ASST CIT (LTU) 1, MUMBAI vs. TATA CONSULTANCY SERVICES LTD, MUMBAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy () & Shri N.K. Pradhan () It(Tp)A No. 3262/Mum/2017 Assessment Year: 2007-08

260A of the Act. This unlike the judgment rendered in a Reference by this Court in S. Inder Singh Gill (supra). Moreover, the decision in South East Asia Shipping Co. (supra) is not available in its entirety. Therefore, it would not be safe to rely upon it as all facts and on what consideration of law, it was rendered

ADITYA BIRLA NUVO LTD (SINCE AMALGAMATED WITH GRASIM INDUSTRIES LIMITED),MUMBAI vs. DCIT CC-1(4) EARLIER WITH ACIT(LTU) 1, MUMBAI

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER &\nSMT RENU JAUHRI, ACCOUNTANT MEMBER\nITA No.563/Mum/2018\n(Assessment Year :2013-14)\nAditya BirlaNuvo Ltd. Vs. Dy. CIT, Central Circle – 1(4)\n(Since Amalgamated with\nGrasim Industries Limited)\nA2 Aditya Birla Centre, S. K.\nAhire Marg, Worli, Mumbai\nEarlier with Asst. CIT(LTU) 1\nRoom No. 902, Old CGO\nBuilding, 9th Floor, M. K. Road,\nMumbai-400 020\nPAN/GIR No.AAACI1747H\n(Appellant) .. (Respondent)\nITA No.1885/Mum/2018\n(Assessment Year :2013-14)

price as defined in clause (ii) of section 92F, where\nthe transfer of such goods or services is a specified domestic transaction referred to in\nsection 92BA?\n30\nITA No. 563/Mum/2018 (A. Y. 2013 -14)\nAditya BirlaNuvo Ltd. vs. Dy. CIT\nb) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not\nappreciating

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

transfer pricing adjustment of ₹ 11,193,854 was made determining the total income of the assessee at ₹ 495,275,430 as per the normal computation of total income. The computation of book profit remains at returned income. 09. Assessee preferred an objection before the learned dispute resolution panel wherein the directions were passed on 15/6/2022. The learned DRP noted that

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA? b) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not appreciating the finding of the TPO that the assessee's generating unit cannot as such

GEMOLOGICAL INSTITUTE OF AMERICA INC. ,MUMBAI vs. ACIT(IT) CIR. 2(3)(2), MUMBAI

In the result, appeal filed by the assessee is partly allowed for statistical purpose

Bench: Shri Amit Shukla, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blegemological Institute Of America, Inc. V. Acit (International Taxation) C/O Gia India Laboratory Pvt. Ltd Circle-2(3)(2) 10Th Floor, Trade Centre 17Th Floor, Air India Building Nariman Point, Mumbai- 400021 Bandra Kurla Complex Bandra (E) Mumbai- 400098 Pan: Aadcg7962K (Appellant) (Respondent) Assessee Represented By : Shri. J.D. Mistry, Shri Niraj Sheth & Shri Ketan Ved Department Represented By Shri Hement Kumar C. Leuva :

Transfer Pricing Study Report). Hence, GIA India Lab is not acting in India on behalf of the assessee company. Further, GIA India Lab is not having any authority to conclude contracts and has neither concluded any contracts on behalf of the assessee company nor has it secured any orders for the assessee company in India. Thus, GIA India Lab cannot

DCIT CEN CIR 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

In the result, appeal of the revenue and the assessee are partly allowed, and the additional ground of the assessee is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

260A". Grasim Industries Ltd. 2) "On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the disallowance of Rs.4,39,259/- towards contribution towards local organizations, relying upon the CIT(A)' order in the assessee's own case for Α.Υ.1996-97 to 2008-09 which have not been accepted

ITO 16(1)(4), MUMBAI vs. SHASHANKA GHOSH, MUMBAI

The appeal of the Revenue is dismissed

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Year: 2011-12 Income Tax Officer-16(1)(4), Vs Shri Shashanka Ghosh, Room No.438, 4Th Floor, C-701, Jay Bharat Chs Ltd. Aayakar Bhavan, Off. Yari Road,Near Amarnath M. K. Road, Tower, Varsova Andher (West), Mumbai-400020 Mumbai-400061 (राज"व /Revenue) ("नधा"रती /Assessee) Pan. No.Acwpg5915E

260A of the Income Tax Act, 1961 against the order dated 07.06.2001 passed by the Income Tax Appellate Tribunal in ITA 3613/Del./2010 for the assessment year 2007-08. 2. The assessee which is the respondent in the appeal is an individual. In the computation of income filed along with the return of income, she declared long term capital gains

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, C.O. filed by assessee is\ndismissed as infructuous

price as defined in clause (ii) of\nsection 92F, where the transfer of such goods or services is a specified domestic\ntransaction referred to in section 92BA?\nb) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not\nappreciating the finding of the TPO that the assessee's generating unit cannot as such

GRASIM INDUSTRIES LIMITED,MUMBAI vs. DCIT, CC-1(4), MUMBAI

In the result, appeal of the revenue and the assessee are partly allowed,\nand the additional ground of the assessee is dismissed

260A\".\n\n2) \"On the facts and circumstances of the case and in law, the Ld. CIT(A) erred in\ndeleting the disallowance of Rs.4,39,259/- towards contribution towards local\norganizations, relying upon the CIT(A)' order in the assessee's own case for\nA.Y.1996-97 to 2008-09 which have not been accepted by the department and\nfurther appeal

ARAMEX INDIA P.LTD,MUMBAI vs. DCIT RG 9(1)(2),

In the result, the appeal is partly allowed

Bench: Shri Saktijit Dey () & Shri N.K. Pradhan () Assessment Year: 2012-13 Aramex India Pvt. Ltd, Deputy Commissioner Of Income 821, Solitaire Corporate Vs. Tax -9(1)(2), Room No. 260A, 2Nd Park Andheir Ghatkopar Rd Floor, Aayakar Bhavan, M.K. Road, Chakala Andheeri (E), Mumbai-400020. Mumbai-400093. Pan No. Aacca6756A Appellant Respondent Assessee By : Mr. Nishant Thakkar & Hiten Chande, Ars Revenue By : Mr. Anand Mohan, Cit-Dr & C.A.K. Singh, Sr. Dr Date Of Hearing : 16/08/2019 Date Of Pronouncement : 08/11/2019

260A, 2nd Park Andheir Ghatkopar RD Floor, Aayakar Bhavan, M.K. Road, Chakala Andheeri (E), Mumbai-400020. Mumbai-400093. PAN No. AACCA6756A Appellant Respondent Assessee by : Mr. Nishant Thakkar & Hiten Chande, ARs Revenue by : Mr. Anand Mohan, CIT-DR & C.A.K. Singh, Sr. DR Date of Hearing : 16/08/2019 Date of pronouncement : 08/11/2019 ORDER PER N.K. PRADHAN, AM This is an appeal filed

SMT.MANJU MAHENDRA GOYAL,MUMBAI vs. INCOME TAX OFFICER 19(2)(3), MUMBAI

The appeal of the assessee is partly allowed

Bench: Shri Joginder Singh, Assessment Year: 2012-13 Smt. Manju Mahendra Goyal Income Tax Officer-19(2)(3), A/802, Surya Apartments, Room No.2018, Matru बनाम/ 53, Bhulabhai Desai Road, Mandir, Tardeo Road, Vs. Mumbai-400026 Mumbai-400007 "नधा"रती / Assessee राज"व / Revenue P.A. No.Aafpg2990N

260A of the Income Tax Act, 1961 against the order dated 07.06.2001 passed by the Income Tax Appellate Tribunal in ITA 3613/Del./2010 for the assessment year 2007-08. 2. The assessee which is the respondent in the appeal is an individual. In the computation of income filed along with the return of income, she declared long term capital gains

AGILITY LOGISTICS P.LTD,MUMBAI vs. DCIT RG 9(1)(1), MUMBAI

In the result the appeal is allowed for statistical purposes in the terms indicated above

Bench: Us Is A Logistic Service Provider, Offering A Comprehensive Portfolio Of International, Domestic & Specialized Freight Handling Services. The Assessee Is A Part Of Agility Group, Headed By Agility Holdings Inc. Usa Which Holds 100% Shareholding In The Assessee Company, Through It’S Step Down Subsidiaries Namely Agility Holding Logistics Pte. Ltd. (Singapore), Agility Logistics Ltd. (Hong Kong) & Agility International Logistics Pte. Ltd. (Singapore).

260A, 2nd Floor, Aayakar Bhavan, M. K. Road, Mumbai-400 020 Appearances by Hirali Desai/Nishant Shah/Chandni Shah for the appellant Sunil Jha for the respondent Date of concluding the hearing : October 21, 2020 December 8th, 2020 Date of pronouncement : ORDER Per Pramod Kumar, VP: 1. By way of this appeal, the assessee appellant has challenged the correctness of the order

GIRAFFE DEVELOPERS PVT. LTD.,MUMBAI vs. PR. CIT - 9 , MUMBAI

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

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalegiraffe Developers Pvt Vs. Pr. Cit – 9, Ltd Room No. 214, 2Nd 111, G Wing, Akruti Floor, Aayakar Commercial Complex, Bhavan, M.K. Road, Next To Akruti Centre Churchgate, Point, Central Road, Mumbai-400020. Andheri (E), Mumbai- 400093 Pan/Gir No. : Aaccn2778D Appellant .. Respondent Appellant By : Shri.Madhur Agrawal & Shri.Fenil Bhatt.Ar Respondent By : Shri.S.Anbuselvam.Dr Date Of Hearing 13.07.2022 Date Of Pronouncement 25.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of Pr. Commissioner Of Income Tax (Appeals)-9, Mumbai Passed U/S 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

sections 92CA and 260A, of Income-tax Act, 1961 Specified domestic transaction - Assessment years 2013-14 and 2014-15 - Assessing Officer had made a reference to Transfer Pricing

AMIRALI AKBARALI ENGINEER,MUMBAI vs. ACIT 24(1), MUMBAI

The appeal of the assessee is partly allowed for

Bench: Shri Joginder Singh & Shri Ramit Kocharassessment Year: 2012-13 Amirali Akbarali Engineer, Vs Acit, A/201, Senha Apna Ghar, Ward-24(1), Unit No.11, Piramal Chamber, Lalbaug, Swami Samarth Nagar, Mumbai Andheri (West), Mumbai-400053 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No.Aacpe9331N

260A of the Income Tax Act, 1961 against the order dated 07.06.2001 passed by the Income Tax Appellate Tribunal in ITA 3613/Del./2010 for the assessment year 2007-08. 2. The assessee which is the respondent in the appeal is an individual. In the computation of income filed along with the return of income, she declared long term capital gains

AHMED P. SURANI,MUMBAI vs. ACIT 3(1)(1), MUMBAI

transfer of long-term securities (Shares)\n Assessment year 2014-15 Assessee-individual engaged in\nbusiness of trading in shares claimed long term capital gains\narising out of sale of shares as exemption under section 10(38)\nAssessing officer denied claim and made certain additions\ninto assessee's income on grounds that said gains were\nearned through bogus penny stock

DCIT - CC -7(3), MUMBAI vs. M/S A. M. CONSTRUCTIONS, MUMBAI

In the result, the appeal of the revenue bearing ITA No

price volatility and potential manipulation with respect to penny\nstocks are pointed out by the Revenue. Further, the Hon'ble Apex Court in the\ncase of PCIT(Central)-1 vs. NRA Iron & Steel Pvt. Ltd. [103 taxmann.com 48] have\nheld that mere filing of formal documents was insufficient in the context of\nproving triple criteria provided in section

DCIT-CC-7(3), MUMBAI vs. M/S LOTUS BUILDSPACE LLP, MUMBAI

In the result, the appeal of the revenue bearing ITA No

price volatility and potential manipulation with respect to penny\nstocks are pointed out by the Revenue. Further, the Hon'ble Apex Court in the\ncase of PCIT(Central)-1 vs. NRA Iron & Steel Pvt. Ltd. [103 taxmann.com 48] have\nheld that mere filing of formal documents was insufficient in the context of\nproving triple criteria provided in section

DCIT CC 7(3), MUMBAI vs. M/S LOTUS LOGISTICS AND DEVELOPERS PVT LTD., MUMBAI

Bench: Shri B.R. Baskaran () & Shri Anikesh Banerjee ()

price volatility and potential manipulation with respect to penny stocks are pointed out by the Revenue. Further, the Hon'ble Apex Court in the case of PCIT(Central)-1 vs. NRA Iron & Steel Pvt. Ltd. [103 taxmann.com 48] have held that mere filing of formal documents was insufficient in the context of proving triple criteria provided in section