TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

section 14 -- -- -- -- -- 194C(2) 14. Deduction u/s.10AA on 15 13 14 -- -- -- interest income during assessment 15. Subscription fees u/s. 16 16 13 -- -- -- 40(a)(ia) 16. Warranty income of 18 -- -- -- -- -- CMC already offered 17. Year end provisions u/s. -- 14 11 -- -- -- 37(1) 18. 80G vis-a-vis CSR -- 18 15 -- -- -- expenses 19. Gratuity expenses -- 19 16 -- -- -- debited

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly\nallowed for all the three

194C(2) shall apply in this case?\"\n15. \"Whether on facts and in circumstances of the case and in law, the Ld. CIT(A)\nerred in deleting the disallowance of claim of deduction under section 10AA in\nrespect of interest Income which was claimed during the course of assessment\nproceedings, without filing revised return of income?\"\n16. \"Whether, on facts

ASUS INDIA PVT LTD.,MUMBAI vs. THE LD. ADDL/JOINT/DEPUTY/ACIT/ ITO, DELHI

In the result, appeal of the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Asus India Private Limited The Learned. 402, Supreme Chambers, Addl/Joint/Deputy/Acit/Ito 17-18 Shah Industrial Estate, Room No.305, Ara Centre 2-E Veera Desai Road, Vs. Jhandewalan Extn, New Delhi, Andheri (West), Delhi-110055 Mumbai-400 053 (Appellant) (Respondent) Pan No. Aajca6450C Assessee By : Mr. Vijay Mehta, Adv. Revenue By : Mr. Nihar Ranjan Samal, Sr. Ar Date Of Hearing: 19.05.2023 Date Of Pronouncement : 16.08.2023

section 194C of the act. With respect to the transfer pricing adjustment, assessee furnished additional evidences before the DRP. The remand

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

transfer pricing adjustment. In addition\nthe Assessing Officer also proposed other\nadditions/disallowances as per the provisions of the Act.\n3.2. The Assessee filed objections before the DRP against the Draft\nAssessment Order, dated 31/03/2015. On 22/12/2015, the DRP\ndisposed off the objections granting partial relief to the\nAssessee. As per the directions of the DRP, the Assessing Officer\npassed

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

transfer pricing adjustment. In addition\nthe\nAssessing\nOfficer\nalso\nproposed\nother\nadditions/disallowances as per the provisions of the Act.\n3.2. The Assessee filed objections before the DRP against the Draft\nAssessment Order, dated 31/03/2015. On 22/12/2015, the DRP\ndisposed off the objections granting partial relief to the\nAssessee. As per the directions of the DRP, the Assessing Officer\npassed

DCIT 4(1), MUMBAI vs. DEUTSCHE EQUITIES INDIA P.LTD, MUMBAI

Bench: SHRI B.R. BASKARAN, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

transfer pricing adjustment and declined to grant any relief in relation to disallowances made in Section 40(a)(i) of the Act in respect of Global Overhead Charges of INR.1,31,15,947/- and payments of INR.10,27,625/- to Team Lease. Further, the CIT(A) also enhance the disallowance under Section

DEUTSCHE EQUITIES INDIA PVT. LTD.,MUMBAI vs. ADDL.C.I.T. RG. 4(1), MUMBAI

194C", "197", "12(4)(b) of DTAA", "Article 7 of DTAA", "Article 5 of DTAA", "Article 12 of DTAA", "92C(2)", "9(1)(vii)", "194J", "40(a)(ii)" ], "issues": "Disallowance of expenses under Section 14A and Section 40(a)(ia), and transfer pricing

M/S CEAT LTD ,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

DCIT, CIRCLE 3 4, MUMBAI, MUMBAI vs. TATA CONSULTANCY SERVICES LIMITED, MUMBAI

In the result, appeals of both, revenue and assessee are partly\nallowed for all the three

194C(2) shall apply in this case?\"\n15. \"Whether on facts and in circumstances of the case and in law, the Ld. CIT(A)\nerred in deleting the disallowance of claim of deduction under section 10AA in\nrespect of interest Income which was claimed during the course of assessment\nproceedings, without filing revised return of income?\"\n16. \"Whether, on facts

M/S CEAT LTD,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

HSBC SECURITIES AND CAPITAL MARKETS (I) P.LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

transfer pricing study: •Ask Me Info Ltd. •MCS Ltd. •CMC Ltd. •C.S. Software Enterprise Ltd •Mphasis BFL, Ltd. •Tata Share Registry Ltd. •HCL Technologies Ltd. •Datamatics Technologies Ltd. 2.10 on the facts and in the circumstances of the case and in law, the learned TPO/AO/DRP erred in wrongfully including the following comparable companies in the final set of comparables: •Apes

DCIT 4(1), MUMBAI vs. HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P.LTD, MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

transfer pricing study: •Ask Me Info Ltd. •MCS Ltd. •CMC Ltd. •C.S. Software Enterprise Ltd •Mphasis BFL, Ltd. •Tata Share Registry Ltd. •HCL Technologies Ltd. •Datamatics Technologies Ltd. 2.10 on the facts and in the circumstances of the case and in law, the learned TPO/AO/DRP erred in wrongfully including the following comparable companies in the final set of comparables: •Apes

HSBC SECURITIES AND CAPITAL MARKETS (INDIA) P. LTD,MUMBAI vs. DCIT RG 4(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

transfer pricing study: •Ask Me Info Ltd. •MCS Ltd. •CMC Ltd. •C.S. Software Enterprise Ltd •Mphasis BFL, Ltd. •Tata Share Registry Ltd. •HCL Technologies Ltd. •Datamatics Technologies Ltd. 2.10 on the facts and in the circumstances of the case and in law, the learned TPO/AO/DRP erred in wrongfully including the following comparable companies in the final set of comparables: •Apes

M/S CEAT LTD,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

M/S CEAT LTD ,MUMBAI vs. INCOME TAX OSD TDS CIRLCE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

M/S CEAT LTD,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

M/S CEAT LTD,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8.\nThe Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9.\nThe Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

M/S CEAT LTD ,MUMBAI vs. INCOME TAX OFFICER OSD TDS CIRCLE 1(1), MUMBAI

section 201(1) of the Act and raised\nthe demand of Rs.1,25,00,396/- .\n8. The Assessee, being aggrieved, challenged the said demand\nbefore the Ld. Commissioner and raised various issues/grounds.\n9. The Ld. Commissioner considering the peculiar facts and\ncircumstances in totality, ultimately confirmed the decision of the\nAO in raising the demand of Rs.1

VODAFONE INDIA LTD,MUMBAI vs. DCIT 7(3), MUMBAI

In the result, the appeal of the assessee is treated as allowed and the appeal of the revenue is dismissed

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

Pricing Officer (TPO) and also various additions. The assessee filed objections against the draft assessment order before Ld DRP. After receipt of the order passed by Ld DRP, the assessing officer has passed this final assessment order, which the assessee is challenging in the present appeal filed before the Tribunal. The revenue is challenging the decision of Ld DRP with