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391 results for “transfer pricing”+ Section 40A(2)(b)clear

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Delhi442Mumbai391Bangalore148Ahmedabad115Chennai110Kolkata83Pune66Jaipur48Hyderabad29Raipur24Cochin22Surat22Indore20Chandigarh14Visakhapatnam13Jodhpur12Rajkot9Cuttack9Agra5Karnataka5Guwahati4Calcutta3SC2Lucknow2Nagpur2Allahabad1Amritsar1

Key Topics

Disallowance63Addition to Income61Section 143(3)47Section 153A40Section 14A40Section 115J32Deduction30Depreciation25Transfer Pricing23

ACIT- 3(1)(1), MUMBAI vs. MM/S SANOFI INDIA LIMITED (FORMERLY KNOWN AS AVENTIS PHARMA LTD)., MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 1302/MUM/2007[2003-2004]Status: DisposedITAT Mumbai31 Oct 2023AY 2003-2004

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 271(1)(c)

Section 40A(2) by observing as under:- “a) material fact is that Assessee has not purchased Rabipur vaccine from any independent third party at lower rates; b) there is nothing in Assessee's books to demonstrate that it has paid more than market price: c) it is none of the business of Assessee nor latter is answerable that Chiron India

M/S SANOFI INDIA LTD (FORMERLY KNOWN AS AVENTIS PHARMA LTD,MUMBAI vs. THE ACIT RG 8(1), MUMBAI

In the result, appeal filed by the Revenue is dismissed

ITA 1606/MUM/2007[2003-2004]Status: DisposedITAT Mumbai31 Oct 2023AY 2003-2004

Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Ble

Showing 1–20 of 391 · Page 1 of 20

...
Section 80I21
Penalty21
Section 92C18
Bench:
Section 271(1)(c)

Section 40A(2) by observing as under:- “a) material fact is that Assessee has not purchased Rabipur vaccine from any independent third party at lower rates; b) there is nothing in Assessee's books to demonstrate that it has paid more than market price: c) it is none of the business of Assessee nor latter is answerable that Chiron India

PAHILAJRAI JAIKISHAN,MUMBAI vs. DCIT 19(3), MUMBAI

In the result, the appeal is allowed

ITA 994/MUM/2014[2010-11]Status: DisposedITAT Mumbai01 Feb 2016AY 2010-11

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14Section 143(2)Section 143(3)Section 14ASection 37(1)Section 40

price and thereafter place orders on behalf of the prospective buyers with you as per samples given to us. Sometimes, we get samples from you which we show to various customers and book orders on your behalf. It is also placed on record after the goods are shipped from India you send a duplicate copy of documents. We contact

ASST CIT 19(3), MUMBAI vs. PAHILAJRAI JAIKISHIN, MUMBAI

In the result, the appeal is allowed

ITA 1562/MUM/2014[2010-11]Status: DisposedITAT Mumbai01 Feb 2016AY 2010-11

Bench: Shri Shailendra Kumar Yadav & Shri Ramit Kocharआयकर अपील सं./I.T.A. No.1562/Mum/2014 ("नधा"रण वष" / Assessment Year: 2010-11)

Section 14Section 143(2)Section 143(3)Section 14ASection 37(1)Section 40

price and thereafter place orders on behalf of the prospective buyers with you as per samples given to us. Sometimes, we get samples from you which we show to various customers and book orders on your behalf. It is also placed on record after the goods are shipped from India you send a duplicate copy of documents. We contact

ADDL CIT 8(1), MUMBAI vs. M/S. SANOFI INDIA LIMITED (FORMERLY KNOWN AS M/S. AVENTIS PHARMA LTD), MUMBAI

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 6698/MUM/2011[2007-08]Status: DisposedITAT Mumbai23 Feb 2024AY 2007-08

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

price, which ultimately recovers its cost of manufacturing, which is also based on the JV agreement. The Chiron group markets the same at the lesser cost does not make, anyway, affects the marketability or achieving the profitability of the assessee in the whole marketing strategy of the Chiron Group. It is wrong on the part of the revenue authorities

SANOFI INDIA LTD FORMERLY KNOWN AS AVENTIS PHARMA LTD ,MUMBAI vs. ADDL CIT RG 8(1), MUMBAI

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 6626/MUM/2009[2005-06]Status: DisposedITAT Mumbai23 Feb 2024AY 2005-06

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

price, which ultimately recovers its cost of manufacturing, which is also based on the JV agreement. The Chiron group markets the same at the lesser cost does not make, anyway, affects the marketability or achieving the profitability of the assessee in the whole marketing strategy of the Chiron Group. It is wrong on the part of the revenue authorities

ADDL CIT RG 8(1), MUMBAI vs. M/S. SANOFI INDIA LIMITED (FORMERLY KNOWN AS M/S. AVENTIS PHARMA LTD), MUMBAI

In the result, the C.O. of the assessee for AY 2007-08 is partly allowed

ITA 7712/MUM/2010[2006-07]Status: DisposedITAT Mumbai23 Feb 2024AY 2006-07

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

For Respondent: Shri Ajay Chandra (CIT-DR) &
Section 32Section 32(1)

price, which ultimately recovers its cost of manufacturing, which is also based on the JV agreement. The Chiron group markets the same at the lesser cost does not make, anyway, affects the marketability or achieving the profitability of the assessee in the whole marketing strategy of the Chiron Group. It is wrong on the part of the revenue authorities

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

b) to include goods, articles or things and intangible property. Therefore, there is no bar that the property may include a basket of product. 023. It is not unusual for taxpayers to negotiate their products altogether, regardless of their individual prices, as they aim to reach an overall profit. The price of a product is cut down to stimulate

AMBICO EXPORTS AND IMPORTS PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 12(1)(1), MUMBAI

In the result, appeal by the assessee is partly allowed in the terms aforesaid

ITA 6822/MUM/2017[2013-14]Status: DisposedITAT Mumbai30 Mar 2021AY 2013-14

Bench: Vikas Awasthy & Shri N.K.Pradhanआअसं. 6822/मुं/2017 ("न.व. 2013-14) It(Tp)A No.6822/Mum/2017(A.Y.2013-14)

For Appellant: Shri Sanjay ChokshiFor Respondent: Shri Sunil Deshpande
Section 143(3)Section 40A(2)(b)Section 92Section 92ASection 92A(1)(b)Section 92A(2)Section 92CSection 92DSection 92F

transfer pricing provisions (section 92 to section 92F of the Act) to Your Assessee inspite of the fact of that both Narayan Foods Limited and Ambico Exports and Imports Private Limited (UK) are neither Associated Enterprise as defined under section 92A of the Act nor a related party as defined under section 40A(2)(b

HINDUSTAN DORR-OLIVER LTD,MUMBAI vs. ACIT-10(1)(1), MUMBAI

The appeal is dismissed

ITA 7116/MUM/2017[2013-14]Status: DisposedITAT Mumbai28 Apr 2022AY 2013-14

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm The Asst. Commissioner Of Hindustan Dorr-Oliver Ltd. Income Tax, 10(1)(1), Chakala, Andheri (E), R.No.209, Vs. Mumbai-400 009 Aayakar Bhavan, M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaach0964P

For Appellant: NoneFor Respondent: Shri Dr. Yogesh Kamat, CIT DR
Section 143(3)Section 144C(13)Section 40A(2)Section 40A(2)(b)Section 92(2)Section 92BSection 92C

section 40A(2)(b) was removed from the definition of specified domestic transaction, is retrospective in M/s Hindustan Dorr Oliver Limited; AY: 13-14 nature and therefore, the entire transfer pricing

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 10(3),

ITA 2877/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Feb 2023AY 2009-10

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No.2877/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2009-10) Strides Shasun Limited Dcit Cir. 15(3)(2) (Formerly Known As R. No. 451, 4Th Floor, Strides Arcolab Limited) बिधम/ Aayakar Bhavan, M. K. 201, Devavrata, Sector 17, Road, Mumbai-400 020 Vs. Vashi, Navi Mumbai – 400 703 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcs8104P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Percy Pardiwala/ Shri Ketan Ved /Shri Ninad Patade, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Ms. Vatsalaa Jha, Ld. Dr सुनवाईकीतारीख/ : 18.01.2023 Date Of Hearing घोषणाकीतारीख / : 28.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla : The Aforesaid Appeal Has Been Filed By Assessee Against The Order Dated 26.02.2014 Passed U/S 143(3) R.W.S. 144C(13) In 2

For Appellant: Shri Percy Pardiwala/ ShriFor Respondent: Ms. Vatsalaa Jha, Ld. DR
Section 10BSection 115JSection 143(3)Section 14ASection 153Section 234BSection 234DSection 30Section 35Section 40A(2)(b)

40A(2)(b) of the Act. 8. Disallowance of FCCB premium. 9. Disallowance of FCCB issue expenses. 3 I.T.A. No. 2877/Mum/2014 Strides Shasun Limited 10. Disallowance u/s. 14A of the Act. 11. Income received on assignment of commercial contracts taxed as business profits. 12. Adjustment made to 'book profits' computed in terms of section 115JB of the Act by: • considering