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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

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

price (ALP) u/s 92CA (3) of the act. Ipca Laboratories ltd; A.Y. 2005:06 to 2010–11 The Commissioner of income tax (Appeals) – 56, Mumbai (CIT (A)) erred in confirming following additions made by the Asst Commissioner of income tax (LTU), Mumbai (AO) u/s 92CA (3) of the act on account of adjustment in arm’s-length price (ALP) pursuant

M/S. MERCATOR LTD,MUMBAI vs. THE DY CIT 5(2), MUMBAI

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

section 153 is the outer time limit for passing the final assessment order and hence, the final assessment order dated 2 April 2014 is time barred and liable to be quashed. 2. At the time of hearing, the Ld.AR has submitted that the grounds of appeal no. 1 to 24 pertains to transfer pricing issues and ground

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

142. Since the issue before us is squarely covered by the aforesaid decision of the Hon'ble Supreme Court cited supra, there is no additional advantage for the assessee by getting the trademark registered. Respectfully following the aforesaid observations, we set aside the impugned order passed by the DRP and allow the ground no.12, raised by the assessee. 65 Viacom

SIRO CLINPHARM P. LTD,MUMBAI vs. DCIT CIR 3(3), MUMBAI

In the result, appeal of the assessee is allowed

section 247(7.1) of the ITA provides that the transfer pricing rules will not apply to guarantees provided by Canadian parent corporations in respect of certain financial commitments of their Canadian controlled foreign I.T.A. Nos. 2618 and 2876/Mum/2014 Assessment year: 2009-10 Page 25 of 56 affiliates to support the active business operations of those affiliates". As to what could

DCIT CIR 3(3), MUMBAI vs. SIRO CLINPHARM P.LTD, MUMBAI

In the result, appeal of the assessee is allowed

section 247(7.1) of the ITA provides that the transfer pricing rules will not apply to guarantees provided by Canadian parent corporations in respect of certain financial commitments of their Canadian controlled foreign I.T.A. Nos. 2618 and 2876/Mum/2014 Assessment year: 2009-10 Page 25 of 56 affiliates to support the active business operations of those affiliates". As to what could

3I INFOTECH LIMITED,MUMBAI vs. PR. CIT- 15, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm 3I Infotech Limited Pcit-15 Tower No.5, 5Th Floor, Aaykar Bhavan, 3Rd To 6Th Floors, Vs. International Infotech Park, Mumbai-400 020 Vashi, Navi Mumbai-400 703 (Appellant) (Respondent) Pan No. Aaaci5205Q Assessee By : Shri Bhupendra Karkhanis, Shri Jay Dharod, Ars Revenue By : Ms. Samruddhi Hande, Dr Date Of Hearing: 17.02.203 Date Of Pronouncement : 10.05.2023

transfer pricing study report for assessment year 2013 – 14 wherein at serial number 6 the transaction of conversion of redeemable preference shares into unsecured loans was mentioned at page number 33 of TPSR. He also referred to the notice issued under section 142

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

142(1) of Income-tax Act, 1961 (in short “Act”) were issued and served on the assessee. 8. Since assessee has entered into international transactions a reference under section 92CA(1) of the Act was issued to Transfer Pricing

BHAVANI GEMS P. LTD.,MUMBAI vs. PR. CIT -5, MUMBAI

Accordingly, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Amarjit Singh, Jm Bhavani Gems Private Limited The Pr. Commissioner Of Income Dw–1370, G–Block West Core, Tax–5, Room No. 515, 5Th Floor, Bharat Diamond Bourse, Bandra Aayakar Bhavan, M.K. Road, Vs. Kurla Complex, Bandra (East), Mumbai–400 020 Mumbai–400 051 (Appellant) (Respondent) Pan No. Aaecb9471D

Transfer Pricing Officer. He submitted that the large remittance were according to Form no. 15CA and 15CB submitted and did not have any co- relation for determination of Arms Length Price of the income transactions. Even otherwise section 142

HSBC ASSET MANAGEMENT (INDIA) P.LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

section 142(1) of the Act were issued and served on the assessee. Pursuant to the reference made by the AO, the Transfer Pricing

DCIT 1(1), MUMBAI vs. HSBC ASSET MANAGEMENT (I) P. LTD, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

section 142(1) of the Act were issued and served on the assessee. Pursuant to the reference made by the AO, the Transfer Pricing