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3,342 results for “transfer pricing”+ Section 22clear

Sorted by relevance

Delhi3,686Mumbai3,342Bangalore1,478Kolkata649Chennai617Ahmedabad571Hyderabad534Pune486Karnataka435Jaipur363Surat263Chandigarh252Indore237Cochin165Rajkot91Visakhapatnam85SC84Cuttack69Calcutta67Telangana61Nagpur57Lucknow56Raipur51Amritsar38Agra33Guwahati30Jodhpur28Dehradun19Ranchi13A.K. SIKRI ROHINTON FALI NARIMAN12Varanasi10Rajasthan10Panaji9Jabalpur7Kerala6Allahabad6Orissa5Patna5Punjab & Haryana2MADAN B. LOKUR S.A. BOBDE1T.S. THAKUR ROHINTON FALI NARIMAN1DIPAK MISRA V. GOPALA GOWDA1D.K. JAIN JAGDISH SINGH KHEHAR1Andhra Pradesh1A.K. SIKRI N.V. RAMANA1

Key Topics

Section 143(3)93Addition to Income54Disallowance44Section 14A41Transfer Pricing27Deduction23Section 92C22Section 115J16Long Term Capital Gains

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)

22% in this year. Challenging the comparables selected by the Transfer Pricing Officer under CUP, the learned Authorised Representative submitted that none of the three companies are comparable to the assessee due to their functional profile. He submitted, though, the assessee has brought this fact to the notice of the Transfer Pricing Officer, he has completely overlooked assessee’s objections

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Showing 1–20 of 3,342 · Page 1 of 168

...
14
Double Taxation/DTAA14
Section 153A13
Business Income13
ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

section 133(6) of the Act was made available to the assessee. He has not properly evaluated all the objections of the assessee. The DRP also upheld the finding of the Transfer Pricing Officer by simply observing that the services provided by the company are largely in the nature of software services. Notably, in case of Invensys Development Centre India

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

22 comparables with average weighted margin of 27.53% as against margin shown by the assessee at 15.65%. The final comparables selected by the Transfer Pricing Officer with their margin is as under:– Operating OP / TC (%) Sales (`) Total Cost (`) Name of Company Profit (`) 41.76 Accentia Technologies Ltd. 407293974 287301205 119992769 (Seg.) 35.30 208000505 153737300 54263205 Acropetal Technologies (Seg.) Aditya Birla Minacs

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

22. The learned Sr. Counsel for the assessee submitted, in pursuance to the query raised by the Transfer Pricing Officer under section

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

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

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

Bench: Shri G Manjunatha () & Shri Ravish Sood () Firmenich Aromatics (India) Vs Acit-9(3)(1), Mumbai Pvt Ltd, 9Th Floor, Arena Space, Cts 20, New Shyam Nagar Road, Behind Majas Bus Depot, Jogeshwari (E), Mumbai. Pan : Aaacf1621M Appellant Respondednt

Section 143(3)Section 144C(5)

section 92C 8 ITA 6081/Mum/2018 r.w.r.10B, the arms length price in relation to an international transaction shall be determined by adopting any one method thereunder and not by adopting two methods as the most appropriate method. The assessee has also argued for not adopting as most appropriate method, as per which, the price at which finished goods are exported

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

section 144C(13) of the Income Tax Act, 1961 (for short "the Act") in pursuance to the directions of the Dispute Resolution Panel–III (DRP), Mumbai. 2. Since all these appeals pertain to the same assessee involving common issues arising out of identical set of facts and circumstances, therefore, as a matter of convenience, these appeals were heard together

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

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

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

22 July 2010 were also pressed to state that business strategies are also required to be considered. The market penetration scheme needs to be considered where a taxpayer penetrating a market or to increase its market share my temper a really charge a price for its products that is lower than the price charged or otherwise comparable products

M/S. MERCATOR LTD,MUMBAI vs. THE DY CIT 5(2), MUMBAI

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

ITA 7278/MUM/2017[2010-11]Status: DisposedITAT Mumbai21 Dec 2022AY 2010-11

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

For Appellant: Mr.Nikhil Tiwari.ARFor Respondent: Mr.KrishnaKumarMishra.DR
Section 143(3)Section 14ASection 250

22 September 2021) Emerson Electric (Company) India Pvt Ltd (ITA No 933/M/2021) dated 18 May 2022 Further, as per provisions of section 144C of the Act, 'eligible assessee' refers to any person in whose case the variation referred to in section 144C(1) of the Act arises as a consequence of the order of the Transfer Pricing

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

section 92B of the Act and, therefore, it was required to be benchmarked as per Indian Transfer Pricing Regulations. The Transfer Pricing Officer took into consideration the information received from banks and determined a rate of 3% as an arm’s length rate to estimate the income by way of guarantee commission/fee. On this basis, the Transfer Pricing Officer worked

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

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

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

transfer pricing provisions were to apply, the provisions of TTS do not allow the adjustment made by the TPO to affect the computation of income under TTS. That being so, the adjustment made by the TPO would not affect the income of the assessee. This, more so, because the first proviso to section 92C(4) does not cover the provisions

JSW ENERGY LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING) 2(3)(1), MUMBAI

In the result, the appeal is allowed

ITA 1223/MUM/2019[2014-15]Status: DisposedITAT Mumbai12 Aug 2022AY 2014-15

Bench: Us Is A Public Company Engaged In The Business Of Generation Of Power & Operation & Maintenance Of The Power Plants, As Also Other Allied Activities. During The Course Of Its Assessment Proceedings, The Assessing Officer Made A Reference Under Section 92Ca(1), For Determination Of The Arm‟S Length Price Of The International Transactions & Specified Domestic Transaction Entered Into By The Assessee With Its Associated Enterprises (Aes), To The Deputy Commissioner Of Income Tax, Assessment Year 2014-15 Page 2 Of 17

Section 271GSection 92CSection 92D

Transfer Pricing Officer (para 20 of written submission). E. It is not recorded in the assessment order that penalty proceedings under section 271G is separately initiated (Para 22