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

SATELLITE TELEVISION ASIAN REGION LTD,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

Transfer Pricing Officer will not be applicable to the total turnover of the assessee in toto. Thus, he observed, in such situation, there is no option left to him but to estimate the income of the assessee as per rule–10 of the Income Tax Rules, 1962 Therefore, referring to the decision of the DRP in assessee’s own case

GEMOLOGICAL INSTITUTE INTERNATIONAL INC.,MUMBAI vs. ASST CIT (IT) CIRCLE- 2 (3)(2), MUMBAI

In the result, appeal is partly allowed

Bench: Shri Saktijit Dey () & Shri Rajesh Kumar ()

Transfer Pricing orders passed in the case of GIA India from where it can be made out that no profit element has been included in the expenses reimbursed. Thus, taking into account the totality of facts and circumstances of the case, we find that addition made by the AO is contrary to facts and therefore, is directed to be deleted

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

SABRE ASIA PACIFIC PTE. LTD,MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-4(2)(1), MUMBAI

Bench: Shri Ravish Sood, Jm & Shri N.K. Pradhan, Am आयकर अपील सं./ I.T.A. No.664/Mum/2017 (निर्धारण वर्ा / Assessment Year:2012-13) Sabre Asia Pacific Pte. Ltd. Deputy Commissioner Of Income Tax (Earlier Known As M/S Abacus International Pte Ltd.), (International Taxation)- 1(1)(1), Room No. Abacus Plaza, 3 Tampines Central I, 117, 1St Floor, Scindia House, Ballard बिधम/ # 08-01 Singapore 529540 Estate, Mumbai 400 038. Vs. C/O Deloitte Haskins & Sells Llp India Bulls Financial Centre Tower 3, 28Th Floor, Senapati Bapat Marg, Elphinstone (W),Mumbai-400 013. स्थायीलेखासं./जीआइआरसं./ Pan/Gir No. Aabca6590M (अपीलाथी/Appellant) (प्रत्यथी /Respondent) :

transfer pricing adjustment of Rs. 2,10,24,208 under section 92CA(4), in respect of the international transaction entered into by the appellant during the year ended 31 March 2012. ITA No.664/Mum/2017 A.Y. 2012-13 & 4 ITA No.7379/Mum/2018 A.Y. 2014-15 Sabre Asia Pacific Pte ltd. Vs. DCIT (IT)-1(1)(1) & Sabre Asia Pacific Pte. Ltd. Vs. ACIT

SABRE ASIA PACIFIC PTE. LTD,MUMBAI vs. DCIT (IT) 1(1)(1), MUMBAI

Bench: Shri Ravish Sood, Jm & Shri N.K. Pradhan, Am आयकर अपील सं./ I.T.A. No.664/Mum/2017 (निर्धारण वर्ा / Assessment Year:2012-13) Sabre Asia Pacific Pte. Ltd. Deputy Commissioner Of Income Tax (Earlier Known As M/S Abacus International Pte Ltd.), (International Taxation)- 1(1)(1), Room No. Abacus Plaza, 3 Tampines Central I, 117, 1St Floor, Scindia House, Ballard बिधम/ # 08-01 Singapore 529540 Estate, Mumbai 400 038. Vs. C/O Deloitte Haskins & Sells Llp India Bulls Financial Centre Tower 3, 28Th Floor, Senapati Bapat Marg, Elphinstone (W),Mumbai-400 013. स्थायीलेखासं./जीआइआरसं./ Pan/Gir No. Aabca6590M (अपीलाथी/Appellant) (प्रत्यथी /Respondent) :

transfer pricing adjustment of Rs. 2,10,24,208 under section 92CA(4), in respect of the international transaction entered into by the appellant during the year ended 31 March 2012. ITA No.664/Mum/2017 A.Y. 2012-13 & 4 ITA No.7379/Mum/2018 A.Y. 2014-15 Sabre Asia Pacific Pte ltd. Vs. DCIT (IT)-1(1)(1) & Sabre Asia Pacific Pte. Ltd. Vs. ACIT

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

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

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

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

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

JCIT(OSD) I/C. OF DCIT -1(3)(1), MUMBAI, MUMBAI vs. ZT SYSTEMS INDIA PRIVATE LIMITED, MUMBAI

In the result, appeal of the revenue is dismissed as per our aforesaid observations

Bench: Shri Amit Shukla & Shri Arun Khodpiaआयकर अपील सं. / Ita No.1729/Mum/2025 "नधा"रण वष" / Assessment Year :2016-17 The Jt. Commissioner Of Income Tax (Osd), I/C. Dcit-1(3)(1), Mumbai (M.H.)

115A read with section 115-0 of the Act 6.4 Based on the transfer pricing order, the Id AO passed

THOMAS COOK (INDIA) LTD,MUMBAI vs. DY CIT 1 (3)92), MUMBAI

In the result, the appeal filed by the assessee is a In the result, the appeal filed by the assessee is a In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 Thomas Cook (India) Ltd., Dy. Cit-1(3)(2), A Wing, 11Th Floor, Marathon Room No. 540, 5Th Floor, Vs. Futurex, N.M. Joshi Marg, Aayakar Bhavan, M.K. Lower Parel (East), Road, Mumbai-400013. Mumbai-400020. Pan No. Aaact 4050 C Appellant Respondent Assessee By : Mr. Ketan Ved Revenue By : Ms. Richa Gulati, Dr : Date Of Hearing 30/05/2023 : Date Of Pronouncement 31/05/2023 Order

115A of the Act. The Ld. Assessing Officer in the draft assessment n the draft assessment order proposed this transfer pricing adjustment for addition. The order proposed this transfer pricing adjustment for addition. The order proposed this transfer pricing adjustment for addition. The Ld. Assessing Officer also proposed additions on other issues, inter Ld. Assessing Officer also proposed additions

M/S. THE BANK OF NOVA SCOTIA,MUMBAI vs. DDIT (I.T) - 3(20, MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri Amarjit Singh आअसं.6818/मुं/2006 ("न.व. 2002-03) The Bank Of Nova Scotia, Mittal Towers, B-Wing, Nariman Point, Mumbai 400 020. Pan: Aaacb-1536-H ...... अपीलाथ"/Appellant बनाम Vs. Deputy Director Of Income Tax (International Taxation)-3(2), Scindia House, Ballard Pier, Mumbai 400 038. ..... ""तवाद"/Respondent आअसं.651/मुं/2007 ("न.व. 2002-03) Adit(It)-3(2),Mumbai R. No.132, 1St Floor, N.M.Road, Mumbai – 400 038. ...... अपीलाथ"/Appellant बनाम Vs. The Bank Of Nova Scotia, Mittal Towers, B-Wing, Nariman Point, Mumbai 400 020. Pan: Aaacb-1536-H ..... ""तवाद"/Respondent

Transfer Pricing adjustment on account of services rendered to Foreign AEs. (viii) Disallowance of Salary paid to expatriate employees. 5. Aggrieved by the assessment order dated 14/03/2005, the assessee filed appeal before CIT(A). The First Appellate Authority vide impugned order granted part relief to the assessee. The Revenue is in appeal on the issues where