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40 results for “transfer pricing”+ Section 44Dclear

Sorted by relevance

Delhi51Mumbai40Dehradun6Bangalore5Kolkata3Indore1SC1

Key Topics

Double Taxation/DTAA26Permanent Establishment24Business Income20Section 143(3)11Addition to Income11Section 9210Section 145A8Section 234B8Section 271(1)(c)6Section 10A6Section 44D6Penalty6

GREATSHIP (INDIA ) LTD,MUMBAI vs. DCIT 5(1)(1), MUMBAI

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1287/MUM/2017[2012-13]Status: DisposedITAT Mumbai05 Apr 2021AY 2012-13

Bench: Shri S.Rifaur Rahman () & Shri Ravish Sood () Ita No.6083/Mum/2018 (Assessment Years: 2012-13 & 2014-15) Greatship (India) Ltd., Dy. Commissioner Of Income- C/O. Kalyaniwalla & Mistry, Vs. Tax-5(1)(1), Army & Navy Building, 3Rd Floor, Room No. 568, 5Th Floor, 148, Mahatma Gandhi Road, Aayakar Bhavan, M.K. Road, Fort, Mumbai – 400 001 Mumbai – 400 020

For Appellant: Shri M.M. Golvala &For Respondent: Shri Anand Mohan &
Section 143(3)Section 92BSection 92C

transfer pricing adjustment of Rs. 62,23,256/- made towards notional interest. The Grounds of appeal nos. 12 to 14 are allowed in terms of our aforesaid observations. 21. We shall now deal with the claim of the assessee that the A.O/DRP had erred in invoking Rule 8D without recording an objective satisfaction that having regard to the accounts

Showing 1–20 of 40 · Page 1 of 2

STAR INDIA PVT.LTD.,MUMBAI vs. ADDL.C.I.T.-RANGE311(1), MUMBAI

The appeal of the AO is dismissed

ITA 6332/MUM/2008[2003-2004]Status: DisposedITAT Mumbai20 May 2016AY 2003-2004
For Appellant: S/Shri Porus Kaka & Divesh ChawlaFor Respondent: Shri N.K. Chand-CIT
Section 143(3)Section 254(1)Section 92

Transfer Pricing Officer has already been obtained and the issue requires proper examination by the Assessing Officer in the light of the report of TPO, detailed analysis of licence fee paid and other evidences filed by the assessee, we set aside the order of the CIT(A) in this regard and the matter is restored to the file

GENERAL MOTORS OVERSEAS CORPORATION,GURGAON vs. DDIT (IT) 3(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 2787/MUM/2014[2008-09]Status: DisposedITAT Mumbai06 Mar 2020AY 2008-09

Bench: Shri Laliet Kumar & Shri M. Balaganesha.Y : 2004-05 :

For Appellant: S.K. Aggarwal Advocate For AssesseeFor Respondent: Avinish Tiwari DR for Revenue
Section 234BSection 44DSection 92

44D of the Act in complete disregard to the facts of the Appellant’s case and also the provisions of the Double Tax Avoidance Agreement with USA *“the DTAA”+. 4. The learned CIT(Appeals) also erred in fact and in law in completely ignoring the provisions of Article 12 Para 6 of the DTAA in levying tax as “Fees

GENERAL MOTORS OVERSEAS CORPORATION vs. ACIT (IT) 3(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 1282/MUM/2009[2004-2005]Status: DisposedITAT Mumbai06 Mar 2020AY 2004-2005

Bench: Shri Laliet Kumar & Shri M. Balaganesha.Y : 2004-05 :

For Appellant: S.K. Aggarwal Advocate For AssesseeFor Respondent: Avinish Tiwari DR for Revenue
Section 234BSection 44DSection 92

44D of the Act in complete disregard to the facts of the Appellant’s case and also the provisions of the Double Tax Avoidance Agreement with USA *“the DTAA”+. 4. The learned CIT(Appeals) also erred in fact and in law in completely ignoring the provisions of Article 12 Para 6 of the DTAA in levying tax as “Fees

GENERAL MOTORS OVERSEAS CORPORATION,GURGAON vs. DDIT (IT) 3(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 1986/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Mar 2020AY 2009-10

Bench: Shri Laliet Kumar & Shri M. Balaganesha.Y : 2004-05 :

For Appellant: S.K. Aggarwal Advocate For AssesseeFor Respondent: Avinish Tiwari DR for Revenue
Section 234BSection 44DSection 92

44D of the Act in complete disregard to the facts of the Appellant’s case and also the provisions of the Double Tax Avoidance Agreement with USA *“the DTAA”+. 4. The learned CIT(Appeals) also erred in fact and in law in completely ignoring the provisions of Article 12 Para 6 of the DTAA in levying tax as “Fees

GENERAL MOTORS OVERSEAS CORPORATION,MUMBAI vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) 3(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 381/MUM/2018[2010-11]Status: DisposedITAT Mumbai06 Mar 2020AY 2010-11

Bench: Shri Laliet Kumar & Shri M. Balaganesha.Y : 2004-05 :

For Appellant: S.K. Aggarwal Advocate For AssesseeFor Respondent: Avinish Tiwari DR for Revenue
Section 234BSection 44DSection 92

44D of the Act in complete disregard to the facts of the Appellant’s case and also the provisions of the Double Tax Avoidance Agreement with USA *“the DTAA”+. 4. The learned CIT(Appeals) also erred in fact and in law in completely ignoring the provisions of Article 12 Para 6 of the DTAA in levying tax as “Fees

DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 5228/MUM/2004[2000-2001]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-2001

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

REFINITIV LTD.,MUMBAI vs. DDIT (I.TAXATION) RANGE 2, MUMBAI

Appeals are disposed off

ITA 5092/MUM/2004[2000-01]Status: DisposedITAT Mumbai28 Jun 2023AY 2000-01

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1979/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

REFINITIV LTD.,MUMBAI vs. ADIT (IT) RG 2(1), MUMBAI

Appeals are disposed off

ITA 3617/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

ADIT (IT) RG 2, MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 5155/MUM/2009[2005-06]Status: DisposedITAT Mumbai28 Jun 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

DDIT (IT) 2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4550/MUM/2013[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

THE DDIT(IT)-2(1), MUMBAI vs. M/S. REUTERS LTD, UK, MUMBAI

Appeals are disposed off

ITA 1978/MUM/2008[2003-2004]Status: DisposedITAT Mumbai28 Jun 2023AY 2003-2004

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

REFINITIV LTD.,MUMBAI vs. THE DY DIT (I.T) 2(1), MUMBAI

Appeals are disposed off

ITA 8348/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

REFINITIV LTD.,MUMBAI vs. DCIT (IT) 2(1), MUMBAI

Appeals are disposed off

ITA 1287/MUM/2009[2004-2005]Status: DisposedITAT Mumbai28 Jun 2023AY 2004-2005

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

REFINITIV LTD.,MUMBAI vs. DDIT (I.T) - 2(1), MUMBAI

Appeals are disposed off

ITA 3422/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

ADIT (IT)-2(1), MUMBAI vs. REUTERS LTD, MUMBAI

Appeals are disposed off

ITA 4575/MUM/2010[2006-07]Status: DisposedITAT Mumbai28 Jun 2023AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

THE DDIT (I.T) 2(1) vs. M/S. REUTERS LTD.,

Appeals are disposed off

ITA 8463/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

THE DDIT (I.T) 2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 8464/MUM/2004[2001-2002]Status: DisposedITAT Mumbai28 Jun 2023AY 2001-2002

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that

ADIT (IT)-2(1), MUMBAI vs. M/S. REUTERS LTD., MUMBAI

Appeals are disposed off

ITA 3366/MUM/2006[2002-2003]Status: DisposedITAT Mumbai28 Jun 2023AY 2002-2003

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Assessment Year 2000 – 01

For Appellant: Shri Niraj D Sheth, AdvocateFor Respondent: Shri Sunil Umap, DR

44D of the act. He accordingly tax the revenues of the assessee received from routers India private limited in the form of distribution fee, product distribution fee and license fee on gross basis at 30% up the provisions of section 115A of the act. With respect to the revenue on front the agreement with ANI media, he held that