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4 results for “transfer pricing”+ Section 271Aclear

Sorted by relevance

Ahmedabad8Chandigarh6Mumbai4Delhi4Hyderabad2Bangalore2Pune1Rajkot1

Key Topics

Section 271G5Section 143(3)4Addition to Income4Section 92C3Section 120(4)(b)3Transfer Pricing3Penalty3Section 92D2Section 92D(3)2

VISEN INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING )-4(3)(1), MUMBAI

Appeal of the assessee is allowed

ITA 3729/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 May 2025AY 2016-17

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

For Appellant: Ms. Usha Gopalan, ARFor Respondent: Shri Mukesh Thakwani, Sr. DR
Section 250Section 271GSection 273BSection 40Section 92CSection 92DSection 92D(3)

transfer pricing order dated 28.10.2019 has considered comparable market rate for corporate guarantee commission @1.5% and accordingly has made adjustment to the ALP in respect of Corporate Guarantee by 0.5% as the assessee has already charged guarantee commission @ 1%, amounting to Rs. 1,34,40,410/-. Therefore, contention of the assessee is rejected. Visen Industries Ltd. 5.8 Thus, in view

Section 1272
Capital Gains2
Short Term Capital Gains2

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

ITA 6772/MUM/2010[2002-03]Status: DisposedITAT Mumbai20 Mar 2024AY 2002-03

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 2

271A,section 271J or section 272A; or (b) an order passed by an Assessing Officer under clause (c) of section 158BC, in respect of search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, after the 30th day of June, 1995, but before the 1st day of January, 1997; or an order

STAR ASIA REGION FZ LLC,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

ITA 1813/MUM/2014[2009-10]Status: DisposedITAT Mumbai08 Dec 2023AY 2009-10

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 143(3)

section Gr.No.18-20 Gr.No.17-19 271(1)(c), 271A and 272B of the Act ITA 1814/Mum/2014 - Star Television Entertainment Ltd (STEL) 3. The assessee is a non resident company and is a tax resident of Hong Kong belonging to the Star Television group of companies. During the year under consideration, the assessee filed the return of income

STAR TELEVISION ENTERTAINMENT LTD,MUMBAI vs. DDIT (IT) 2(1), MUMBAI

ITA 1814/MUM/2014[2009-10]Status: DisposedITAT Mumbai08 Dec 2023AY 2009-10

Bench: Shri Amit Shukla () & Ms. Padmavathy S. ()

Section 143(3)

section Gr.No.18-20 Gr.No.17-19 271(1)(c), 271A and 272B of the Act ITA 1814/Mum/2014 - Star Television Entertainment Ltd (STEL) 3. The assessee is a non resident company and is a tax resident of Hong Kong belonging to the Star Television group of companies. During the year under consideration, the assessee filed the return of income