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

In the result, assessee’s appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

Transfer Pricing Officer. 50. The learned Sr. Counsel for the assessee submitted, since, a part of the services rendered under the IPSA was neither in the nature of software development or ITES the assessee benchmarked it separately. He submitted, for that reason also the assessee did not claim deduction under section

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

In the result, appeal stands partly allowed

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

section 10A of the Act. 8. Without prejudice to the above ground, the learned AU erred in reducing the telecommunication charges only from the export turnover and not from both, i.e total turnover and export turnover, in computing the deduction u/s 10A of the Act. 9. The Appellant craves leave to add, alter, vary, omit, substitute or amend

ACIT 421 MUMBAI, MUMBAI CITY vs. SAMIR NARAIN BHOJWANI, MUMBAI

Appeal of the assessee is allowed for statistical purposes and the\nappeal of the revenue is dismissed

50, arising on transfer of long term capital assets, at the\nrates mentioned in section 112 of the Act instead of charging them at the normal\nrates as has been done by the AO.\"\n3\nITA Nos.261 & 1022/Mum/2025\nSamir Narain Bhojwani\nITA No. 1022/Mum/2025 – Revenue\n1. Whether on the facts in the circumstances of the case the Ld.CIT

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

In the result, appeal is partly allowed

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

Transfer Pricing Officer has classified the income received under IPSA agreement to be of the nature of ITES and has also benchmarked it as such, the Assessing Officer cannot take a contrary view by stating that it is not in the nature of ITES only for disallowing assessee’s claim of deduction under section 10A of the Act. The Department

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

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

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 92C 8 ITA 6081/Mum/2018 r.w.r.10B, the arms length price in relation to an international transaction shall be determined by adopting any one method thereunder and not by adopting two methods as the most appropriate method. The assessee has also argued for not adopting as most appropriate method, as per which, the price at which finished goods are exported

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

In the result, appeal is partly allowed

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

50. We have considered rival submissions and perused the material on record. Undisputedly, the Transfer Pricing Officer rejected this company as a comparable on the reasoning that it fails export earning filter of 75%. Therefore, it is evident, there is no dispute with regard to functionally similarity between the assessee and this company. On a perusal of the annual report

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

DCIT (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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

sections 092. Accordingly total income was assessed at ₹ 331,392,165 against the returned income of ₹ 278,678,540/-. 093. The assessee aggrieved with assessment order preferred an appeal before the learned CIT – A. The transfer pricing adjustment made by the learned assessing officer based on the order of the learned transfer pricing officer was confirmed Ipca Laboratories

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

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

section 92C in conformity with the arm's length price as so determined by the Transfer Pricing Officer." IT(TP)A No.720/MUM/2015 Page 8 of 29 “The Transfer Pricing Officer vide order u/s. 92CA(3) of the income-tax Act, 1961, dated 13/01/14 has held that adjustments aggregating to Rs.17,24,50

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

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

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