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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112/-. The assessee is aggrieved with that order as per ground no.1 and ground no.2, only transfer pricing adjustments are under challenge before us. The learned Authorised Representative with respect to the addition of ₹24,18,705 on sale of finished goods reiterated the same argument as were advanced before us on this ground for A.Y. 2008-09. With respect

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

112. Ground no.8, relates to transfer pricing adjustment on account of finance cost on reimbursement receipts of carriage expenses, marketing & other expenses and travelling & other expenses at ` 99,81,739 (under both Business Models). 113. During the Transfer Pricing proceedings, the Transfer Pricing Officer asked time lag in receipt of the reimbursement of expenses from the A.Es. The assessee submitted

THE ACIT RG 10(1), MUMBAI vs. M/S. NETAFIM IRRIGATION INDIA P. LTD, MUMBAI

In the result, appeals are dismissed

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

112. 12. Without prejudice to his submission that the Transfer Pricing Officer has not applied CUP, he submitted, for benchmarking the payment of royalty CUP is not the most appropriate method. He submitted, if the Transfer Pricing Officer was of the view that CPM is not the most appropriate method, he could have determined the arm's length price

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

BHAVANI GEMS P. LTD.,MUMBAI vs. PR. CIT -5, MUMBAI

Accordingly, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm Bhavani Gems Private Limited The Pr. Commissioner Of Income Dw–1370, G–Block West Core, Tax–5, Room No. 515, 5Th Floor, Bharat Diamond Bourse, Bandra Aayakar Bhavan, M.K. Road, Vs. Kurla Complex, Bandra (East), Mumbai–400 020 Mumbai–400 051 (Appellant) (Respondent) Pan No. Aaecb9471D

section 142(1) of the Act dated 06.02.2018 vide Para 3 sought for various details of income transactions along with 3CEB report. Further his notice dated 30.08.2018 also called for the foreign remittances vide Para 14 and 18. These two notices were replied vide letter dated 22.09.2017 & 07.05.2018. iii. He further referred to circular dated 10.03.2016, which was in replacement

INFINITY RETAIL LTD,MUMBAI vs. DCIT RG 10(1)(1), MUMBAI

The appeals are partly allowed

transfer pricing adjustment of Rs.40,07,005 pertaining to reimbursement of out of pocket expenses and reimbursement of software maintenance expenses to its Associated Enterprise ("AE"), alleging the same is not at arm's length in terms of the provisions of Sections 92C(1) and 92C(2) of the Income-tax Act, 1961 ("Act") read with Rule

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

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

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

section 14A regardless of whether they are direct or indirect, fixed or variable and managerial or financial in accordance with law. It is further evident that deduction in respect of expenditure incurred by the assessee in relation to exempt income and taxable income has to be determined as per mechanism laid down in section 14A and in accordance with

ITO 10(3)(4), MUMBAI vs. KEYSTONE SOLUTION P. LTD, MUMBAI

In the result, appeal stands partly allowed for statistical purpose

Bench: Shri Saktijit Dey & Shri Ramit Kochar

section 92CA(3) of the Act, the Assessing Officer passed the assessment order adding the transfer pricing adjustment proposed by the Transfer Pricing Officer. Being aggrieved with 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 was convinced that

CAPGEMINI INDIA P.LTD,BHIWANDI vs. DCIT CIR 10(2), MUMBAI

In the result ground number 12 of the appeal of the assessee is allowed with above directions

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am Capgemini India Pvt. Ltd. The Dy. Commissioner Of C/O Kalyaniwalla & Mistry, Income Tax, Army & Navy Bldg, Circle 10(2), 3Rd Floor, R. No. 475, Vs. 148, M.G. Road, Ayakar Bhavan, Fort, M.K. Road, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaack2632B Appellant By : Shri M M Golvala, Ar Respondent By : Ms. Vatsalaa Jha, Cit Dr Date Of Hearing: 15.02.2022 Date Of Pronouncement : 12.05.2022

112% of the total amount of cost and expenses incurred by assessee. He referred to page no. 114 of the Paper Book which is a letter dated 7th November, 2013 addressed to the Transfer Pricing Officer wherein it was explained that the reimbursement of expenditure are of the nature of travel expenses, accommodation expenses, visa expenses, communication expenses, meal expenses

ESSAR INVESTMENTS LTD,MUMBAI vs. DCIT 5(1), MUMBAI

In the result, the present appeal is partly allowed

section 56 and never intended for arriving at a fair market value for comparing an international transaction. 19. It is to be noted that Ld. Counsel for the Assessee, did submit that if the CUP method and CCI guidelines method suggested by the assessee were not acceptable, DCF method could be adopted but with certain riders. His objections were with