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2,132 results for “transfer pricing”+ Section 44clear

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Key Topics

Section 143(3)57Addition to Income56Disallowance44Transfer Pricing34Section 14A33Section 92C25Deduction21Double Taxation/DTAA15Section 144C(5)

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 2,132 · Page 1 of 107

...
14
Section 40A(2)14
Depreciation14
Section 115J13

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)

44. With the aforesaid observations, we restore the issue back to the file of the Assessing Officer. Consequently, ground no.1, is allowed for statistical purposes. 45. In ground no.2, assessee has challenged transfer pricing adjustment made in respect of information technology enabled services (ITES) segment. 46. Though, in ground no.2 with sub grounds the transfer pricing adjustment with regard

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)

Transfer Pricing Officer himself has allowed working capital adjustment to the assessee. That being the case, we direct the Assessing Officer/Transfer Pricing Officer to consider assessee’s claim of working capital adjustment while computing the margins of the comparables.” 34. In view of the aforesaid, we direct the Assessing Officer to consider assessee’s claim of working capital adjustment keeping

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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

Section 40A (3) of the Act was also confirmed. Accordingly, the appeal of the assessee was dismissed and therefore, assessee has preferred this appeal before us. 074. The ground no.1 of the appeal with respect to the transfer pricing adjustment wherein adjustment of ₹1,17,44

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)

44. Brief facts are, during the year under consideration assessee provided support services to its AEs in respect of building MS Access databases and MS Excel work sheets. In the transfer pricing analysis, the assessee benchmarked the aforesaid transaction by selecting TNMM as the most appropriate method with operating profit to operating cost as the PLI. By undertaking a search

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)

section 143(3) r.w.s. 144C of the Income Tax Act, 1961 (in short ‘the Act’) dated 15/02/2012. 2 2. The Grounds of appeal raised by the assessee read as under:- “1. Addition on account of Arm's Length Price by TPO Rs. 24,91,59,200/- (i) The Ld. CIT (A) erred in law and facts in upholding rejection

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(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 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

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

44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

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

44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(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 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

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

44,898,014/– on 28/11/2012 by making a transfer pricing adjustment of ₹ 6,278,920/– and disallowance of depreciation on goodwill of ₹ 21,100,663/–. The adjustment on account of the transfer pricing was made in view of the order of the learned transfer pricing officer dated 6/1/2016 passed under section

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

Transfer Pricing Officer without proper FAR analysis, without applying any most appropriate method and without considering any comparable is not justified. In support of his submissions, the learned A.R. for the assessee placed reliance on the following decisions:– i) CIT v Lever India Exports Ltd ITA No 1306 of 2014, order dated 23.01.2017 (Bom); ii) CIT V Merck

DCIT CIR 3(1), MUMBAI vs. GLOBE OP FINANCIAL SERVICES (INDIA) P. LTD, MUMBAI

In the result, Department’s appeal is partly allowed for statistical purposes

ITA 1610/MUM/2011[2005-06]Status: DisposedITAT Mumbai13 Jun 2016AY 2005-06

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri Saurabh Soparkar a/wFor Respondent: Shri Sambit Mishra
Section 92C

section 143(3) adding the amount of ` 2,62,84,830. Being aggrieved of the assessment order so passed, the assessee preferred appeal before the first appellate authority. 4. The learned Commissioner (Appeals), after considering the submissions of the assessee and on a perusal of the material on record, accepted the contention of the assessee that two companies selected