HSBC ASSET MANAGEMENT (INDIA) P.LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

section 144C(3)(a) of the Act assessing the total income of the assessee at Rs.13,71,73,770. In appeal, the learned CIT(A) M/s. HSBC Asset Management (I) Pvt. Ltd. ITA no.5830/Mum./2013 ITA no.5835/Mum./2013 vide impugned order partially upheld the transfer pricing adjustment made by the TPO/AO. Being aggrieved, the assessee is in appeal before

DCIT 1(1), MUMBAI vs. HSBC ASSET MANAGEMENT (I) P. LTD, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

section 144C(3)(a) of the Act assessing the total income of the assessee at Rs.13,71,73,770. In appeal, the learned CIT(A) M/s. HSBC Asset Management (I) Pvt. Ltd. ITA no.5830/Mum./2013 ITA no.5835/Mum./2013 vide impugned order partially upheld the transfer pricing adjustment made by the TPO/AO. Being aggrieved, the assessee is in appeal before

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 Officer further held that total assets of the assessee shows that the creditworthiness of the assessee is much higher than that of the Associated Enterprises and therefore, interest savings of 1.27% should be shared between parties in the ratio of 80:20 and accordingly, he proposed guarantee commission at the rate of 1%. xi. Ld AO computed amount

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 Officer further held that total assets of the assessee shows that the creditworthiness of the assessee is much higher than that of the Associated Enterprises and therefore, interest savings of 1.27% should be shared between parties in the ratio of 80:20 and accordingly, he proposed guarantee commission at the rate of 1%. xi. Ld AO computed amount

TATA CHEMICALS LTD,MUMBAI vs. ADDL CIAT 2(3), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

section 14A regardless of whether they are direct or indirect, fixed or variable and managerial or financial in accordance with law. It is further evident that deduction in respect of expenditure incurred by the assessee in relation to exempt income and taxable income has to be determined as per mechanism laid down in section 14A and in accordance with

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

Pricing Officer were not on the basis of any detailed search process.\nAt least, no such analysis is either forthcoming from the order of the Transfer\nPricing Officer or could be brought to our notice by learned Departmental\nRepresentative. On the contrary, on a thorough and careful reading of the\nimpugned order of learned Commissioner (Appeals

DCIT(CC)-8(3), MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment years under consideration stands partly allowed and cross appeals filed by the assesse stands dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 92BA w.e.f. 01/04/2013, then statute would have provided that for the purpose of Sub-section (8) to Section 80IA, “market value” in relation to goods or services means the arm’s length price as defined in clause (ii) of Section 92F. If both the clauses exist then one has to see if the market value is discernible from

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

Transfer Pricing Officer? 19.3.1. This question was disposed of by the Hon’ble Jurisdictional High Court by observing as under:- 3. Regarding Question No.(a) (a) It is an agreed position between the parties that the issue raised herein stand concluded against the Revenue and in favour of the Respondent - Assessee. This by the decision of this Court

TATA CHEMICALS LTD,MUMBAI vs. DCIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

Transfer Pricing Officer? 19.3.1. This question was disposed of by the Hon’ble Jurisdictional High Court by observing as under:- 3. Regarding Question No.(a) (a) It is an agreed position between the parties that the issue raised herein stand concluded against the Revenue and in favour of the Respondent - Assessee. This by the decision of this Court

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

Transfer Pricing Officer? 19.3.1. This question was disposed of by the Hon’ble Jurisdictional High Court by observing as under:- 3. Regarding Question No.(a) (a) It is an agreed position between the parties that the issue raised herein stand concluded against the Revenue and in favour of the Respondent - Assessee. This by the decision of this Court

ACIT (IT)-4(2)(2), MUMBAI vs. STANDARD CHARTERED BANK LTD., MUMBAI

In the result, appeal filed by the assessee is partly allowed

195 of the Act would not be\nattracted and there being no failure to deduct tax at\nsource from the said payment of interest made by the PE,\nthe question of disallowance of the said interest by\ninvoking the provisions of section 40(a)(i) of the Act does\nnot arise. Accordingly we answer question No.1 referred\nto this Special

STANDARD CHARTERED BANK,MUMBAI vs. DDIT(IT) 2 (1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

section\n44C of the Act. Following the decision of his predecessor-\nin-office, learned Commissioner (Appeals) deleted the\ndisallowance by holding that the expenditure is allowable\nunder section 37(1) of the Act without imposing\nrestrictions contained under section 44C of the Act.\n19. We have considered rival submissions and perused\nmaterial on record. Learned Counsels appearing for the\nparties

STANDARD CHARTERED BANK,MUMBAI vs. DDIT(IT) 2 (1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

195 of the Act would not be\nattracted and there being no failure to deduct tax at\nsource from the said payment of interest made by the PE,\nthe question of disallowance of the said interest by\ninvoking the provisions of section 40(a)(i) of the Act does\nnot arise. Accordingly we answer question No.1 referred\nto this Special

ACIT (IT)-4(2)(2), MUMBAI vs. STANDARD CHARTERED BANK LTD., MUMBAI

In the result, appeal filed by the assessee is partly allowed

195 of the Act would not be\nattracted and there being no failure to deduct tax at\nsource from the said payment of interest made by the PE,\nthe question of disallowance of the said interest by\ninvoking the provisions of section 40(a)(i) of the Act does\nnot arise. Accordingly we answer question No.1 referred\nto this Special

UPS JETAIR EXPRESS PRIVATE LIMITED,MUMBAI vs. ACIT - 11(1)(2), MUMBAI

195 r.w.s.9(1)(vii) and\nExplanation to section 9(2). Accordingly, disallowance was made us. 40(a)(i). By\nthe impugned order, the CIT(A) confirmed the disallowance.\n14. It was also argued by ld. AR that Titus being a resident law firm, is liable to\ntax in India. In view of proviso to Section 40(a)(i), in case

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

Transfer Pricing\nadjustment. He also excludes payments made by AEs to assessee\nas pass-through cost.\ne. Ld. CIT(A) in AYs 2007-08, 2008-09, 2009-10, 2010-11, 2012-13,\n2013-14, 2014-15 and 2015-16 has been holding that the method\nadopted by AO is incorrect\nf. Appropriate Profit Level Indicator (PLI) decided

THE HONG KONG & SHANGHAI BANKING CORPORATION LTD.,MUMBAI vs. ADDL. DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) - RANGE -3, MUMBAI

195", "Section 40(a)(i)", "Section 40A(9)" ], "issues": "Transfer pricing adjustments on correspondent banking activities, marketing and support services

DCIT (IT) 2(2)(2), MUMBAI vs. THE HONGKONG AND SHANGHAI BANKING CORP LTD, MUMBAI

In the result, the captioned appeals by the assessee are partly\nallowed and that of the revenue are partly allowed

pricing adjustments for correspondent banking, marketing and support services, and derivatives. Domestic issues like employee separation expenses, gratuity fund overfunding, and nosto account maintenance charges were also dealt with.", "result": "Partly Allowed", "sections": [ "Section 37", "Section 35DDA", "Section 10(10C)", "Section 195", "Section 40(a)(i)", "Section 40A(9)" ], "issues": "Transfer