SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DICT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

SWARAN NADHAN SALARIA,MUMBAI vs. DCIT CENTRAL CIRCLE 1(2), MUMBAI

In the result all In the result all appeals of the assesses from AY 2014

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

section 271(1)(c) of the Act are fulfilled. In view of the above, the penalty in respect of interest and the excess the penalty in respect of interest and the excess the penalty in respect of interest and the excess depreciation is also cancelled cancelled. The relevant grounds of the appeal of The relevant grounds of the appeal

TPG GROWTH II MAKETS PTE LTD.,MUMBAI vs. DCIT 4(1)(2), MUMBAI

Accordingly, Ground No. 4 raised by the Appellant is partly allowed

Transfer pricing (TP") adjustment in respect of purchase of equity shares of Sutures India Private Limited (SIPL) and Quality Needles Private Limited ("QNPL') On the facts and in the circumstances of the case and in law, the Ld. DRP erred in upholding the action of Ld. TPO / Ld. AO of determining the arm's length price (ALP) of the international

VARIAN MEDICAL SYSTEMS INTERNATIONAL (INDIA) PRIVATE LIMITED,MUMBAIQQQ vs. ASSESSMENT UNIT NFAC CETNRE ITO, MINISTRY OF FINANCE DELHI, DELHI

In the result, the appeal of the assessee is partially allowed

Bench: Shri Narender Kumar Choudhry, Jm & Ms Padmavathy S, Am

Transfer Pricing- interest on outstanding receivables Ground No. 4 (4.1 to 4.6) Disallowance of employee contribution to PF in the Ground No. 5 (5.1 to 5.3) intimation under section 143(1) Addition on account of accretion to reserve treated as Ground No.6 (6.1 to 6.6) LTCG Disallowance of Finance Cost under section 37(1) of the Ground No.7

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- 3(2)(1), Mumbai, the Hon'ble Dispute Resolution Panel ('DRP') erred in: 1.1. not appreciating that explanation to section 92B of the Act as amended by Finance Act, 2012 does not alter the basic character of the definition of 'international transaction' u/s 928 and therefore, since provision of guarantee (by the assessee

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- 3(2)(1), Mumbai, the Hon'ble Dispute Resolution Panel ('DRP') erred in: 1.1. not appreciating that explanation to section 92B of the Act as amended by Finance Act, 2012 does not alter the basic character of the definition of 'international transaction' u/s 928 and therefore, since provision of guarantee (by the assessee

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

1) of section 143; (e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

1) of section 143; (e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

1) of section 143; (e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

1) of section 143; (e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

1) of section 143; (e) the amount of deemed total income assessed as per the provisions of section 115JB or section 115JC is greater than the maximum amount not chargeable to tax, where no return of income has been filed; (f) the amount of deemed total income reassessed as per the provisions of section 115JB or section 115JC

SHELL INDIA MARKETS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(4), MUMBAI

Bench: SHRI AMIT SHUKLA, JUDICIAL MEMBER\n&\nMS. PADMAVATHY S (Accountant Member)

1). In addition to\nincorporating the transfer pricing adjustments, he also made\na corporate tax disallowance under section 40(a)(ia)\namounting to Rs.8,82,155/- on the ground of alleged short\ndeduction of tax at source on a payment of Rs.29,40,517/-.\n5. The assessee filed detailed objections before the Dispute\nResolution Panel (DRP) on 25 October

SALTWATER STUDIO LLP,MUM vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकरअपीलसं/ I.T.A. No.13/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2017-18) बिधम / Saltwater Studio Llp Nfac, Delhi 103, Corporate Corner, F Block, Northe Block, Vs. Sunder Nagar, Near Dalmia New Delhi-110001 College, Malad (West) Mumbai-400 064 स्थधयीलेखधसं/.जीआइआरसं/.Pan/Gir No. : Ackfs1653D (अपीलार्थी / Appellant) .. (प्रत्यर्थी / Respondent)

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material facts relating to the transaction; and (e) the amount of undisclosed income referred to in section 271AAB. (7) The penalty referred to in sub-section (1) shall be a sum equal

VVF (INDIA) LIMITED,MUMBAI vs. INCOME TAX DEPARTMENT NATIONAL FACELESS ASSESSMENT CENTRE , MUMBAI

In the result appeal filed by the assessee stands partly allowed for statistical purposes

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

transfer pricing adjustment has already been made on the principal transactions of sale of goods and service and thus, such adjustment constitutes double additions. Without prejudice to the above: 5 ITA 4840/Mum/2024 A.Y. 2020-21 5.4.That the DRP/NFAC/AO/TPO erred on facts and in law in not appreciating that Assessee practices a uniform policy of not charging interest from

MARSH INDIA INSURANCE BROKERS PRIVATE LIMITED ,MUMBAI vs. ADDL/JT/DY/ASSTT/CIT/ITO/NFAC, DELHI, DELHI

In the result, both the appeal

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 & Assessment Year: 2017-18 Marsh India Insurance Brokers Additional/Joint/Deputy/Assistant Private Limited, Commissioner Of Income 1201-02, Tower, One India Vs. Tax/Income-Tax Officer, National Bulls Centre, Jupiter Mills E-Assessment Centre, Delhi. Compound, Senapati Bapat Marg, Elphinstone Road (West), Mumbai-400013. Pan No. Aadcm 4220 G Appellant Respondent Assessee By : Mr. Madhur Agrawal Revenue By : Mr. Manoj Kumar, Cit-Dr

transfer pricing. Accordingly, the ground No. 1 of the appeal of the assessee is dismissed as of the appeal of the assessee is dismissed as of the appeal of the assessee is dismissed as withdrawn. 7. The ground No. 2 of the appeal relate The ground No. 2 of the appeal relates to deduction of to deduction of Rs.4

MARSH INDIA INSURANCE BROKERS PVT. LTD,MUMBAI vs. ADDL /JTDY/ACIT/ITO/NFAC, MUMBAI

In the result, both the appeal

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 & Assessment Year: 2017-18 Marsh India Insurance Brokers Additional/Joint/Deputy/Assistant Private Limited, Commissioner Of Income 1201-02, Tower, One India Vs. Tax/Income-Tax Officer, National Bulls Centre, Jupiter Mills E-Assessment Centre, Delhi. Compound, Senapati Bapat Marg, Elphinstone Road (West), Mumbai-400013. Pan No. Aadcm 4220 G Appellant Respondent Assessee By : Mr. Madhur Agrawal Revenue By : Mr. Manoj Kumar, Cit-Dr

transfer pricing. Accordingly, the ground No. 1 of the appeal of the assessee is dismissed as of the appeal of the assessee is dismissed as of the appeal of the assessee is dismissed as withdrawn. 7. The ground No. 2 of the appeal relate The ground No. 2 of the appeal relates to deduction of to deduction of Rs.4