ESSEL MINING & INDUSTRIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX - CENTRAL CIRCLE 1(4), MUMBAI

In the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year the result, the appeal of the Revenue for assessment year

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12 & Assessment Year: 2012-13 Essel Mining & Industries Ltd., Dy. Cit, Central Circle-1(4), Industry House, 18Th Floor, 10, 9Th Floor, Old Cgo Building, Camac Street, Vs. Mk Road, Kolkata-700017. Mumbai-400020. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 & Assessment Year: 2012-13 Jcit, Central Circle-1(4), M/S Essel Mining & Industries Room No. 902, Pratishtha Ltd., Bhavan, 9Th Floor, Old Cgo Vs. Industry House, 18Th Floor, 10, Building Annexe, Camac Street, Mumbai-400020. Kolkata-700017. Pan No. Aaace 6607 L Appellant Respondent Assessment Year: 2011-12 M/S Essel Mining & Industries Dy. Cit, Central Circle-1(4), Ltd., 9Th Floor, Old Cgo Building, Vs. Industry House, 18Th Floor, 10, Mk Road

3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of In ground No. 3, the Revenue is aggrieved with the deletion of disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA of the Act amounting to disallowance of deduction u/s 80IA

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

In the result, the appeal of the assessee is allowed

143(3) read with section 144C(3) of the Income-tax Act, 1961 is void and bad in law as it has been passed beyond the period of limitation referred to in section 153 of the Act. Additional Ground No.3 3. The learned CIT(A) erred in confirming the action of the learned AO of not allowing the claim

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

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

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

DCIT 15(1)(2), MUMBAI vs. COLGATE PALMOLIVE (INDIA) LTD., MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

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

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

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

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

COLGATE -PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

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

pricing officer for passing an order under section 92CA a further period available for completion of the assessment was to be extended by 12 months. Thus, the time limit for passing order under section 143 (3) was available up to 31/12/2016. According to the provisions of section 92CA (3A) the transfer

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONI AND COMPANY PRIVATE LIMITED, MUMBAI

143(3)", "Section 144C(3)", "Section 92B", "Section 35DD", "Section 43B", "Section 92CA(1)", "Section 115JB", "Section 153" ], "issues": "1. Whether the issuance of letters of comfort, financial guarantees, and performance guarantees by the assessee to its AEs constituted international transactions and whether 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)

Pricing Addition. Since the Assessee preferred not to file any objections before the Dispute Resolution Panel, the Assessing Officer passed the Assessment Order, dated 20/04/2016 under Section 143(3) read with Section 144C(3) of the Act. After making the aforesaid Transfer

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)

Pricing Addition. Since the Assessee preferred not to file any objections before the Dispute Resolution Panel, the Assessing Officer passed the Assessment Order, dated 20/04/2016 under Section 143(3) read with Section 144C(3) of the Act. After making the aforesaid Transfer

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

Pricing Addition.\nSince the Assessee preferred not to file any objections before the\nDispute Resolution Panel, the Assessing Officer passed the\nAssessment Order, dated 20/04/2016 under Section 143(3) read\nwith Section 144C(3) of the Act. After making the aforesaid Transfer

M/S. ATUL PROJECTS INDIA PVT LTD.,,MUMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA P LTD,MUMBAI vs. DCIT- 9(1)(2) (NOW JURIDICTION WITH DC CC 2(4)), MUMBAI

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA PVT LTD.,,MUMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA PVT LTD.,,MUMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

M/S. ATUL PROJECTS INDIA PVT LTD.,,MIMBAI vs. DCIT- 9(1)(2), ( NOW JURIDICTION WITH DC CC-2(4), MUMBAI

Bench: Ms. Kavitha Rajagopal () & Ms. Padmavathy S. ()

143(3) of the Act dated 29.12.2016 did not allow the deduction claimed by the assessee under section 80IB(10) for Rs.86,30,612/- for the reason that –  The deduction was not claimed in the original return of income filed under section 139(1) and, therefore, not allowable as per provision of section 80AC;  Certain units are having the built

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 compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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 compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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 compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

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 compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section