DCIT RG. - 6(3), MUMBAI vs. M/S. KANSAI NEROLAC PAINTS LTD., MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Transfer Pricing Officer (TPO) in order to determine the Arm's Length Price (ALP) of the international transactions the assessee is having with its Associated Enterprises (AEs). The TPO proposed an adjustment of Rs.1,18,18,886/-. The Assessing officer passed the order dated January 30, 2012 under section 143(3) r.w.s 144C(3) of the Act, wherein besides

KANSAI NEROLAC PAINTS LTD,MUMBAI vs. DCIT RG 6(2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Transfer Pricing Officer (TPO) in order to determine the Arm's Length Price (ALP) of the international transactions the assessee is having with its Associated Enterprises (AEs). The TPO proposed an adjustment of Rs.1,18,18,886/-. The Assessing officer passed the order dated January 30, 2012 under section 143(3) r.w.s 144C(3) of the Act, wherein besides

M/S. KANSAI NEROLAC PAINTS LTD.,MUMBAI vs. DCIT RG. - 6(3), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Transfer Pricing Officer (TPO) in order to determine the Arm's Length Price (ALP) of the international transactions the assessee is having with its Associated Enterprises (AEs). The TPO proposed an adjustment of Rs.1,18,18,886/-. The Assessing officer passed the order dated January 30, 2012 under section 143(3) r.w.s 144C(3) of the Act, wherein besides

KANSAI NEROLAC PAINTS LIMITED (ERSTWHILE KNOWN AS GOODLASS NEROLAC PAINTS LIMITED),MUMBAI vs. ADDL CIT, RANGE 6 (2), MUMBAI

Accordingly we see no infirmity in the decision of CIT(A) and uphold the decision of the CIT(A). This ground of the revenue is dismissed

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Transfer Pricing Officer (TPO) in order to determine the Arm's Length Price (ALP) of the international transactions the assessee is having with its Associated Enterprises (AEs). The TPO proposed an adjustment of Rs.1,18,18,886/-. The Assessing officer passed the order dated January 30, 2012 under section 143(3) r.w.s 144C(3) of the Act, wherein besides

S.S. ORAL HYGIENE PRODUCTS P. LTD ( NOW MERGED WITH COLGATE PALMOLIVE (I) LTD),MUMBAI vs. DCIT 10(3), MUMBAI

In the result, appeals of the assessee are allowed and appeal of the learned

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Ss Oral Hygeine Products Private Dcit Cir 3(3) [Now Commissioner Ltd (Now Merged With Colgate – Of Income Tax – 10(3)] Palmolive (India) Ltd Room No. 450, 4 Th Floor, Aayakar Colgate – Palmolive (India) Vs. Bhavan, M.K. Road, Mumbai-400 Limited, Colgate Research Centre, 020 Main Street, Near Hiranandani Gardens, Powai, Mumbai- 400 076 (Appellant) (Respondent)

Transfer Pricing Officer vide order u/s 92 CA (3) of The Act dated 30th April, 2010, proposed a total adjustment of ₹5,02,99,706/-. Several other disallowances were made by the learned Assessing Officer. The addition of ₹19,55,313/- was made under Section 145A

SS ORAL HYGEINE PRODUCTS P.LTD (NOW MERGED WITH COLGATE-PALMOLIVE (INDIA) LTD),MUMBAI vs. DCIT CIR 3(3) ( NOW ADDL CIT 10(3), MUMBAI

In the result, appeals of the assessee are allowed and appeal of the learned

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Ss Oral Hygeine Products Private Dcit Cir 3(3) [Now Commissioner Ltd (Now Merged With Colgate – Of Income Tax – 10(3)] Palmolive (India) Ltd Room No. 450, 4 Th Floor, Aayakar Colgate – Palmolive (India) Vs. Bhavan, M.K. Road, Mumbai-400 Limited, Colgate Research Centre, 020 Main Street, Near Hiranandani Gardens, Powai, Mumbai- 400 076 (Appellant) (Respondent)

Transfer Pricing Officer vide order u/s 92 CA (3) of The Act dated 30th April, 2010, proposed a total adjustment of ₹5,02,99,706/-. Several other disallowances were made by the learned Assessing Officer. The addition of ₹19,55,313/- was made under Section 145A

DCIT CIR 3(3), MUMBAI vs. S.S ORAL HYGIENE PRODUCTS P.LTD, MUMBAI

In the result, appeals of the assessee are allowed and appeal of the learned

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal, Jm Ss Oral Hygeine Products Private Dcit Cir 3(3) [Now Commissioner Ltd (Now Merged With Colgate – Of Income Tax – 10(3)] Palmolive (India) Ltd Room No. 450, 4 Th Floor, Aayakar Colgate – Palmolive (India) Vs. Bhavan, M.K. Road, Mumbai-400 Limited, Colgate Research Centre, 020 Main Street, Near Hiranandani Gardens, Powai, Mumbai- 400 076 (Appellant) (Respondent)

Transfer Pricing Officer vide order u/s 92 CA (3) of The Act dated 30th April, 2010, proposed a total adjustment of ₹5,02,99,706/-. Several other disallowances were made by the learned Assessing Officer. The addition of ₹19,55,313/- was made under Section 145A

PIRAMAL GLASS PVT LTD.,MUMBAI vs. ASST CIT RANGE 7(3)(2), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Piramal Glass Pvt. Ltd Asst. Commissioner Of Income Tax (Earlier Known As Gujarat Glass Room No.123A, Ltd) Aaykar Bhavan Vs. Piramal Tower, Ganpatrao Kadam M.K. Road, Marg, Lower Parel, Mumbai-400 Mumbai-400 020 013 (Appellant) (Respondent) Pan No. Aabcg0093R

Transfer Pricing Officer for determination of Arm's Length Price vide order under section 92CA(3) dated 29th October, 2009 an upward adjustment of ₹2,62,05,329/- was proposed. Draft assessment order was passed on 30th November, 2009, wherein the above addition was made. The objections were filed before the learned Dispute Resolution Panel. The learned Dispute Resolution Panel

DCIT, 1(1)(1), MUMBAI vs. CABOT INDIA LTD., NAVI MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD.,MUMBAI vs. ACIT 15 (1) (2), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

ASST CIT 15(1)(2), MUMBAI vs. CABOT INDIA LTD, NAVI MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD.,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

CABOT INDIA LTD,MUMBAI vs. DCIT 1(1), MUMBAI

In the result ITA number 1911/M/2016 filed by the learned assessing officer for assessment year 2011 – 12 is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

transfer pricing officer that royalty payments are treated at arm‟s-length only when it is proved substantially by the taxpayer that such intangibles were actually used and further have benefited to the assessee. The learned dispute resolution panel while giving direction under section 144C (5) of the income tax act dated 7/9/2012 has held that the royalty payments

HINDUSTHAN UNILEVER LTD,MUMBAI vs. DY CIT RANGE 1(1)(2), MUMBAI

In the result, the appeal filed by the assessee and Revenue are partly\nallowed

pricing adjustments was dismissed.", "result": "Partly Allowed", "sections": [ "10B", "80IB", "80IC", "145A", "14A", "37(1)", "43(6)(c)", "1150" ], "issues": "The appeals and cross-objection dealt with issues including deductions under various sections, WDV calculation, Tsunami relief expenses, CENVAT credit, capital subsidy, and transfer

DCIT 1 (1)(2), MUMBAI vs. M/S HINDUSTAN UNILEVER LTD., MUMBAI

In the result, the appeal filed by the assessee and Revenue are partly\nallowed

transfer pricing was dismissed.", "result": "Partly Allowed", "sections": [ "Sec. 80IB", "Sec. 80IC", "Sec. 10B", "Sec. 145A", "Sec. 14A", "Sec. 37(1)", "Sec. 43(6)(c)", "Sec. 43(1)", "Sec. 115O