TATA INTERNATIONAL LTD,MUMBAI vs. ADDL CIT 7(3), MUMBAI

In the result, the appeal of the assessee is allowed, appeal of the revenue is dismissed and cross objection of the assessee is dismissed as infructuous

Pricing Officer u/s 92CA(1) of the Act on 11/01/2008. The jurisdiction of the ld. AO (i.e DCIT Circle 7(3), Mumbai) was assigned to the Additional CIT Range 7(3), Mumbai on 05/05/2008. Subsequently a notice u/s 142(1) of the Act dated 29/07/2008 was issued by the ld.Additional CIT on the assessee. The assessment

ACIT 7(3), MUMBAI vs. TATA INTERNATIONAL LTD, MUMBAI

In the result, the appeal of the assessee is allowed, appeal of the revenue is dismissed and cross objection of the assessee is dismissed as infructuous

Pricing Officer u/s 92CA(1) of the Act on 11/01/2008. The jurisdiction of the ld. AO (i.e DCIT Circle 7(3), Mumbai) was assigned to the Additional CIT Range 7(3), Mumbai on 05/05/2008. Subsequently a notice u/s 142(1) of the Act dated 29/07/2008 was issued by the ld.Additional CIT on the assessee. The assessment

RGA INTERNATIONAL REINSURANCE COMPANY DESIGNATED ACTIVITY COMPANY,IRELAND vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX) - CIRCLE 4(1)(1), MUMBAI

Appeal of the assessee is partly allowed

Bench: Ms Padmavathy S, Am & Shri Raj Kumar Chauhan, Jm

115B of the Act. 12. Ground 12 The learned AO has, on the facts and circumstances of the case, erred in not following the decision of Hon'ble Income-tax Appellate Tribunal's decision in the Appellant's own case for Assessment Year 2015-16, Assessment Year 2017-18. Assessment Year 2018-19, Assessment Year 2019-20, Assessment Year

RGA INTERNATIONAL REINSURANCE COMPANY DESIGNATED ACTIVITY CO,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-4(1)(1), MUMBAI

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

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blerga International Reinsurance V. Dcit (International Taxation) -4(1)(1) Room No. 172, 17Th Floor Company Designated Activity Air India Building, Nariman Point Company Mumbai – 400 021 C/O. S.R.B.C & Associates Llp 14Th Floor, The Ruby 29 Senapati Bapat Marg Dadar (W), Mumbai – 400028 Pan: Aadcr1226K (Appellant) (Respondent) Assessee Represented By : Shri P.S. Paridiwala & Ms. Jasmin Amalasadvala Department Represented By : Ms. Surabhi Sharma

115B of the Act. 8. Ground 8 The learned AO has, on the facts and circumstances of the case and in law, and based on the directions of the Hon'ble DRP, erred in levying interest under section 234B of the Act. 9. Ground 9 The learned AO has, on the facts and circumstances of the case

RGA INTERNATIONAL REINSURANCE COMPANY DESIGNATED ACTIVITY COMPANY,MUMBAI vs. ACIT (IT) - RG. 4(1)(1), MUMBAI

In the result, the appeal is allowed in the terms indicated above

Bench: Us Are As Follows:

115B of the Act. 9. Ground 9 The learned AO has, on the facts and circumstances of the case and in law, and based on the directions of the Hon'ble DRP, erred in levying interest under section 234B of the Act. 10. Ground 10 The learned AO has, on the facts and circumstances of the case

DCIT-CC-5(3), MUMBAI, AIR INDIA BUILDING, NARIMAN POINT vs. KOTAK MAHINDRA LIFE INSURANCE COMPANY LIMITED, MUMBAI

In the result, the appeal of the revenue is dismissed

Bench: Shri Amit Shukla & Shri Gagan Goyaldcit, Cc 5(3), 1906, 19Th Floor, Air India Building, Nariman Point, Mumbai - 400 020. ..... Appellant Vs. Kotak Mahindra Life Insurance Co. Ltd. 8Th Floor, 12Bkc, Bandra Kurla Complex, G Block, Mumbai – 400 051 Pan No. Aaaco3983B ..... Respondent

Transfer Pricing Office -2(3) (1), Mumbai vide letter dated 24.09.2022 has communicated to pass the final order as deemed fit.” 5. The case of the assessee was finally assessed at a figure of Rs. 460, 27, 00,078/- as normal business income and Rs. 169, 69, 02,000/- as income from other sources. The assessee being aggrieved with this

DCIT, CIRCLE-1 ,, THANE vs. EVEREST INDUSTRIES LTD., MUMBAI

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres

DCIT CIRCLE-1 , THANE vs. M/S EVEREST INDUSTRIES LTD. , DELHI

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres

EVEREST INDUSTRIES LTD, NOIDA vs. DY CIT CIRLCE-1 , THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres

EVEREST INDUSTRIES LTD,NOIDA vs. DY CIT CIRLCE-1, THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres

EVEREST INDUSTRIES LTD.,NOIDA vs. DY CIT CIRCLE- 1, THANE

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres

DCIT CIRCLE-1 , THANE vs. M/S EVEREST INDUSTRIES LTD. , DELHI

In the result, the In the result, the assessee and Revenue are are educated as under:

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14 Everest Industries Limited, Dcit, Circle-1, D-206, Sector-63, Noida- Ashar I.T. Park, 6Th Floor, B- 201301, Vs. Wing, 16-Z, Wagle Industrial Uttar Pradesh Estate, Thane(W)- 400 604. Pan No. Aaace 7550 N Appellant Respondent Assessment Year: 2008-09 & Assessment Year: 2009-10 & Assessment Year: 2012-13 & Assessment Year: 2013-14

115B of the Act despite the fact that no adjustment adjustment adjustment other other other than than than the the the ones ones ones mentioned menti menti in Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Sec.115JB is permissible as held by the Supreme Court in the case of Apollo Tyres