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

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

THE INDIAN HOTELS COMPANY LTD,MUMBAI vs. ADDL CIT 2(2), MUMBAI

In the result, all the appeals of the assessee are allowed

section 120 (4)(b) of the Act.” 2.1. We find that the aforesaid additional ground goes to the root of the matter and does not involve verification of facts. Hence, the same being a legal issue, we deem it fit and appropriate to admit the aforesaid additional ground and take up the matter for adjudication. 3. We have heard rival

TATA STEEL LTD,MUMBAI vs. ADDL CIT 2(3), MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

section 120(4)(b)/section 127 of the Act. The learned DR further submitted that in NTPC Ltd. (supra), the issue was determination of tax liability and all the facts were available on record, unlike in the present case. It was submitted that the assessee participated in the assessment proceedings before the Transfer Pricing

ITO (IT) TDS-2, MUMBAI vs. TATA STEEL LTD, MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

section 120(4)(b)/section 127 of the Act. The learned DR further submitted that in NTPC Ltd. (supra), the issue was determination of tax liability and all the facts were available on record, unlike in the present case. It was submitted that the assessee participated in the assessment proceedings before the Transfer Pricing

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. ACIT 9(3)(1), MUMBAI

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

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

b. Payments for Technical Knowhow 3,96,90,306 c. Payment for interest on ECB loan 51,74,209 d. Payment for software charges 2,21,62,308 Total 9,89,08,525 4. The Ld. AO has passed draft assessment order u/s 143(3) r.w.s. 144C(1) of the I.T. Act, 1961 on 30-11-2017 and made

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

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

b) of the Income Tax, Rules 1962. Accordingly, the disallowance to the extent of ₹21,800/- out of total disallowance of ₹1,56,365/- is upheld and Assessing Officer is directed to delete the balance Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 disallowance. Accordingly, ground no.4 of the appeal is partly allowed. 078. In the result, the appeal

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

B. It is palpable that in both such situations, the value of transaction between the associated enterprises is tailor-made to suit the overall interest of the multinational company. It does not represent the transaction at its true value. In the first situation, the receipt from the transaction recorded in India will be lower and its ALP will be higher

RAMESH BUILDERS (INDIA),MUMBAI vs. ITO 12(1)(2), MUMBAI

In the result, the appeal filed by the assessee-Ramesh Builders(India) in ITA N0

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1797/Mum/2012 ("नधा"रण वष" / Assessment Year : 2007-08) Ramesh Builders (India), Income Tax बनाम/ 9, Dhiraj Chambers, Officer,12(1)(2),Aayakar V. 9, Hazarimal Somani Marg, Bhavan,M.K. Road, Fort,Mumbai – 400001. Mumbai. "थायी लेखा सं./Pan : Aaafr4655E .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

price on the date of retirement. It was the contention of the assessee that there is no need to substitute the market value in respect of units mentioned at S.No. 3 to 8 as per above statement as rate adopted for transfer to retiring partner was Rs.1932.46 per square feet , however, in respect of unit

RAMESH BUILDERS,MUMBAI vs. ITO 12(1)(1), MUMBAI

In the result, the appeal filed by the assessee-Ramesh Builders(India) in ITA N0

Bench: Shri Saktijit Dey & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1797/Mum/2012 ("नधा"रण वष" / Assessment Year : 2007-08) Ramesh Builders (India), Income Tax बनाम/ 9, Dhiraj Chambers, Officer,12(1)(2),Aayakar V. 9, Hazarimal Somani Marg, Bhavan,M.K. Road, Fort,Mumbai – 400001. Mumbai. "थायी लेखा सं./Pan : Aaafr4655E .. (अपीलाथ" /Appellant) (""यथ" / Respondent)

price on the date of retirement. It was the contention of the assessee that there is no need to substitute the market value in respect of units mentioned at S.No. 3 to 8 as per above statement as rate adopted for transfer to retiring partner was Rs.1932.46 per square feet , however, in respect of unit