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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

40A (3) of the Act. The fact shows that the above disallowance is made on account of payment made to government agencies such as road tax and attestation charges to various embassy’s’. We find that lifetime road tax of ₹25,810/- is paid to the government and therefore, it cannot be considered for disallowance. Further, the various attestation charges

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

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

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

9 of the income- tax Act, 1961, thus establishing that the liability to deduct tax ot source under section 195 arose which the assessee failed to discharge?" 11. "Whether on facts and in circumstances of the case and in law, the Ld. CIT(A) erred in allowing the deduction, holding that the year-end provision represents a known liability

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

SULZER PUMPS INDIA PVT LTD.,MUMBAI vs. DY CIT CIRCLE-15 (3)(2), MUMBAI

Accordingly, appeal of assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm The Dy. Commissioner Of Sulzer Pumps India Pvt Ltd. Income Tax, Circle 15(3)(2), Plot No.9, Midc, Digha, Room No. 451, Aayakar Thane- Belapur Road, Navi Vs. Bhavan, Maharshi Karve Mumbai-400 708 Road, Mumbai-400 020 (Respondent) (Appellant) Pan No. Aaack2238F Assessee By : Shri V. Shridharan & Ms. Manasi C, Ar Revenue By : Shri C T Mathew, Dr Date Of Hearing: 17.06.2022 Date Of Pronouncement : 16.09.2022

9. Marketing services (agency services) 28,62,597 CUP rendered and Commission received thereof 10. Warranty expenses paid to AES for 2,29,53,871 Other Method undertaking repair/ rectification work on behalf of the Assessee (including reversal of amount charged by the AEs for warranty claims in earlier years) 11. SAP related support services received

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

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 CHEMICALS LTD,MUMBAI vs. DCIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed

TATA CHEMICALS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

Appeal is hereby dismissed as infructuous

transfer pricing adjustment made M/s. Tata Chemicals Limited in respect of special purpose loan of USD 110 million. Accordingly, the ground No.1 raised by the assessee is allowed. 3. At this juncture, it would be relevant to address the additional ground raised by the assessee on 16/05/2011 which is as under:- 1. The appellant company prays that it be allowed