SAMIR NARAIN BHOJWANI ,MUMBAI vs. DCIT 4(2)(1), MUMBAI

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

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

50, arising on transfer of long term capital assets, at the rates mentioned in section 112 of the Act instead of charging them at the normal rates as has been done by the AO.” ITA No. 1022/Mum/2025 – Revenue “1. Whether on the facts in the circumstances of the case the Ld.CIT(A) was justified in allowing the claim of Rs.3

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

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

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

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

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

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. 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

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. 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

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

1,83,27,826, was treated as the adjustment made to the arm's length price. 49. Being aggrieved of such adjustment, the assessee raised objections before the DRP. However, the DRP concurred with the view of the Transfer Pricing Officer. 50. The learned Sr. Counsel for the assessee submitted, since, a part of the services rendered under the IPSA

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

JSW ENERGY LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING) 2(3)(1), MUMBAI

In the result, the appeal is allowed

Bench: Us Is A Public Company Engaged In The Business Of Generation Of Power & Operation & Maintenance Of The Power Plants, As Also Other Allied Activities. During The Course Of Its Assessment Proceedings, The Assessing Officer Made A Reference Under Section 92Ca(1), For Determination Of The Arm‟S Length Price Of The International Transactions & Specified Domestic Transaction Entered Into By The Assessee With Its Associated Enterprises (Aes), To The Deputy Commissioner Of Income Tax, Assessment Year 2014-15 Page 2 Of 17

Transfer Pricing Officer in levying penalty of Rs 50,97,0400 under section 271G r.w.s. 274 of the Income Tax Act, 1961 in relation to the international and specified domestic transactions undertaken by the appellant.” 2. The relevant material facts are as follows. The assessee before us is a public company engaged in the business of generation of power

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

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

50. Ground no.1, has already been dealt with while deciding grounds no.10 and 15 of assessee’s appeal in ITA no.1671/Mum./2014, in the earlier part of the order. Therefore, separate adjudication is not required. 51. In ground no.2,the Revenue has challenged the decision of learned DRP in directing that the adjustment to be made by the Transfer Pricing

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

50%, being contrary to the principles of transfer pricing, contrary to the records, made in the absence of showing any comparable and compliance with the transfer pricing provisions and the same therefore ought to be deleted. Interest under section 234B 19. On the facts and in the circumstances of the case and in law, the learned AO erred in levying

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