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1,022 results for “transfer pricing”+ Section 148(1)clear

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Key Topics

Section 143(3)119Addition to Income63Section 14843Section 14738Section 6838Disallowance29Section 115J26Section 26324Section 92C23

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. DCIT 9(3)(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

148 ITD 513 (Mum.); and vii) DCIT v/s M/s. Diebold Software Services Pvt. Ltd., ITA no. 4347/Mum./2012, dated 02.04.2014. 20. The learned Departmental Representative relying upon the observations of the DRP and the Transfer Pricing Officer submitted that the assessee did not file proper documentary evidences before the Transfer Pricing Officer to prove availing of services. He submitted

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

Showing 1–20 of 1,022 · Page 1 of 52

...
Long Term Capital Gains23
Section 69C22
Transfer Pricing21
ITA 884/MUM/2016[2011-12]Status: Disposed
ITAT Mumbai
17 May 2024
AY 2011-12
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

price at which these are transferred to the pre-paid distributors. No payment or credit was made by the Assessee to its pre-paid distributors. In fact, it was the pre-paid distributors who make a payment to the Assessee for transferring pre-paid talk time and connections and accordingly the discount extended was not income earned by the distributors

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

ITA 2003/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing officer. During the proceedings, details

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

ITA 2005/MUM/2023[2019-20]Status: DisposedITAT Mumbai29 Nov 2023AY 2019-20

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing officer. During the proceedings, details

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

ITA 2004/MUM/2023[2018-19]Status: DisposedITAT Mumbai29 Nov 2023AY 2018-19

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing officer. During the proceedings, details

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

ITA 2002/MUM/2023[2012-13]Status: DisposedITAT Mumbai29 Nov 2023AY 2012-13

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

For Appellant: Shri Devendra Jain &For Respondent: Shri Vivek Perumpura
Section 131Section 143Section 147Section 148Section 263Section 271BSection 68Section 92C

section 148 of the act and reference was made to the learned transfer pricing officer in terms of Para number 3.3 of the instruction number 3/2016 and survey findings were also shared ITA No. 2002-05/Mum/2023 A.Y. 2012-13, 17-18, 18-19, 19-20 ZENZI PHARMECEUTICAL INDUSTRIES PVT. Ltd. with the transfer pricing officer. During the proceedings, details

NAVNIDHI STEEL AND ENGG CO. P.LTD,MUMBAI vs. DCIT 5(2)(1), MUMBAI

The appeal of the assessee is dismissed

ITA 3420/MUM/2017[2007-08]Status: DisposedITAT Mumbai08 Jan 2018AY 2007-08

Bench: Shri Joginder Singh, Assessment Year: 2007-08

Section 133(6)Section 143(1)Section 143(2)Section 148Section 68Section 69C

transferred to some other account. (iv) It means that Bhanwarlal Jain Group companies are providing only accommodation entries and no genuine transactions. In the light of the above facts, the Ld. Assessing Officer treated the amount of Rs.25 lakhs taken as loans/advances as unexplained cash credit u/s 68 of the Act. 2.2. On appeal before the Ld. Commissioner of Income

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

section 40(a)(ia) of the Act at ` 5,68,97,341. 144. The assessee is engaged in the business of broadcasting and telecasting of television channels. Accordingly, it incurs up–linking charges in connection with its broadcasting business. For the assessment year 2009-10, the assessee paid ` 5,68,97,341, towards up–linking fees to Television Eighteen India

TIMES INFOTAINMENT MEDIA LTD,MUMBAI vs. ASST CIT RG 1(3), MUMBAI

In the result, all the three appeal are allowed in the terms indicated above

ITA 7523/MUM/2014[2010-11]Status: DisposedITAT Mumbai30 Aug 2021AY 2010-11
Section 143(3)

148,480/- has been issued but the Appellant had received no such refund order. Initiation of penalty proceedings under section 271(1)(c) of the Act 18. erred in initiating penalty proceedings under section 271(1)(c) of the act. 5. Coming to the appeal for the assessment year 2012-13, which is directed against the order dated 22nd December

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 6405/MUM/2024[2011-12]Status: DisposedITAT Mumbai26 Jun 2025AY 2011-12

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2472/MUM/2025[2018-19]Status: DisposedITAT Mumbai26 Jun 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2471/MUM/2025[2017-18]Status: DisposedITAT Mumbai26 Jun 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2470/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Jun 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2469/MUM/2025[2015-16]Status: DisposedITAT Mumbai26 Jun 2025AY 2015-16

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC-4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2468/MUM/2025[2014-15]Status: DisposedITAT Mumbai26 Jun 2025AY 2014-15

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

HEMENDRA RAMJI VIRA ,MUMBAI vs. DCIT CC 4(1), MUMBAI

In the result, appeals of the assessee are allowed

ITA 2467/MUM/2025[2013-14]Status: DisposedITAT Mumbai26 Jun 2025AY 2013-14
Section 127(2)Section 132Section 132(1)Section 142(1)Section 143(2)Section 147Section 148Section 153ASection 56Section 68

transfer under section 127, all proceedings past, pending, and prospective, shift with it, as made abundantly clear in the Explanation to that section. The officer who has lost jurisdiction becomes a persona non grata to that file; any action initiated by such an officer thereafter is bereft of legal sanctity. Consequently, as the very substratum of the reassessment, the notice

VODAFONE INDIA LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-8(3)(2), MUMBAI

ITA 2834/MUM/2017[2012-13]Status: DisposedITAT Mumbai17 May 2024AY 2012-13
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

1,97,54,77,395/- proposed in the Draft Assessment Order)\nin respect of roaming charges.\n6.3. Being aggrieved, the Assessee has carried the issue in appeal\nbefore the Tribunal.\n6.4. We have considered the rival submissions and perused the\nmaterial on record.\n6.5. We note that in the identical facts and circumstances, the\nTribunal has, vide order dated 08/11/2023

DCIT 8(3)(2), MUMBAI vs. M/S VODAFONE IDEA LIMITED (EARLIER KNOWN AS VODAFONE INDIA LIMITED WHICH NOW STANDS MERGED WITH IDEA CELLULAR LIMITED (ICL) AND CONSEQUENTLY KNOWN AS VODAFONE IDEA LIMITED), MUMBAI

ITA 1919/MUM/2016[2011-12]Status: DisposedITAT Mumbai17 May 2024AY 2011-12
Section 115JSection 143(3)Section 144C(13)Section 144C(5)Section 14ASection 234DSection 271(1)(c)Section 36(1)(iii)Section 37Section 40

1,97,54,77,395/- proposed in the Draft Assessment Order)\nin respect of roaming charges.\n6.3. Being aggrieved, the Assessee has carried the issue in appeal\nbefore the Tribunal.\n6.4. We have considered the rival submissions and perused the\nmaterial on record.\n6.5. We note that in the identical facts and circumstances, the\nTribunal has, vide order dated 08/11/2023

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-4(3), CENTRAL RANGE-4, MUMBAI vs. M/S.GROWMORE RESEARCH & ASSET MANAGEMENT LIMITED, MUMBAI

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 1196/MUM/2019[1991-92]Status: DisposedITAT Mumbai30 Mar 2021AY 1991-92

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 1991-92 Dcit, M/S. Growmore Research Cent. Cir.-4(3) & Assets Management Central Range-4, Ltd., Room No.1921, 32, Madhuli Apartment, Vs. 19Th Floor, 3Rd Floor, Air India Bldg., Dr. Annie Besant Road, Nariman Point, Worli, Mumbai – 400 018 Mumbai - 400021 Pan: Aaacg4936C (Appellant) (Respondent) Assessment Year: 1991-92 M/S. Growmore Research Dcit & Assets Management Cent. Cir.-4(3), Ltd., Central Range-4, 32, Madhuli Apartment, Room No.1921, 3Rd Floor, Vs. 19Th Floor, Dr. Annie Besant Road, Air India Bldg., Worli, Mumbai – 400 018 Nariman Point, Pan: Aaacg4936C Mumbai - 400021

For Appellant: Shri Dharmesh Shah, A.RFor Respondent: Dr. P. Daniel, D.R
Section 147Section 14ASection 234Section 69

1) that in cases where the Assessing Officer had reason to believe that income had escaped assessment a notice had to be issued to an assessee for filing return of income within a specified period, not being less than thirty days. The (italicised in portion) became subject-matter of dispute in proceedings pending before various High Courts. In certain cases

M/S. GROWMORE RESEARCH & ASSETS MANAGEMENT LTD.,MUMBAI vs. DCIT CENT. CIR. - 4(3), MUMBAI

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 504/MUM/2019[1991-92]Status: DisposedITAT Mumbai30 Mar 2021AY 1991-92

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 1991-92 Dcit, M/S. Growmore Research Cent. Cir.-4(3) & Assets Management Central Range-4, Ltd., Room No.1921, 32, Madhuli Apartment, Vs. 19Th Floor, 3Rd Floor, Air India Bldg., Dr. Annie Besant Road, Nariman Point, Worli, Mumbai – 400 018 Mumbai - 400021 Pan: Aaacg4936C (Appellant) (Respondent) Assessment Year: 1991-92 M/S. Growmore Research Dcit & Assets Management Cent. Cir.-4(3), Ltd., Central Range-4, 32, Madhuli Apartment, Room No.1921, 3Rd Floor, Vs. 19Th Floor, Dr. Annie Besant Road, Air India Bldg., Worli, Mumbai – 400 018 Nariman Point, Pan: Aaacg4936C Mumbai - 400021

For Appellant: Shri Dharmesh Shah, A.RFor Respondent: Dr. P. Daniel, D.R
Section 147Section 14ASection 234Section 69

1) that in cases where the Assessing Officer had reason to believe that income had escaped assessment a notice had to be issued to an assessee for filing return of income within a specified period, not being less than thirty days. The (italicised in portion) became subject-matter of dispute in proceedings pending before various High Courts. In certain cases