITA 2539/MUM/2014[2007-08]Status: DisposedITAT Mumbai21 Aug 2023AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Mr. Percy J Pardiwala Sr AdvFor Respondent: Ms. Samruddhi Hande, Sr.AR
Section 143Section 92C

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments