THE BANK OF NOVA SCOTIA,MUMBAI vs. ADDL DIT (IT) RG 3, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

115A", "Section 44C", "Section 10(15)"], "issues": "The primary issues revolve around the correct computation of disallowances under Section 14A, the allowability of expatriate salaries, transfer pricing

NIPRO CORPORATION,JAPAN,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION 3(3)(1), MUMBAI

In the result, appeal of the assessee is partly allowed as indicated above for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Nipro Corporation, Japan Vs. The Deputy Commissioner Of Nipro India Corporation Pvt. Income Tax , Ltd. International Taxation, Plot No.3-1, Circle 3(3)(1) Room No.1630, 16 Th Floor, Air Midc, Kesurdi, Khandala, Tal, Khandala, Satara, India Building, Mumbai-412802 Nariman Point, Mumbai-400 021 (Appellant) (Respondent) Pan No. Aaecn4534F

transfer-pricing adjustment on account of interest receivable was also taxed under the head income from other sources at the rate of 5% as provision of Section 194LC of the Act read with section 115A

DCIT (IT) -1(2)(1), MUMBAI vs. THE BANK OF NOVA SCOTIA, MUMBAI

transfer pricing adjustments were dismissed as not pressed. The issue of expatriate salary was allowed in favor of the assessee, reversing the CIT(A)'s disallowance. The applicability of Section 115A

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)

transfer pricing order under section 92CA(3) by 29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the ratio laid down by the Hon'ble Madras High Court in the above case, we hold that the order passed by the TPO making the TP Adjustment is barred by limitation and accordingly liable to be quashed. Hence, the TP Adjustment

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)

transfer pricing order under section 92CA(3) by 29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the ratio laid down by the Hon'ble Madras High Court in the above case, we hold that the order passed by the TPO making the TP Adjustment is barred by limitation and accordingly liable to be quashed. Hence, the TP Adjustment

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)

transfer pricing order under section 92CA(3) by 29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the ratio laid down by the Hon'ble Madras High Court in the above case, we hold that the order passed by the TPO making the TP Adjustment is barred by limitation and accordingly liable to be quashed. Hence, the TP Adjustment

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADIT (IT) 3(2), MUMBAI

transfer pricing adjustments, and applicability of Section 115A. Several grounds were dismissed as not pressed, while others were allowed or dismissed

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADDL CIT (IT) 3, MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

transfer pricing methodologies while allowing others.", "result": "Partly Allowed", "sections": [ "Sec. 14A", "Sec. 10(15)", "Sec. 92C", "Sec. 44C", "Sec. 115A

THE BANK OF NOVA SCOTIA,MUMBAI vs. ADIT (IT) 3(2), MUMBAI

In the result, the appeals of the assessee are partly allowed and\nappeals of the revenue are also partly allowed

transfer pricing adjustments for correspondent banking services, expatriate salary disallowances, and applicability of Section 115A to foreign currency loan interest

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under Section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under Section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under Section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

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

Accordingly these grounds are dismissed as not pressed

transfer pricing order under section 92CA(3) by\n29.01.2014 whereas the order is passed on 30.01.2014. Therefore, applying the\nratio laid down by the Hon'ble Madras High Court in the above case, we hold that\nthe order passed by the TPO making the TP Adjustment is barred by limitation and\naccordingly liable to be quashed. Hence, the TP Adjustment

THE ADIT (IT)-3(2), MUMBAI vs. M/S. THE BANK OF NOVASCOTIA, MUMBAI

transfer pricing adjustments concerning correspondent banking services and interbank indemnities, the tribunal upheld the assessee's position in most instances, finding TNMM to be the appropriate method and directing deletion of adjustments made by the TPO.", "result": "Partly Allowed", "sections": [ "14A", "8D", "10(15)", "44C", "92C", "115A

DDIT (IT) 3(2), MUMBAI vs. THE BANK OF NOVA SCOTIA, MUMBAI

In the result, the appeals of the assessee are partly allowed and appeals of the revenue are also partly allowed

Bench: Shri Vikas Awasthy & Shri Amarjit Singhita No.8841/Mum/2010 The Bank Of Nova Scotia Vs. Assistant Director Of Mittal Towers, B Wing Income Tax (It) -3(2) Nariman Point Scindia House Mumbai – 400 020 Ballard Pier Mumbai – 400 038 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacb1536H Appellant .. Respondent It(Tp)A. No.3862/Mum/2013 The Bank Of Nova Scotia Vs. Additional Director Of Mittal Towers, B Wing Income Tax (It) -3 Nariman Point Air India Building Mumbai – 400 020 Nariman Point Mumbai – 400 021 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacb1536H Appellant .. Respondent Ita.No.3989/Mum/2012 Deputy Director Of Income Vs. M/S The Bank Of Nova Tax (It) -3(2) Scotia, Mittal Towers, B Scindia House Wing, Nariman Point Ballard Pier, N. M. Road Mumbai – 400 021 Mumbai – 400 038

Transfer Pricing adjustment in respect of Correspondent banking services and Correspondent Banking Charges – whether to be excluded in view of Article 7(3) of the India- Canada DTAA and Upholding the inclusion of comparable selected by the TPO in respect of correspondent banking services and Upholding the use of single year data in determining arm’s length price in respect