JOHNSON & JOHNSON PVT. LTD.,MUMBAI vs. ACIT - LTU-1, MUMBAI

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

transfer pricing order, the ld AO should not have passed the draft assessment order. Thus provision of section 144C does not apply to the assessee. Thus, the time limit for completion of the assessment reverts back to 21 Months from the end of the assessment year. Therefore, as held by the co-ordinate Bench in ATOS India Private Limited (supra

JOHNSON &JOHNSON P.LTD,MUMBAI vs. THE DCIT/ACIT/JT/ITO/NFAC, DELHI

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm

transfer pricing order, the ld AO should not have passed the draft assessment order. Thus provision of section 144C does not apply to the assessee. Thus, the time limit for completion of the assessment reverts back to 21 Months from the end of the assessment year. Therefore, as held by the co-ordinate Bench in ATOS India Private Limited (supra

SHELL INDIA MARKETS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(4), MUMBAI

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

section 144B, sustaining the transfer pricing\nadjustments as well as the disallowance under section\n40(a)(ia).\n6. Aggrieved, the assessee

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

transfer pricing adjustment.\n2.6 In pursuance of the DRP's directions, the Assessing Officer\npassed the final assessment order dated 23.10.2025 under\nsection 143(3) read with sections 144C(13) and 144B

M/S. NATUREX INDIA PVT. LTD,MUMBAI vs. NFAC, DELHI DCIT-CIR 2(3) (1), MUMBAI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Vikas Awasthy & Shri Gagan Goyalm/S. Naturex India Pvt. Ltd. 502, 5Th Floor, Akruti Centre Point, Midc Central Road, Andheri (East), Chakala Midc S.O. Mumbai-400093 Pan: Aabcv0883A ..... Appellant Vs. Nfac, Delhi/Dcit Cir. 2(3) (1) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

transfer price of the Appellant in respect of the payment of management service fee of INR 3, 01, 42,197/- to Associated Enterprises ('AEs'), holding that this international transaction does not satisfy the arm's length principle envisaged under the Act and in specific in doing so grossly erred in: 2.1 Disregarding the evidence placed on record by labelling them

DCIT -5(2) (1) , MUMBAI vs. KEC INTERNATIONAL LTD, MUMBAI

Accordingly, Ground No. 3.1 & 3.2 raised by the Assessee are dismissed

section 144B of the Act. 1.2. The Appellant prays that the draft assessment order be held as bad in law and consequently, the assessment proceedings and the final assessment order be quashed. 2. Transfer pricing

M/S. LAXMI ORGANIC INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Section 144C(8), does not extend to\npicking up and making an enhancement of income in respect of an item\nin respect of which no variation is proposed in the impugned assessment\norder, and in the impugned assessment order. the \"variation\" proposed\nis with respect to Arm's length price for the sale of electricity only:\n(f) erred

APM TERMINALS INDIA PRIVATE LIMITED,MUMBAI vs. THE DY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), MUMBAI

In the result, ground No.1 of the appeal of the assessee is allowed, holding that the assessment order passed by the learned Assessing Officer is barred by limitation and hence quashed

Bench: Shri. Prashant Maharishi, Prashant Maharishi & Shri Sandeep Singh Karhailsandeep Singh Karhail

section 144B of the Income Tax Act (the A Act (the Act) dated 31/7/2022 by the assessment 2022 by the assessment unit, determining the total income of the assessee at determining the total income of the assessee at determining the total income of the assessee at Rs.11,64,10,372/ 10,372/– making transfer pricing

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

transfer pricing adjustment of INR 16,59,51,699/- which incorporated in the Draft Assessment Order dated 22/04/2021, passed under Section 143(3) read with Section 144B

OMNIACTIVE HEALTH TECHNOLOGIES LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 8(2)(1), AAYAKAR BHAWAN, MUMBAI

In the result, assessee’s appeal is allowed for statistical purposes

Bench: SHRI NARENDRA KUMAR BILLAIYA (Accountant Member), SHRI SUNIL KUMAR SINGH (Judicial Member)

section 144B of the Income tax Act, 1961 ("the Act") in pursuance to the directions dated 18 June 2024 issued by the Hon'ble Dispute Resolution Panel ('DRP") u/s 144C(5) of the Act, for the aforesaid assessment year on the grounds set out herein; 3 Omniactive Health Technologies Limited 1:0 Transfer Pricing

UPS EXPRESS PRIVATE LIMITED,MUMBAI vs. DEPUTY C/ASSISTANT COMMISSIONER OF INCOME TAX 3(1)(1), MUMBAI

In the result the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Renu Jauhri ()

144B of the Act beyond the time limit as specified under Section 153 of the Act. The Appellant submits that the assessment order being barred by limitation is without jurisdiction and void ab initio and hence, the same is liable to be quashed 3. Ground No. 3-Transfer Pricing

KBS CREATION LTD ,MUMBAI vs. DY COMM. OF INCOME TAX -CIRCLE 24(1), MUMBAI

In the result, the concise ground of appeal of the assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

transfer pricing provisions prescribed procedure for arriving at arm’s length price in a systematic manner in the Act. The TPO has rigorously applied various filters as applicable. There cannot be exceptions on application of filters as to industry class or to any specific assessee. The DRP justified turn over filter, export turnover filter, RPT filter by referring various case

EDWARDS LIFESCIENCES (INDIA) PVT LTD,MUMBAI vs. ACIT-2(1)(1), MUMBAI

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

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailedwards Lifesciences (India) Pvt. Ltd., 4Th Floor Commerz – Ii, International Business Park Oberoi Garden City, Goregaon (East), Off Western Express Highway Goregaon (East), ............... Appellant Mumbai - 400063 Pan : Aaacb4203F V/S Assistant Commissioner Of Income Tax, Circle-2(1)(1), ……………… Respondent Kautilya Bhawan, Bkc, Mumbai - 400012 Assessee By : Ms. Chandni Shah Ms. Riddhi Maru Ms. Kinjal Patel Revenue By : Shri Bhagirath Ramawat, Sr.Dr

144B of the Income Tax Act, 1961 (“the Act”) pursuant to the directions issued by the learned Dispute Resolution Panel (“learned DRP”) under section 144C(5) of the Act, for the assessment year 2021-22. 2. In this appeal, the assessee has raised the following grounds: - 2 “Grounds pertaining to Transfer Pricing

GOLDMAN SACHS (INDIA) SECURITIES PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, DELHI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

transfer pricing adjustment for non-binding investment advisory and support services lacked merit. For IT-enabled services, the issue of comparability of R Systems International Ltd. was remanded to the TPO/AO for fresh adjudication.", "result": "Partly Allowed", "sections": [ "143(3)", "144C(13)", "144B

CAPITA INDIA PRIVATE LIMITED,MUMBAI vs. ASSESSMENT UNIT, NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), MUMBAI

sections": [ "143(3)", "144C(13)", "144B", "144C(5)", "153", "92CA", "115P", "143(1)", "234A", "234B", "92CA(1)", "92CA(3)" ], "issues": "The primary issues were the correctness of the transfer pricing

KGK CREATIONS PRIVATE LIMITED,MUMBAI vs. CIRCLE 2(2)(1), MUMBAI

In the result, ground No. 9 to 13 are allowed

Bench: Shri Pawan Singh & Shri Girish Agrawalkgk Creations Private Limited Jurisdiction Assessing Officer Gj-10, Seepz Sez, Seepz S.O. Vs. (Jao) Mumbai 400096, Circle 2(2)(1), Mumbai Aayakar Pan No. Aabck0378H Bhawan, Mumbai Appellant/ Assessee Respondent/ Revenue Assessee Represented By Shri Vijay Mehta Ca / Ar Department Represented By Shri Kiran Unavekar Sr. Dr. Date Of Hearing 17/03/2025 Date Of Pronouncement 28/03/2025

section 144C(13) read with 144B of the Indian Income-tax Act, 1961 ("the Act") in pursuance of the directions issued by the Hon'ble Dispute Resolution Panel-II, Delhi ("DRP") on the following grounds of appeal, which are without prejudice to each other: A. General ground 1. The Learned Additional / Joint Commissioner of Income-Tax, Transfer Pricing

MICHAEL PAGE INTERNATIONAL RECRUITMENT PVT LTD,MUMBAI vs. DCIT CIRCLE 14(1)(1), MUMBAI

sections": [ "143(3)", "144C(13)", "144B", "144C(5)", "153", "37", "41", "92CA(1)", "92D", "92C(3)", "92C(1)", "10D", "92C", "10B", "10A" ], "issues": "Whether the transfer pricing

ARIES AGRO LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX CIRCLE 14(1)(1), MUMBAI

Accordingly, the transfer pricing addition of INR.103,26,939/- is deleted. Ground No. 1 raised by the Appellant is allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

144B of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], as per the direction issued by Dispute Resolution Panel (1), Mumbai [for short ‘DRP’] on 25/09/2023 under Section 144C(5) of the Act for the Assessment Year 2020-2021. A.Y.2020-21 2. The Appellant has raised following grounds of appeal : “1. On the facts and in the circumstances

DSV AIR & SEA PVT. LTD (SUCESSSOR TO PANALPINA WORLD TRANSPORT (INDIA PVT. LTD,MUMBAI vs. ADDL /JT/ACIT/ ITO/NFAC, DELHI

Bench: Shri Baskaran Br & Shri Kuldip Singhassessment Year: 2017-18

Pricing Officer (TPO) under section 143(3) read with section 144C(13) of the ITA No.796/M/202 2 M/s. DSV Air & Sea Pvt. Ltd. [Successor to Panalpina World Transport (India) Pvt. Ltd.] Income Tax Act, 1961 (for short 'the Act') qua the assessment year 2017-18 on the grounds inter-alia that: “General Ground 1. erred in assessing the total income