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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

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

4) of the Act on account of adjustment in Arm's Length Price (ALP) pursuant to order of the Additional Commissioner of Income-tax, Transfer Pricing 1(3), Mumbai (TPO), u/s. 92CA(3) of the Act dated 21st October 2011 in respect of the following transactions: (i) Adjustment of Rs. 1,27,40,126/-in respect of goods sold

INCOME TAX OFFICER-25(3)(5), MUMBAI vs. NILIMA ABHIJIT TANNU, MUMBAI

Bench: Hon’Ble Shri Sandeep Gosain, Jm & Hon’Ble Shri G. Manjunatha, Am

transfer of the original asset took place, or which is not utilized by him for the purchase or construction of the new asset before the date of furnishing the return of income under section 139, shall be deposited by him before furnishing such return. It was submitted that such deposit being made in any case not later than

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

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

1 crore is without any basis. Thus, it is very much clear that the determination of arm's length price by the Transfer Pricing Officer is not as per any one of the methods prescribed under section 92C of the Act r/w rule 10B. As discussed elsewhere in this order, such determination of arm's length price

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

1,83,27,826, was treated as the adjustment made to the arm's length price. 49. Being aggrieved of such adjustment, the assessee raised objections before the DRP. However, the DRP concurred with the view of the Transfer Pricing Officer. 50. The learned Sr. Counsel for the assessee submitted, since, a part of the services rendered under the IPSA

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

1. In making an upward transfer pricing adjustment of Rs. 946,786,679 in determining the arms length pricing (ALP) of the international transactions pertaining to (a) investment advisory services in respect of listed Indian equities; (b) Investment advisory/support services in respect of strategic (unlisted) investments and (c) Investment banking services, provided by the Appellant to its overseas associated Enterprises

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

Transfer Pricing Officer certainly cannot determine the arm's length price on ad–hoc / estimation basis. Our reasoning in paragraph 11 to 15 will equally apply to this issue also. Accordingly, we delete the adjustment made to the arm's length price of payment made towards availing information system services from AE. This ground is allowed.” “Facts relating

JSW ENERGY LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING) 2(3)(1), MUMBAI

In the result, the appeal is allowed

Bench: Us Is A Public Company Engaged In The Business Of Generation Of Power & Operation & Maintenance Of The Power Plants, As Also Other Allied Activities. During The Course Of Its Assessment Proceedings, The Assessing Officer Made A Reference Under Section 92Ca(1), For Determination Of The Arm‟S Length Price Of The International Transactions & Specified Domestic Transaction Entered Into By The Assessee With Its Associated Enterprises (Aes), To The Deputy Commissioner Of Income Tax, Assessment Year 2014-15 Page 2 Of 17

4. 2017, “to grant us (i.e. the assessee) an adjournment”. However, no adjournment was granted by the Transfer Pricing Officer. As evident from the impugned penalty order, the requisite transfer pricing study was filed on 7th July 2017, and there has been full compliance with the requisitions made by the TPO subsequently. Elaborate submissions were made to explain the delay

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

Section 92CA(3) of the Act proposed, inter alia, the following transfer pricing adjustments: SNo. Additions/Disallowances Amount (INR) 1 Payment of Royalty for brand name and mark 7,97,68,155/- 2 Technology support charges 1,31,43,772/- 3 Payment for GMAC costs, PwC consulting charges and People Survey charges 4

ILJIN ELECTRIC CO. LTD,MUMBAI vs. DCIT (IT) CIR 2(2)(1), MUMBAI

In the result, appeal for A

Bench: Shri Jason P. Boaz, Accoutant Member & Shri Saktijit Dey

1 to 4. In addition, clause 12.1 of the IFB also requires the bidder to quote the price for supplies to be made from abroad in the foreign currency, whereas, the price to be quoted for goods to be supplied within India is to be quoted in Indian currency. It is relevant to mention that the breakdown of price