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

Appeal of the assessee is allowed

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

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

TWENTIETH CENTURY FOX TELECOMMUNICATIONS INTERNATIONAL, INC,MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-4(1)(2), MUMBAI

271C and Section 273B of the Act in the case of CIT v.\nThomas Muthoot reported in (2015) 61 taxmann.com 76 (Kerala). The\nassessee pleaded that he was under the bonafide belief that under Section\n194A, they were not liable to deduct tax at source on the interest paid by a\npartner to the firm and thus, pleaded ignorance

TWENTIETH CENTURY FOX INTERNATIONAL TELEVISION, INC, MUMBAI vs. DCIT (INTERNATIONAL TAXATION)-4(1)(2) , MUMBAI

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sunil Kumar Singh, Hon’Ble

271C and Section 273B of the Act in the case of CIT v. Thomas Muthoot reported in (2015) 61 taxmann.com 76 (Kerala). The assessee pleaded that he was under the bonafide belief that under Section 194A, they were not liable to deduct tax at source on the interest paid by a partner to the firm and thus, pleaded ignorance

DCIT(OSD)(TDS)-2(3), MUMBAI, MUMBAI vs. WOCKHARDT LTD., MUMBAI

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

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singh

transferred to the ITA. No. 2633/MUM/2024 Wockhardt Ltd, Mumbai. stockiest and that the company had to still carry liability in terms of expired goods and quality of goods etc. and therefore the stockiest were working as agents of assessee company, to promote and effect sales on behalf of assessee." (b) "On the facts and circumstances of the case