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

DCIT(IT)-2(2)(2), NARIMAN POINT vs. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD, BANDRA

Pricing Report in form\nNo.3CEB u/s. 92E of the Income-tax Act 1961. The assessee had also filed the\ntax audit report in form No. 3CA and 3CD u/s.44AB of the Income-tax Act, 1961.\nThe case was selected for scrutiny assessment and order under section 143(3)\nrws 144C(3) was passed on 03.02.2017, wherein the AO assessed

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 & 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

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 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 HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED -INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

Pricing Report in form\nNo.3CEB u/s. 92E of the Income-tax Act 1961. The assessee had also filed the\ntax audit report in form No. 3CA and 3CD u/s.44AB of the Income-tax Act, 1961.\nThe case was selected for scrutiny assessment and order under section 143(3)\nrws 144C(3) was passed on 03.02.2017, wherein the AO assessed

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

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

115A (1) (a) (iiaa) as interest received under section 194LC and taxed accordingly. 05. Return of income was picked up for scrutiny for verification of international transaction in respect of lending or borrowing of money as per transfer pricing risk parameters. The notice under Section 143(2) of the Act was issued on 9 August 2018. 06. As the assessee

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 certain changes have been made and\nwith the passage of time the Finance Act 1994 has also carried\nout certain amendments in the said section w.e.f. 1/4/95 the\nscope and effect of the amendments was explained by CBDT in\nCircular No.684 dated 6/6/94(208 ITR 08(St.), relevant page-43.\nThis CBDT circular and related provisions

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

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

115A certain changes have been made and\nwith the passage of time the Finance Act 1994 has also carried\nout certain amendments in the said section w.e.f. 1/4/95 the\nscope and effect of the amendments was explained by CBDT in\nCircular No.684 dated 6/6/94(208 ITR 08(St.), relevant page-43.\nThis CBDT circular and related provisions

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED INDIA BRANCHES ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

Pricing Report in form\nNo.3CEB u/s. 92E of the Income-tax Act 1961. The assessee had also filed the\ntax audit report in form No. 3CA and 3CD u/s.44AB of the Income-tax Act, 1961.\nThe case was selected for scrutiny assessment and order under section 143(3)\nrws 144C(3) was passed on 03.02.2017, wherein the AO assessed

THE HONGKONG AND SHANGHAI BANKING CORPORATION LIMITED ,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

Pricing Report in form\nNo.3CEB u/s. 92E of the Income-tax Act 1961. The assessee had also filed the\ntax audit report in form No. 3CA and 3CD u/s.44AB of the Income-tax Act, 1961.\nThe case was selected for scrutiny assessment and order under section 143(3)\nrws 144C(3) was passed on 03.02.2017, wherein the AO assessed

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

B which is a complete code in Itself; 3. The Assessing Officer / DRP erred in making disallowing 3. The Assessing Officer / DRP erred in making disallowing 3. The Assessing Officer / DRP erred in making disallowing Rs.8,70,45,135/ Rs.8,70,45,135/- pertaining to discount on Employee Stock pertaining to discount on Employee Stock Option Plan (being the difference

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 certain changes have been made and\nwith the passage of time the Finance Act 1994 has also carried\nout certain amendments in the said section w.e.f. 1/4/95 the\nscope and effect of the amendments was explained by CBDT in\nCircular No.684 dated 6/6/94(208 ITR 08(St.), relevant page-43.\nThis CBDT circular and related provisions

GENERAL ELECTRIC INTERNATIONAL INC.,GURGAON vs. DCIT, INTERNATIONAL TAXATION CIRCLE 2(3)(2), MUMBAI

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

transfer pricing adjustments were required. In response to the notices issued, the Appellant has made its submission on 01/10/2018, and 23/10/2018. Thereafter, on account of change of incumbent, fresh notice under Section 142(1) of the Act along with questionnaire was issued to the Appellant on 16/11/2019. Thereafter on the Appellant filed replies dated, 02/12/2019 and on 20/12/2019