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

In the result, appeal stands partly allowed

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

section 10A of the Act. 8. Without prejudice to the above ground, the learned AU erred in reducing the telecommunication charges only from the export turnover and not from both, i.e total turnover and export turnover, in computing the deduction u/s 10A of the Act. 9. The Appellant craves leave to add, alter, vary, omit, substitute or amend

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

transfer pricing order is invalid and thus\nentire assessment is bad in law as provisions of section 144C(1) of the\nAct are not applicable to the Appellant,\nFinal assessment order passed is time barred - The ground was\nrequested to be kept as academic.\n1. Without prejudice to the above, the Ld. AO erred in not passing the\nfinal assessment

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

In the result, appeal is partly allowed

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

section 133(6) of the Act, the company has furnished its financial results for the financial year 2008–09 and 2009–10. In this context, he drew our attention to the financial results for March ending 2008 and 2009 as found place in the annual report of the company placed at Page–638 of the paper book. The learned

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

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

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

price under the aforesaid methods prescribed under section 92C of the Act. If the 24 ITA 6081/Mum/2018 Assessing Officer in course of assessment proceedings finds that the assessee has entered into international transactions with its AE, he may with the previous approval of the authority concerned make a reference to the Transfer

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

In the result, appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

24 J.P. Morgan Advisors India Pvt. Ltd. company before the Transfer Pricing Officer nor before the DRP. Thus, he submitted, at this stage the assessee cannot challenge the selection of this company through additional ground. In support of such contention he relied upon certain case laws as submitted in Legal Paper Book–II. 41. In rejoinder, the learned Authorised Representative

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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

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

Section 80IB of `30,66,334/–. The return was revised on 27th March, 2008 at `19,06,13,100/–. As the assessee has entered into international transaction, the learned Assessing Officer referred the matter for determination of arm's length price to the Jt. Commissioner of Income Tax, Transfer Pricing, 1(1), Mumbai. The international transactions of the assessee were

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

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.

transfer pricing order has to be passed 60 days prior to due date of completion of assessment as per Section 153(1) of the Act. As per provisions of Section 153 of the Act, the time limit to pass the assessment order is 24

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

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

section 92C in conformity with the arm's length price as so determined by the Transfer Pricing Officer." IT(TP)A No.720/MUM/2015 Page 8 of 29 “The Transfer Pricing Officer vide order u/s. 92CA(3) of the income-tax Act, 1961, dated 13/01/14 has held that adjustments aggregating to Rs.17,24

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

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

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (in short ‘the Act’) dated 15/02/2012. 2 2. The Grounds of appeal raised by the assessee read as under:- “1. Addition on account of Arm's Length Price by TPO Rs. 24,91,59,200/- (i) The Ld. CIT (A) erred in law and facts in upholding rejection