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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

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

Transfer Pricing Grounds 1. Imputing interest on delayed receipt from debtors 2. Imputing interest on the share application money paid to the subsidiaries by the Appellant. 3. Imputing guarantee commission with respect to the corporate guarantees provided by the Appellant to its Associated Enterprises Corporate Tax Grounds 4. Disallowance of the deduction claimed u/s 10B of the Income

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), MUMBAI vs. TATA SONS LIMITED, MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

Transfer Pricing Officer (‘TPO’) vide order dated 30/01/2015 passed under section 92CA (3) of the Act by applying the SBI tariff card rate along with a markup determined arm’s length guarantee commission fees at 3%. Accordingly, the TPO, inter-alia, proposed adjustment of Rs. 7,10,30,009.77 in respect of international transaction of receipt of guarantee fees

TATA SONS LTD.,MUMBAI vs. ACIT,CIR 2(3)(1), MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

Transfer Pricing Officer (‘TPO’) vide order dated 30/01/2015 passed under section 92CA (3) of the Act by applying the SBI tariff card rate along with a markup determined arm’s length guarantee commission fees at 3%. Accordingly, the TPO, inter-alia, proposed adjustment of Rs. 7,10,30,009.77 in respect of international transaction of receipt of guarantee fees

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

3 are related to Transfer Pricing On the issue of Provision of Software, Technical and Consultancy Services: 1.1 Whether on the facts and circumstances of the case and in law, the Ld. CIT(A) is correct in directing the AO/TPO to restrict the adjustment made on account of Provision of Software & Consultancy Services by relying on the decision

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

The appeal is dismissed

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

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 adjustment made in case of the appellant is bad in law. No tax evasion 5. The Ld. Assessing Officer, Transfer Pricing Officer and the Ld. Dispute Resolution Panel

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

section 92C(1). of the method prescribed under section 92C(1). 38. The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice The assessee's main argument is that due to the trade practice prevailing in the in the diamond industry separate identity of the diamond

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

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

transfer pricing order dated 30th September, 2005, passed under section 92CA (3) is beyond jurisdiction and thus null and void.” 7. Ld. Counsel for the assessee submitted that the above additional grounds of appeal is not pressed at this stage, accordingly, the above additional ground is dismissed as not pressed. Page No.| 6 ITA.NO.1606 & 1302/MUM/2007 (A.Y: 2003-04) ITA.NO

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

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

transfer pricing order dated 30th September, 2005, passed under section 92CA (3) is beyond jurisdiction and thus null and void.” 7. Ld. Counsel for the assessee submitted that the above additional grounds of appeal is not pressed at this stage, accordingly, the above additional ground is dismissed as not pressed. Page No.| 6 ITA.NO.1606 & 1302/MUM/2007 (A.Y: 2003-04) ITA.NO

ECL FINANCE LTD.,MUMBAI vs. A.C.I.T. - 3(1)(2), MUMBAI

In the result, this appeal by the assessee stands partly allowed

40A (2) (b) is not a "specified domestic transaction" under section 92BA of the Act and, hence, the transfer pricing adjustment made in this behalf is liable to be quashed. 3

BAJINATH MELARAM,MUMBAI vs. PR CIT 18, MUMBAI

In the result, appeal of the Assessee is hereby allowed

Bench: Shri G.S.Pannu, Am & Shri Amarjit Singh, Jm / I.T.A. No.1795/M/16 (Assessment Year: 2011-12) M/S. Baijnath Melaram Vs. Pr. Commissioner Of Income C/O.Mangaldas D. Shah & Co Tax – 18 506, Lotus House, 5Th Floor, 6Th Floor, Earnest House, 33-A, New Marine Lines Nariman Point, Mumbai - 400020 Mumbai - 400021 Pan/Gir No. : Aaafb2675E (/Appellant) .. Respondent)

3 AJKPD7142GF 28, 785 Rizvanbhai Wrong Ramesh Roadways Rizvanbhai PAN BZBPM6848M Nurani PAN Noorani PAN ADGPN3469B 4 CGUPF6560H 28, 620 Wrong Sarvaiya Sarvaiya Gurukrupa Transport PAN Abbasbhai PAN AKUPG2269F Abbasbhai PAN CGUPS6560H 5 Rafikbhai AIYPB7298R 33,025 Tambe Gurukrupa Transport Rafikbhai Babubhai Virani Shreeniva Agent Babubhai sa Bijesh PAN AKUPG2269F Virani PAN A/YPB7298R The provision of section 40a(ia), thus