PROCTER & GAMBLE HOME PRODUCTS P.LTD,MUMBAI vs. DCIT 3(3)(1), MUMBAI

The appeals of the assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am Aayakr Apila Sam./ Ita No. 1095/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2012-13) Aayakr Apila Sam./ Ita No. 1096/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 1097/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2014-15)

section of TNMM over the other methods as the most appropriate method in its study report, but the AO could not point out any reason to deviate from the same as to why any other method is to be applied. He stated that even the assessee has selected TNMM Method over the other methods, as the most appropriate method

PROCTER & GAMBLE HOME PRODUCTS P.LTD,MUMBAI vs. DCIT 3(3)(1), MUMBAI

The appeals of the assessee are allowed

Bench: Sri Mahavir Singh, Jm & Sri Manoj Kumar Aggarwal, Am Aayakr Apila Sam./ Ita No. 1095/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2012-13) Aayakr Apila Sam./ Ita No. 1096/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 1097/Mum/2019 (Inaqa-Arna Baya- / Assessment Year 2014-15)

section of TNMM over the other methods as the most appropriate method in its study report, but the AO could not point out any reason to deviate from the same as to why any other method is to be applied. He stated that even the assessee has selected TNMM Method over the other methods, as the most appropriate method

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

transfer-pricing adjustment in respect of ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 transaction of provision for guarantee by applying the rate of 0.5% of the guarantee amount. 2. The learned assessing officer/DRP has erred in disallowing an amount of ₹ 54,199,690/– under section 14 A of the act. 3. The learned assessing officer/DRP

MACROTECH DEVELOPRS LTD,MUMBAI vs. DY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

transfer-pricing adjustment in respect of ITA Nos. 2266 & 2239/Mum/2022 Macrotech Developers Ltd; A.Ys. 17-18 & 18-19 transaction of provision for guarantee by applying the rate of 0.5% of the guarantee amount. 2. The learned assessing officer/DRP has erred in disallowing an amount of ₹ 54,199,690/– under section 14 A of the act. 3. The learned assessing officer/DRP

GEMOLOGICAL INSTITUTE OF AMERICA, INC,MUMBAI vs. DCIT (IT) RG 2(3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

GEMOLOGICAL INSTITUTE OF AMERICA INC.,MUMBAI vs. DCIT (IT) 2(3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

GEMOLOGICAL INSTITUTE OF AMERICA INC.,MUMBAI vs. ASST CIT (IT) CIRCLE- 2 (3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

GEMOLOGICAL INSTITUTE OF AMERICA, INC,MUMBAI vs. DCIT (IT) RG 2(3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

GEMOLOGICAL INSTITUTE OF AMERICA INC. ,MUMBAI vs. DCIT(IT) CIR. 2(3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

GEMOLOGICAL INSTITUTE OF AMERICA INC. ,MUMBAI vs. ASST CIT (IT) CIRCLE- 2 (3)(2), MUMBAI

In the result, the appeal for the assessment year 2016-17 is also partly allowed in the terms indicated above

transfer pricing, any such adjustment in royalty income can be allowed to the assessee as a result of an APA to which the assessee is not even a party. Whichever way one looks at it, the core issue really is whether or not the quantification of royalty income in the hands of the assessee will stand reduced by the refund

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. DCIT CIR 5(3)(2), MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

transfer pricing adjustment. 11. Further the learned assessing officer noted that assessee company has shown an amount of ₹ 423,053,242/– as dividend income out of which a sum of ₹ 8,151,229 has been treated as expenditure attributable to earning of dividend income and amount of ₹ 413,198,013 has been claimed as exempt under section

DCIT CIR 5(3)(2), MUMBAI vs. THE GREAT EASTERN SHIPPING CO. LTD, MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 Nd Floor, Vs. Room No.525B, 5 Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 Nd Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

transfer pricing adjustment. 11. Further the learned assessing officer noted that assessee company has shown an amount of ₹ 423,053,242/– as dividend income out of which a sum of ₹ 8,151,229 has been treated as expenditure attributable to earning of dividend income and amount of ₹ 413,198,013 has been claimed as exempt under section

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

transfer pricing adjustment. 11. Further the learned assessing officer noted that assessee company has shown an amount of ₹ 423,053,242/– as dividend income out of which a sum of ₹ 8,151,229 has been treated as expenditure attributable to earning of dividend income and amount of ₹ 413,198,013 has been claimed as exempt under section

THE GREAT EASTERN SHIPPING CO. LTD,MUMBAI vs. ASST CIT CIR 5(3)(2), MUMBAI

In the result, appeal of the assessee (ITA number 1597/M/2018) is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Am & Shri Narfendrakumar Choudhary , Jm & & The Great Eastern Shipping Co. The Dy. Commissioner Of Ltd. Income-Tax, Kalyaniwalla & Mistry Llp Range-5(3), Esplanade House, 2 N D Floor, Vs. Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Fort, Mumbai-400 001 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaact1565C The Dy. Commissioner Of Income- The Great Eastern Shipping Co. Tax, Ltd. Range-5(3), Kalyaniwalla & Mistry Llp Vs. Esplanade House, 2 N D Floor, Room No.525B, 5Th Floor, M.K. Marg, 29, Hazarimal Somani Marg, Mumbai-400 020 Fort, Mumbai-400 001 (Appellant) (Respondent)

transfer pricing adjustment. 11. Further the learned assessing officer noted that assessee company has shown an amount of ₹ 423,053,242/– as dividend income out of which a sum of ₹ 8,151,229 has been treated as expenditure attributable to earning of dividend income and amount of ₹ 413,198,013 has been claimed as exempt under section

DCIT-14(3)(1), MUMBAI vs. WNS GLOBAL SERVICES PVT LTD., MUMBAI

In the result appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

Section 32 (1) of the act. Therefore the assessee claimed depreciation at the rate of 25% on the written down value of the same amounting to ₹ 518,502,824/–. The learned AO did not allow the depreciation as according to him the rights acquired by the assessee may be a commercial right but are different then the commercial right

WNS GLOBAL; SERVICES PVT LTD.,MUMBAI vs. DY CIT CIRCLE- 14 (3)(1), MUMBAI

In the result appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Cross Objection No. 52/Mum/2020 (Arising In Ita No. 2383/Mum/2019 For A.Y. 10-11)

Section 32 (1) of the act. Therefore the assessee claimed depreciation at the rate of 25% on the written down value of the same amounting to ₹ 518,502,824/–. The learned AO did not allow the depreciation as according to him the rights acquired by the assessee may be a commercial right but are different then the commercial right

CLSA INDIA P.LTD,MUMBAI vs. DCIT CIR 4(1)(1), MUMBAI

In the result, the appeal is allowed

Bench: Shri C N Prasad & Shri Rajesh Kumarassessment Year : 2011 -12 Clsa India P. Ltd., Dcit Cir 4(1)(1), (Formerly Cls India Ltd) Mumbai Vs. 8/F, Dalamal House, Nariman Point, Mumbai 400 021. Pan Aaacc2262K (Appellant) (Respondent)

transfer pricing study report and allowed exclusion of one TPO comparable company i.e. Motilal Investment Advisors Pvt. Ltd. According, as per the directions of the DRP the TPO computed the addition at Rs 67,62,961/-. 26. The learned AR submitted before us that the TPO has himself accepted the fact that Ladderup Corporate Advisory Private Limited is into investment

ESTATE OF NALINI MANILAL ,MUMBAI vs. ITO WARD 20(1)(1), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2024-25 Estate Of Nalini Manilal, Ito 20(1)(1), 57, Naiman Bhavan, Vinay Shah Piramal Chambers, Vs. Marg, Nariman Point, S.O. Mumbai-400012. Mumbai-400021. Pan No. Aaaae 0475 E Appellant Respondent

Section 168 of the Act governs the assessment of executors in respect of the the Act governs the assessment of executors in respect of the the Act governs the assessment of executors in respect of the income of the estate of a deceased person. The provision stipulates income of the estate of a deceased person. The provision stipulates income