GRASIM INDUSTRIES LTD.,MUMBAI vs. DY CIT, CENTRAL CIRCLE-1(4), MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 2 (19 AA) of the act. viii. In any event provisions of the deemed dividend cannot be applied as there is no release of any assets by the assessee to its shareholders as assessee has transferred its ―undertaking‖ to Aditya Birla capital limited and Aditya Birla capital limited has issued equity shares of Aditya Birla capital limited

DY CIT CC-1(4), MUMBAI vs. M/S GRASIM INDUSTRIES LTD., MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

Section 2 (19 AA) of the act. viii. In any event provisions of the deemed dividend cannot be applied as there is no release of any assets by the assessee to its shareholders as assessee has transferred its ―undertaking‖ to Aditya Birla capital limited and Aditya Birla capital limited has issued equity shares of Aditya Birla capital limited

KORN FERRY INTERNATIONAL P.LTD,MUMBAI vs. DCIT 3(2), MUMBAI

Appeal of the AO is dismissed

price at which those shares were issued by the assessee to its employees had to be regarded as expenditure incurred for business purposes allowable u/s. 37(1) of the Act.Respectfully following the above decision, we decide Ground No.2 in favour of the assessee .” Respectfully following the above order,we allow the appeal of the assessee with regard to second ground

GOLDMAN SACHS (INDIA) SECURITIES P.LTD,MUMBAI vs. ITO (IT) TDS 3, MUMBAI

115Q have been amended w.e.f.01.04.2013 and profit arising out of buyback of shares is to taxed at a particular tax rate.But,the AY.,before us, is prior to the April,1st,2013.Therefore,we have to decide the issue as per the prevailing law applicable on the date of the transaction in question.There is no ambiguity about the provisions that would

PFIZER LTD,MUMBAI vs. DCIT - 14(2) (2), MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

115Q of the act. Therefore, adequate information available on the record, we have no hesitation in admitting the additional ground of appeal. Hence, we admit the same. 017. Coming to the merits of the ground of appeal, the learned authorized representative submitted that ITA No.2108, 2132/Mum/2018 & CO 110/Mum/2019; A.Y. 2014-15 i. Shareholders of Pfizer Ltd is a resident

ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

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

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

115Q of the act. Therefore, adequate information available on the record, we have no hesitation in admitting the additional ground of appeal. Hence, we admit the same. 017. Coming to the merits of the ground of appeal, the learned authorized representative submitted that ITA No.2108, 2132/Mum/2018 & CO 110/Mum/2019; A.Y. 2014-15 i. Shareholders of Pfizer Ltd is a resident