ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ROHA DYECHEM P. LTD,MUMBAI vs. ACIT CEN CIR 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ACIT CEN CI-43 vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ROHA DYECHEM PVT.LTD.,MUMBAI vs. ACIT-CENTRAL CIRCLE 43, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ACIT CC-43, MUMBAI vs. ROHA DYECHEM P. LTD, MUMBAI

In the result, all the appeals of the assessee and revenue except ITA No

Bench: Shri Kuldip Singh () & Shri Om Prakash Kant () Assessment Year: 2004-05 Acit Cen Ci-43 Rohadyechem Pvt Ltd., 6Th Floor, R.No. 659, Aayakar Survoday Mill Compund, Bhavan, M.K.Rd. Vs. M.P. Mills, Tardeo, Mumbai 400 020 Mumbai-400 034 Pan No. Aaacr 4974P Appellant Respondent

section 80IB of the Act has been adjudicated by us. We have, following the decision of ITA No. 10,4293, 4294, 4295,2859, 2860, 2861, 2862,2863/MUM/2009, 6015, 5969/MUM/2014,6401/MUM/2008 A.Y. 2002-03, 2004-05, 2005-06, 2006-07, 2007-08, 2009-10 53 the ITAT in the case of the assessee for assessment year

ITO 10(3)(4), MUMBAI vs. KEYSTONE SOLUTION P. LTD, MUMBAI

In the result, appeal stands partly allowed for statistical purpose

Bench: Shri Saktijit Dey & Shri Ramit Kochar

section 92CA(3) of the Act, the Assessing Officer passed the assessment order adding the transfer pricing adjustment proposed by the Transfer Pricing Officer. Being aggrieved with the assessment order so passed, the assessee preferred appeal before the first appellate authority. 4. The learned Commissioner (Appeals) after considering the submissions of the assessee was convinced that

DCIT-2(2)(1), MUMBAI vs. THE INDIAN HOTELS COMPANY LTD., MUMBAI

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

190/-. The case of the Assessee was selected for scrutiny. During the assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference under Section 92CA(3) of the Act was made to the Transfer Pricing

THE INDIAN HOTELS COMPANY LTD.,MUMBAI vs. DCIT CIR. 2(2)(1), MUMBAI

In the result, appeal of the Assessee is partly allowed whereas the appeal of the Revenue is dismissed

190/-. The case of the Assessee was selected for scrutiny. During the assessment proceeding, the Assessing Officer noted that the Assessee had entered into International Transactions with its Associated Enterprises (AEs) and therefore, a reference under Section 92CA(3) of the Act was made to the Transfer Pricing

DCIT (LTU)-2, MUMBAI vs. S I GROUP INDIA LTD, NAVI MUMBAI

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

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledy. Commissioner Of Income-Tax V. M/S. Si Group India Limited Large Taxpayer Unit – 2 Plot No: D-2/I, Ttc Industrial Area World Trade Centre Thane – Belapur Road Centre 1, 29Th Floor, Cuffe Parade Opp. Juinagar Railway Station Mumbai – 400 005 Navi Mumbai – 400 705 Pan: Aaach7323L (Appellant) (Respondent) M/S. Si Group India Limited V. Assistant Commissioner Of Income-Tax Large Taxpayer Unit Plot No: D-2/I, Ttc Industrial Area Mumbai Thane – Belapur Road Opp. Juinagar Railway Station Navi Mumbai – 400 705 Pan: Aaach7323L (Appellant) (Respondent) Assessee By : Shri Ajit Kumar Jain & Shri Siddhesh Chaugule Department By : Shri Vivek A. Perampura

190/- is taken to be the ALP price. The assessee should have paid the ALP price of Rs.6,94,94,543/- instead of the transaction price of Rs.7,94,46,969/-. Hence the difference of Rs.99,52,426/- is to be adjusted towards determination of ALP of import of raw material from AE.” 22. In the course of the assessment

SI GROUP INDIA LTD,NAVI MUMBAI vs. ASST CIT LTU, MUMBAI

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

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledy. Commissioner Of Income-Tax V. M/S. Si Group India Limited Large Taxpayer Unit – 2 Plot No: D-2/I, Ttc Industrial Area World Trade Centre Thane – Belapur Road Centre 1, 29Th Floor, Cuffe Parade Opp. Juinagar Railway Station Mumbai – 400 005 Navi Mumbai – 400 705 Pan: Aaach7323L (Appellant) (Respondent) M/S. Si Group India Limited V. Assistant Commissioner Of Income-Tax Large Taxpayer Unit Plot No: D-2/I, Ttc Industrial Area Mumbai Thane – Belapur Road Opp. Juinagar Railway Station Navi Mumbai – 400 705 Pan: Aaach7323L (Appellant) (Respondent) Assessee By : Shri Ajit Kumar Jain & Shri Siddhesh Chaugule Department By : Shri Vivek A. Perampura

190/- is taken to be the ALP price. The assessee should have paid the ALP price of Rs.6,94,94,543/- instead of the transaction price of Rs.7,94,46,969/-. Hence the difference of Rs.99,52,426/- is to be adjusted towards determination of ALP of import of raw material from AE.” 22. In the course of the assessment

M/S. EMERSON PROCESS MANAGEMENT (INDIA) PVT. LTD (SUCESSOR IN INTEREST FOR PENTAIR VALVES AND CONTROLS PVT LTD,MUMBAI vs. ADDL/JT/CIT/DY/ACIT/NFAC, MUMBAI

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

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

190/-. 03. The ground no.1 raised by the assessee is despite intimation to ld AO, Ld. TPO, LD DRP, assessment has been made by the learned Assessing Officer in the name of Emerson Process Management (India) Pvt. Ltd under Section 143(3) read with section 144C (13) of the Act, however, the draft assessment order, Transfer pricing

M/S. EMERSON PROCESS MANAGEMENT (INDIA) PVT. LTD (SUCESSOR IN INTEREST FOR PENTAIR VALVES AND CONTROLS PVT LTD,MUMBAI vs. ADDL/JT/CIT/DY/ACIT/NFAC, MUMBAI

In the result, ITA number 2126/M/2022 filed by the assessee is allowed

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

190/-. 03. The ground no.1 raised by the assessee is despite intimation to ld AO, Ld. TPO, LD DRP, assessment has been made by the learned Assessing Officer in the name of Emerson Process Management (India) Pvt. Ltd under Section 143(3) read with section 144C (13) of the Act, however, the draft assessment order, Transfer pricing

RELIANCE INDUSTRIES LIMITED,MUMBAI vs. DY COMMISSIONER OF INCOME TAX CIRCLE-3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer Pricing Officer (TPO) in both the years under consideration. After the receipt of order of TPO, the AO passed draft assessment order and the assessee chose not to file its objection to the Dispute Resolution Panel. Hence the AO passed the final assessment order making various additions to the returned income in both the years. The assessee filed appeals

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer Pricing Officer (TPO) in both the years under consideration. After the receipt of order of TPO, the AO passed draft assessment order and the assessee chose not to file its objection to the Dispute Resolution Panel. Hence the AO passed the final assessment order making various additions to the returned income in both the years. The assessee filed appeals

RELIANCE INDUSTRIES LTD.,MUMBAI vs. ACIT CIRCLE 3(4), MUMBAI

In the result, both the appeals of the assessee and both the appeals of the revenue are treated as partly allowed

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Transfer Pricing Officer (TPO) in both the years under consideration. After the receipt of order of TPO, the AO passed draft assessment order and the assessee chose not to file its objection to the Dispute Resolution Panel. Hence the AO passed the final assessment order making various additions to the returned income in both the years. The assessee filed appeals