FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

Transfer Pricing study report the Ld. TPO noted that\nassessee used transactional net margin method to compute the\nmargin of the services rendered under Data Processing Service\nand Software Development Service Segment by using OP/OC as\nPLI.\nData Processing Service Segment\n6.1 The assessee thus computed its margin under Data\nProcessing Service Segment at 12.48%. It was noted that\nassessee

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer) passed under Section 92CA(3) of the Act being adjustment to the Arm's Length Price of the international transactions which has been upheld by the learned Dispute Resolution Panel-3, Mumbai (the learned Dispute Resolution Panel) as per direction passed under Section 144C(5) of the Act dated 31st December, 2013 . Further

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer) passed under Section 92CA(3) of the Act being adjustment to the Arm's Length Price of the international transactions which has been upheld by the learned Dispute Resolution Panel-3, Mumbai (the learned Dispute Resolution Panel) as per direction passed under Section 144C(5) of the Act dated 31st December, 2013 . Further

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer) passed under Section 92CA(3) of the Act being adjustment to the Arm's Length Price of the international transactions which has been upheld by the learned Dispute Resolution Panel-3, Mumbai (the learned Dispute Resolution Panel) as per direction passed under Section 144C(5) of the Act dated 31st December, 2013 . Further

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to make fresh order under section 92CA (3) after conducting inquiries into the international transaction undertaken by the assessee for assessment year 2012 – 13. The learned TPO was also directed to include the issues and findings already considered and decided by the TPO for assessment year 12

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to make fresh order under section 92CA (3) after conducting inquiries into the international transaction undertaken by the assessee for assessment year 2012 – 13. The learned TPO was also directed to include the issues and findings already considered and decided by the TPO for assessment year 12

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to make fresh order under section 92CA (3) after conducting inquiries into the international transaction undertaken by the assessee for assessment year 2012 – 13. The learned TPO was also directed to include the issues and findings already considered and decided by the TPO for assessment year 12

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to make fresh order under section 92CA (3) after conducting inquiries into the international transaction undertaken by the assessee for assessment year 2012 – 13. The learned TPO was also directed to include the issues and findings already considered and decided by the TPO for assessment year 12

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

sections": [ "90", "92C(3)", "92CA(1)", "37(1)", "80G", "14A", "135", "40(a)(i)", "40(a)(ia)", "115JB", "10AA", "195", "10A", "9(1)(vi)", "13(2)", "13(3)", "9(1)(iv)", "Article 25", "Article 7", "Article 12" ], "issues": "The appeals raised multiple issues including transfer pricing

TATA AIG GENERAL INSURANCE COMAPANY LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

section 2 Years from the end of the assessment 3 A.Y. 2009-10 Tata AIG General Insurance 153 of the Act as the law stood year (i.e 31.03.2012) 2 Extension of period of limitation in case a reference is made u/s 92CA of 12 Months (i.e. 31.03.2013) the Act 3 Date on which reference was made to the Transfer Pricing

ATOS INDIA P.LTD,MUMBAI vs. DCIT RG 14(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Shri G. S. Pannu & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1795/Mum/2017 (ननधधारणवर्ा / Assessment Year: 2012-13) Dcit-14(1)1), Atos India Pvt. Ltd., Aayakar Bhavan Godrej & Boyce Complex, बनाम/ Mumbai Plant 5, Pirojshanagar, Vs. Lbs Marg, Vikhroli (West), Mumbai-400079 स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aaaco2461J (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Shri Dhanesh Bafna /Chandni Sha /Riddhi Maru /Kinjal Patel, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Dr. Yogesh Kamat, Ld. Dr सुनवधईकीतधरीख/ 01.06.2022 & : 25.01.2023 Date Of Hearing घोर्णधकीतधरीख / : 23.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: 1. The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) In 2

12 months case reference is made under section 31/03/2016 92CA of the Act D Proceeding for assessment should be 31.3.2016 completed on / before this date E A date prior to the date on which 30.3.2016 period of limitation expires F Sixty day period expires on 31.1.2016 G Transfer Pricing

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

section 92CA(1) of the Act was issued to Transfer Pricing Officer – 4(2)(1), Mumbai. The background of the assessee is, assessee is the leading integrated travel and travel related financial services company offering a broad spectrum of services that include Foreign Exchange, Corporate Travel, MICE, Leisure Travel, Insurance, Visa & Passport services and E-Business. During this AY, Assessee

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 10(3),

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No.2877/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2009-10) Strides Shasun Limited Dcit Cir. 15(3)(2) (Formerly Known As R. No. 451, 4Th Floor, Strides Arcolab Limited) बिधम/ Aayakar Bhavan, M. K. 201, Devavrata, Sector 17, Road, Mumbai-400 020 Vs. Vashi, Navi Mumbai – 400 703 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcs8104P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Percy Pardiwala/ Shri Ketan Ved /Shri Ninad Patade, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Ms. Vatsalaa Jha, Ld. Dr सुनवाईकीतारीख/ : 18.01.2023 Date Of Hearing घोषणाकीतारीख / : 28.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla : The Aforesaid Appeal Has Been Filed By Assessee Against The Order Dated 26.02.2014 Passed U/S 143(3) R.W.S. 144C(13) In 2

section 153, i.e. 31st March 2013, starts with 30.03.2013 as per the following calculation:- 60 day period expires on March = 30 days (excluding 31.03.2013) February = 28 days January = 2 days Thus, the date on which transfer pricing has been passed was 29.01.2013, whereas the transfer pricing order u/s 92CA (3) has been passed on 30.01.2013. 12

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

12,637/- 5 Excessive AMP expenditure 22,01,14,350/- Total 36,38,25,151/- On 31/03/2015, the Assessing Officer passed Draft Assessment Order under Section 143(3) read with Section 144C(1) of the Act incorporating the above transfer pricing

SHAPOORJI PALLONJI AND COMPANY PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

Appeals are partly allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

12,684/- under Section 115JB of the Act. The case of the Assessee was selected for scrutiny. During the course of assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) Therefore, reference was made under Section 92CA(1) of the Act to the Transfer Pricing

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

12,684/- under Section 115JB of the Act. The case of the Assessee was selected for scrutiny. During the course of assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) Therefore, reference was made under Section 92CA(1) of the Act to the Transfer Pricing

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

12 TNMM is accepted as MAM in transfer pricing scrutiny, we would like to is accepted as MAM in transfer pricing scrutiny, we would like to is accepted as MAM in transfer pricing scrutiny, we would like to considers TNMM to be the most appropriate method for determination considers TNMM to be the most appropriate method for determination considers TNMM

LANXESS INDIA P.LTD,THANE vs. DCIT CIR 1, THANE

In the result, the appeal of the assessee

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

12, pursuant to the order of Ld. Dispute Resolution Panel-1, Mumbai (in short ‘the DRP’). 1, Mumbai (in short ‘the DRP’). 2. The grounds raised by the assessee are reproduced as under: The grounds raised by the assessee are reproduced as under: The grounds raised by the assessee are reproduced as under: 1. On the facts and circumstances