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2,201 results for “transfer pricing”+ Section 43(6)clear

Sorted by relevance

Delhi2,529Mumbai2,201Bangalore880Ahmedabad457Chennai439Karnataka365Kolkata359Hyderabad315Jaipur293Chandigarh219Pune186Surat153Indore147Cochin104Rajkot63Calcutta60SC54Cuttack52Lucknow44Visakhapatnam44Raipur41Telangana40Nagpur39Agra28Guwahati28Jodhpur21Amritsar18Rajasthan9Ranchi8Dehradun7Allahabad7Kerala7Varanasi6Orissa5A.K. SIKRI ROHINTON FALI NARIMAN5Panaji4Patna2DIPAK MISRA V. GOPALA GOWDA1MADAN B. LOKUR S.A. BOBDE1Andhra Pradesh1

Key Topics

Section 143(3)76Addition to Income49Disallowance38Transfer Pricing38Section 14A32Section 92C27Section 115J21Section 144C(5)20Deduction19

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

In the result, assessee’s appeal is partly allowed

ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

section 133(6) of the Act was made available to the assessee. He has not properly evaluated all the objections of the assessee. The DRP also upheld the finding of the Transfer Pricing Officer by simply observing that the services provided by the company are largely in the nature of software services. Notably, in case of Invensys Development Centre India

Showing 1–20 of 2,201 · Page 1 of 111

...
Comparables/TP19
Depreciation16
Section 4015

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

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

6. Justifying the change in the method of royalty payment from net sales to gross sales, the assessee submitted that the licensor always intended to collect royalty on gross sales. However, it was not able to do so prior to 2009 owing to the restrictions in the Foreign Direct Investment policy (FDI) prevalent at that time which required net sales

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

43. Insofar as five other companies selected by the assessee viz. Aryaman Financial Services Ltd., Excess India Advisors India Ltd., ICRA Management Consulting Services Ltd., ICRA On–line Limited, Kinetic Trust Ltd., on a perusal of the order of the Transfer Pricing Officer, we find, he has neither made any discussion on these companies nor has assigned any reason

ZEE ENTERTAINMENT ENTERPRISES LIMITED,MUMBAI vs. ADDL. COMM OF INCOME TAX RANGE-11 (1), MUMBAI

In the result, appeal of the assessee is partly allowed

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

Bench: Shri G.S.Pannu & Shri Ravish Soodzee Entertainment Enterprises Ltd., 135, Continental Building, Dr.A.B.Road, Worli, Mumbai 400 020 Pan:Aaacz 0243R ...... Appellant Vs. The Addl. Commissioner Of Income Tax, Range -11(1), 4Th Floor, Room No.434, Aaykar Bhavan,M.K.Road, Mumbai – 400 020 .... Respondent

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

6. On the other hand, the Ld. Departmental Representative appearing for the Revenue primarily reiterated the stand of the Transfer Pricing Officer. It is 10 sought to be pointed out that the Transfer Pricing Officer had called for the stock inventory of all the programmes indicating their cost, unamortized amount on the date of sale, selling price, difference between book

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

43. The learned Sr. Counsel for the assessee submitted, while deciding identical issue in assessment year 2008–09, the Tribunal has held that the services rendered under IPSA being in the nature of ITES, the assessee is eligible to claim deduction under section 10A of the Act. Further, he submitted, insofar as SEZ units are concerned, the assessee is eligible

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

In the result, the appeal filed by the assessee is partly allowed

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

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

Section 143(3)Section 144C(5)

6. Aggrieved by the directions of the DRP, the assessee is in appeal before us. 7. The first issue that came up for our consideration from ground 1 of the appeal is transfer pricing adjustment in relation to export of finished goods. The facts with regard to the impugned dispute are that the assessee has exported finished goods

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

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

Transfer Pricing Officer did not accept the explanation of the assessee and interest rate at libor + 300 basis points. Accordingly, with respect to amount of advance of `6,18,679/- was made. Accordingly, the order under Section 92CA(3) of the Act was passed on 30th October, 2009. Consequently, a draft assessment order was passed on 25th November

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

6 J.P. Morgan Advisors India Pvt. Ltd. 10. In ground no.3, the assessee has challenged the addition made of ` 1,57,46,155, on account of adjustment to the arm's length price of investment advisory services. 11. Brief facts are, the assessee is a subsidiary of J.P. Morgan Securities India Pvt. Ltd. and is a part of J.P. Morgan

THERMO FISHER SCIENTIFIC INDIA PVT LTD. ,MUMBAI vs. DCIT-15(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for In the result, the appeal of the assessee is allowed for statistical purposes

ITA 769/MUM/2023[2009-10]Status: DisposedITAT Mumbai31 Jul 2023AY 2009-10

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2009-10 Thermo Fisher Scientific India Dy. Cit-15(3)(1), Pvt. Ltd., Room No. 360, Aayakar Vs. 403-404, ‘B’ Wing, Delphi, Bhavan, New Marine Lines, Hiranandani Business Park, Mumbai-400020. Mumbai-400076. Pan No. Aabct 3207 A Appellant Respondent

For Appellant: Mr. Niraj ShethFor Respondent: Mr. Mudit Nagpal, CIT-DR
Section 43(1)

43(6) of the IT Act of the Act and holding that the cost of goodwill in the hands of of the Act and holding that the cost of goodwill in the hands of of the Act and holding that the cost of goodwill in the hands of Appellant should be nil, without appreciating that the said Appellant should

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

6), Mumbai, by his order dated 13/01/14. The main contention of the assessee Company was that the provisions of transfer pricing regulations do not apply to the companies, whose income is taxable under the Tonnage Tax Scheme, and hence, the adjustment/enhancement of income made in the transfer pricing order would not have any effect on the taxable income

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

transfer pricing officer with similar direction. Accordingly, ground number 1 of the appeal is allowed for statistical purposes. 036. This is the solitary issue in the appeal of assessee, therefore appeal of the assessee is allowed for statistical purposes. 037. The learned assessing officer has preferred cross objection and raised following grounds:- CO 180/MUM/2019 Arising out of ITA 588/MUM/2017