DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI, MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.), MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

Transfer Pricing Officer observed that the assessee was unable to establish that it has received any benefit due to the cost incurred by the AEs. Accordingly, he concluded that since the assessee has failed to establish the benefit derived relating to the cost incurred by the AEs on various account, the arm's length price of such transaction

CITIGROUP GLOBAL MARKETS (INDIA) PRIVATE LIMITED,MUMBAI vs. DCIT, CIRCLE-4(1), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Citigroup Global Markets (India) Private Limited The Dcit 1402, 14Th Floor, Circle -4(1), First International Financial Aaykar Bhavan Centre, Vs. M.K. Road, Bandra Kurla Complex, Mumbai-400 020 G Block, Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No.Aaecs7234F Citigroup Global Markets (India) The Jcit (Osd) Private Limited 4(1)(1) 1402, 14Th Floor, Room No. 640, 6 Th Floor, First International Financial Aaykar Bhavan, Centre, Vs. M.K. Road, Bandra Kurla Complex, G Block, Bandra (East), Mumbai-400 020 Mumbai-400 051 (Appellant) (Respondent) Assessee By : Shri Nishant Thakkar & Mr. Jasmin Amalsadwala, Ars Revenue By : Ms. Vranda U. Matkari, Dr Date Of Hearing: 04/08/2023 Date Of Pronouncement : 25/10/2023

section 143 (3) of the act was passed on 26/3/2014 wherein the total income of the assessee is determined at ₹ 4,746,798,774/–. 011. Assessee preferred the appeal before the learned CIT (A), who passed an appellate order on 12th October, 2017, partly allowing the appeal. The learned CIT (A) while adjudicating the transfer pricing adjustment directed the learned

JOINT COMMISSIONER OF INCOME TAX (OSD)-4(1)(1), MUMBAI vs. CITIGROUP GLOBAL MARKETS (INDIA) PRIVATE LIMITED, MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Citigroup Global Markets (India) Private Limited The Dcit 1402, 14Th Floor, Circle -4(1), First International Financial Aaykar Bhavan Centre, Vs. M.K. Road, Bandra Kurla Complex, Mumbai-400 020 G Block, Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No.Aaecs7234F Citigroup Global Markets (India) The Jcit (Osd) Private Limited 4(1)(1) 1402, 14Th Floor, Room No. 640, 6 Th Floor, First International Financial Aaykar Bhavan, Centre, Vs. M.K. Road, Bandra Kurla Complex, G Block, Bandra (East), Mumbai-400 020 Mumbai-400 051 (Appellant) (Respondent) Assessee By : Shri Nishant Thakkar & Mr. Jasmin Amalsadwala, Ars Revenue By : Ms. Vranda U. Matkari, Dr Date Of Hearing: 04/08/2023 Date Of Pronouncement : 25/10/2023

section 143 (3) of the act was passed on 26/3/2014 wherein the total income of the assessee is determined at ₹ 4,746,798,774/–. 011. Assessee preferred the appeal before the learned CIT (A), who passed an appellate order on 12th October, 2017, partly allowing the appeal. The learned CIT (A) while adjudicating the transfer pricing adjustment directed the learned

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.) , MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

Transfer Pricing Officer observed that the\nassessee was unable to establish that it has received any benefit\ndue to the cost incurred by the AEs. Accordingly, he concluded\nthat since the assessee has failed to establish the benefit derived\nrelating to the cost incurred by the AEs on various account, the\narm's length price of such transaction

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLYUT WORLDWIDE (INDIA) PVT. LTD.), MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

Transfer Pricing Officer observed that the\nassessee was unable to establish that it has received any benefit\ndue to the cost incurred by the AEs. Accordingly, he concluded\nthat since the assessee has failed to establish the benefit derived\nrelating to the cost incurred by the AEs on various account, the\narm's length price of such transaction

DCIT, CIRCLE 3 4, MUMBAI, MUMBAI vs. TATA CONSULTANCY SERVICES LIMITED, MUMBAI

In the result, appeals of both, revenue and assessee are partly\nallowed for all the three

Section 40(a)(ia) of the Act both under normal provisions of the Act\nas well as under the computation of book profits u/s.115JB of the Act. We find\nthat the Id. CIT(A) had deleted the said disallowance by observing as under:-\n\"This is a matter arising for the first time in the case of assessee

ADIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

114, 1st Floor, 11th & 12th and 14th Floor, Vs. Scindia House, N.M. Marg, Hoechst House, Nariman Point, Ballard Estate, Mumbai-400038. Mumbai-400021. PAN: AACCC3872B Appellant) : Respondent) I.T.A. No. 2313/Mum/2017 (Assessment Year: 2012-13) I.T.A. No. 4652/Mum/2017 (Assessment Year: 2013-14) I.T.A. No. 458/Mum/2019 (Assessment Year: 2014-15) I.T.A. No. 7881/Mum/2019 (Assessment Year: 2015-16) I.T.A. No. 1027/Mum/2021 (Assessment Year

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. THE DY-CIT (INT. TAXATION)-2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

114, 1st Floor, 11th & 12th and 14th Floor, Vs. Scindia House, N.M. Marg, Hoechst House, Nariman Point, Ballard Estate, Mumbai-400038. Mumbai-400021. PAN: AACCC3872B Appellant) : Respondent) I.T.A. No. 2313/Mum/2017 (Assessment Year: 2012-13) I.T.A. No. 4652/Mum/2017 (Assessment Year: 2013-14) I.T.A. No. 458/Mum/2019 (Assessment Year: 2014-15) I.T.A. No. 7881/Mum/2019 (Assessment Year: 2015-16) I.T.A. No. 1027/Mum/2021 (Assessment Year

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE DY.CIT OF INCOME TAX (INTERNATIONSL TAXATION) -2(1) (1) , MUMBAI

Accordingly these grounds are dismissed as not pressed

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Dcit (International Taxation)- Investment Bank (Formerly 2(1)(1), 1St Floor, Room No. 136, Known As ‘Calyon Bank’) Vs. 11Th Floor, Hoechst House, Scindia House, N.M. Marg, Nariman Point, Mumbai-400021. Ballard Pier, Mumbai-400038. Pan: Aaccc3872B Appellant) : Respondent)

114, 1st Floor, 11th & 12th and 14th Floor, Vs. Scindia House, N.M. Marg, Hoechst House, Nariman Point, Ballard Estate, Mumbai-400038. Mumbai-400021. PAN: AACCC3872B Appellant) : Respondent) I.T.A. No. 2313/Mum/2017 (Assessment Year: 2012-13) I.T.A. No. 4652/Mum/2017 (Assessment Year: 2013-14) I.T.A. No. 458/Mum/2019 (Assessment Year: 2014-15) I.T.A. No. 7881/Mum/2019 (Assessment Year: 2015-16) I.T.A. No. 1027/Mum/2021 (Assessment Year

ASST CIT RG 9(2)(1), MUMBAI vs. CRISIL LTD, MUMBAI

Transfer\nPricing- 1(1), Mumbai (TPO) in making an adjustment of Rs. 13,65.09,673 to the\nprovision of back end support for financial data analysis services by the Appellant to its\nassociated enterprise (AE).\n2. On the facts and circumstances of the case, the Hon'ble DRP erred in upholding\nthe action of the Ld.AO/ Ld. TPO in characterizing

CRISIL LTD,MUMBAI vs. DCIT (OSD) 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 10A of IT Act / Export turnover as defined in Explanation 2(IV) of Section 10A of the IT Act + domestic sale proceeds 19. In the instant case, if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under Section10A of the IT Act are allowed only in Export Turnover but not from the Total

CRISIL LTD,MUMBAI vs. ASST CIT RG 9(2)(2), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 10A of IT Act / Export turnover as defined in Explanation 2(IV) of Section 10A of the IT Act + domestic sale proceeds 19. In the instant case, if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under Section10A of the IT Act are allowed only in Export Turnover but not from the Total

CRISIL LTD,MUMBAI vs. ADDL CIT 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 10A of IT Act / Export turnover as defined in Explanation 2(IV) of Section 10A of the IT Act + domestic sale proceeds 19. In the instant case, if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under Section10A of the IT Act are allowed only in Export Turnover but not from the Total

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 15(3)(2), MUMBAI

The appeal of the assessee is allowed

Bench: Amit Shukla () & Ms. Padmavathy S. ()

section 35(1 )(iv) of the Act. 2 : 0 Re.: Credit for advance-tax granted short by Rs. 3,16,50f 152/- 2 : 1 The Assessing Officer has erred in granting credit for advance-tax short by Rs. 3,16,50,152/-.” 6. The Ld.AR submitted that the assessee has raised the additional grounds, which do not involve verification

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

114, 1st Floor,\nScindia House, N.M. Marg,\nBallard Estate, Mumbai-400038.\nAppellant)\nVs.\nCredit Agricole Corporate and\nInvestment Bank,\n11th & 12th and 14th Floor,\nHoechst House, Nariman Point,\nMumbai-400021.\nPAN: AACCC3872B\nRespondent)\nI.T.A. No. 2313/Mum/2017\n(Assessment Year: 2012-13)\nΙ.Τ.Α. No. 4652/Mum/2017\n(Assessment Year: 2013-14)\nΙ.Τ.Α. No. 458/Mum/2019\n(Assessment Year

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

114, 1st Floor,\nScindia House, N.M. Marg,\nBallard Estate, Mumbai-400038.\nAppellant)\nVs.\nCredit Agricole Corporate and\nInvestment Bank,\n11th & 12th and 14th Floor,\nHoechst House, Nariman Point,\nMumbai-400021.\nPAN: AACCC3872B\n:\nRespondent)\nI.T.A. No. 2313/Mum/2017\n(Assessment Year: 2012-13)\nΙ.Τ.Α. No. 4652/Mum/2017\n(Assessment Year: 2013-14)\nΙ.Τ.Α. No. 458/Mum/2019\n(Assessment Year

DCIT (IT) 2(1)(1), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

114, 1st Floor,\nScindia House, N.M. Marg,\nBallard Estate, Mumbai-400038.\nAppellant)\nVs.\nCredit Agricole Corporate and\nInvestment Bank,\n11th & 12th and 14th Floor,\nHoechst House, Nariman Point,\nMumbai-400021.\nPAN: AACCC3872B\n: Respondent)\nI.T.A. No. 2313/Mum/2017\n(Assessment Year: 2012-13)\nΙ.Τ.Α. No. 4652/Mum/2017\n(Assessment Year: 2013-14)\nΙ.Τ.Α. No. 458/Mum/2019\n(Assessment Year

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE JT CIT (INTERNATIONAL TAXATIONA), MUMBAI

Accordingly these grounds are dismissed as not pressed

114, 1st Floor,\nScindia House, N.M. Marg,\nBallard Estate, Mumbai-400038.\nAppellant)\nVs.\nCredit Agricole Corporate and\nInvestment Bank,\n11th & 12th and 14th Floor,\nHoechst House, Nariman Point,\nMumbai-400021.\nPAN: AACCC3872B\n:\nRespondent)\nI.T.A. No. 2313/Mum/2017\n(Assessment Year: 2012-13)\nΙ.Τ.Α. No. 4652/Mum/2017\n(Assessment Year: 2013-14)\nΙ.Τ.Α. No. 458/Mum/2019\n(Assessment Year