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

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

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

In the result, appeals filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

transfer pricing order is invalid and thus entire assessment is bad in law as provisions of section 144C(1) of the Act are not applicable to the Appellant; Final assessment order passed is time barred - The ground was requested to be kept as academic. 1. Without prejudice to the above, the Ld. AO erred in not passing the final assessment

MAERSK TANKERS INDIA PRIVATE LIMITED,MUMBAI vs. THE ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, MUMBAI

transfer pricing risk, and (iii) depreciation.\nStatutory notices under sections 143(2) and 142(1) were issued,\nand the assessee

TATA CHEMICALS LTD,MUMBAI vs. ADDL CIAT 2(3), MUMBAI

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

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

section 14A regardless of whether they are direct or indirect, fixed or variable and managerial or financial in accordance with law. It is further evident that deduction in respect of expenditure incurred by the assessee in relation to exempt income and taxable income has to be determined as per mechanism laid down in section 14A and in accordance with

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI, MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.), MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

Section 37 of the Act and genuineness of the expenditure?\"\"\nBrief facts of the case are as under:\n3. The assessee, an Indian company, and is a part of U.T. Worldwide Group U.K. It is submitted that the assessee belongs to a group that is world leader in international flight forwarding business. The assessee is engaged in the business

DEPUTY COMMISSIONER OF INCOME TAX- 3(1)(1), MUMBAI vs. DSV SOLUTIONS PVT. LTD. (FORMERLY UT WORLDWIDE (INDIA) PVT. LTD.) , MUMBAI

In the result, the appeals filed by the revenueand cross\nobjections filed by the assesse for 2012-13, 2013-14 & 2014-\n15 under consideration stand dismissed

Section 37 of the Act and\ngenuneness of the expenditure?\"\nBrief facts of the case are as under:\n3. The assessee, an Indian company, and is a part of U.T.\nWorldwide Group U.K. It is submitted that the assessee belongs\nto a group that is world leader in international flight forwarding\nbusiness. The assessee is engaged in the business

DCIT(CC)-8(3), MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

142 Basis points for the year under consideration. Assessee also considered an additional spread of basis point of LIBOR and computed the interest at Rs.6,27,50,560/-. Assessee provided following working in respect of same:- 5. The Ld.TPO was not convinced with the assessee’s methodology to compute interest on floating rate. He also rejected the comparables selected

DCIT CC 3(2) CEN RG 3, MUMBAI vs. WORLD SPORTS (INDIA) P . LTD, MUMBAI

In the result, CO of the assessee is allowed and departments appeal stands dismissed

Transfer Pricing Order is barred by limitations and, therefore, void ab initio. The Appellant pray that the same be quashed. 2. The Assessing Officer erred in passing the final order dated 27.05.2014, beyond the period of limitation prescribed under section 153 of the Act. The Appellants submit that the Assessment Order is barred by limitations and, therefore, void ab initio

HERE SOLUTIONS INDIA PRIVATE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 10 (1)(1), MUMBAI

In the result, the appeal by the assessee is allowed

142(1) of the\nAct were issued and served on the assessee. Pursuant to the reference by the\nAssessing Officer (“AO”) under section 92CA(1) of the Act, the Transfer Pricing

VVF (INDIA) LIMITED,MUMBAI vs. INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE , MUMBAI

In the result appeal filed by the assessee stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

section 143(2) along with 142(1) of the act was issued. In response to statutory notices, the representative of assessee appeared before the Ld.AO and filed requisite details as called for. 2.1. The Ld.AO noted that, the assessee had international transaction with its associated enterprise. Accordingly reference was made to the transfer pricing

M/S. EMERSON PROCESS MANAGEMENT (INDIA) PVT. LTD (SUCESSOR IN INTEREST FOR PENTAIR VALVES AND CONTROLS PVT LTD,MUMBAI vs. ADDL/JT/CIT/DY/ACIT/NFAC, MUMBAI

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

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

Transfer Pricing Officer passed an order under Section 92CA(3) of the Act in the name of Pentair Valves and Controls India Private Limited. On 11th February, 2021, in response to notice under vii Section 142

M/S. EMERSON PROCESS MANAGEMENT (INDIA) PVT. LTD (SUCESSOR IN INTEREST FOR PENTAIR VALVES AND CONTROLS PVT LTD,MUMBAI vs. ADDL/JT/CIT/DY/ACIT/NFAC, MUMBAI

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

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

Transfer Pricing Officer passed an order under Section 92CA(3) of the Act in the name of Pentair Valves and Controls India Private Limited. On 11th February, 2021, in response to notice under vii Section 142

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

transfer pricing adjustment cannot be made on adhoc basis. The TPO has to apply one of the prescribed method as is notified during the relevant point of time. We see no plausible reason to sustain the addition, hence, the adjustment on account of purchase of property from Hispano is liable to be deleted. We hold and direct accordingly

ACIT (IT)-4(2)(2), MUMBAI vs. STANDARD CHARTERED BANK LTD., MUMBAI

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

section 40(a)(i) of the\nAct. During the current assessment year, the matter was referred to the\nTransfer Pricing Officer and Transfer Pricing Officer has considered the\nvarious submissions submitted before him and he allowed about 60% of\nthe cost allocated to the Indian Branch based on the detailed submissions\nmade by the assessee justifying the allocation

STANDARD CHARTERED BANK,MUMBAI vs. DDIT(IT) 2 (1), MUMBAI

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

section 40(a)(i) of the\nAct. During the current assessment year, the matter was referred to the\nTransfer Pricing Officer and Transfer Pricing Officer has considered the\nvarious submissions submitted before him and he allowed about 60% of\nthe cost allocated to the Indian Branch based on the detailed submissions\nmade by the assessee justifying the allocation

STANDARD CHARTERED BANK,MUMBAI vs. DDIT(IT) 2 (1), MUMBAI

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

section 40(a)(i) of the\nAct. During the current assessment year, the matter was referred to the\nTransfer Pricing Officer and Transfer Pricing Officer has considered the\nvarious submissions submitted before him and he allowed about 60% of\nthe cost allocated to the Indian Branch based on the detailed submissions\nmade by the assessee justifying the allocation

OMNI ACTIVE HEALTH TECHNOLOGIES LIMITED,MUMBAI vs. ADDL/JT/DY/ASST/CIT/ITO/NFAC, DELHI

142(1)/143(2) were issued to the Appellant. During the assessment proceedings, the Assessing Officer noted that the Appellant had entered into international transactions with Associated Enterprises (AEs) and therefore, a reference was made to the Transfer Pricing Officer (TPO) for computation of Arm’s Length Price (ALP) under Section