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

2. 66.00% Edelweiss Capital Ltd. 3. 13.88% IDC India Ltd. 4. 184.91% L&T Capital Co. Ltd. 5. 6.51% SERI Capital Markets Ltd. 6. Sumedha Fiscal Service Ltd. 48.84% 7. (segmental) Keynote Corporate Services Ltd. 209.19% 8. (segmental) 105.10% Arithmetic mean 8. Applying the arithmetic mean of 105.10%, the Transfer Pricing Officer worked out the arm's length price

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

55. The DRP, however, agreed with the computation of the Assessing Officer. 56. The learned Sr. Counsel for the assessee submitted that deduction under section 10A of the Act has to be allowed unit–wise from the gross total income and thereafter loss has to be set off. In this context he relied upon the decision

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

2,81,17,008.\nThe Appellant prays that the AO be directed to grant relief in\nrespect of levy of interest under section 234B of the Act, in\nconsequence to relief granted in respect of the aforesaid grounds\nof appeal.\nGround 6- Levy of interest under section 234D of the Act\n6.1. On the facts and in the circumstances

ASSISTANT COMMISSIONER OF INCOME TAX 25(3), MUMBAI vs. PANKAJ ENTERPRISES, MUMBAI

In the result, both the appeals of the Revenue for AY 2012

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 Pankaj Enterprises, Jt. Cit Range-25(3), C/O Shankarlal Jain & Assoicates Pritashkar Bhavan, Bkc, 12, Engineer Building, 265, Vs. Bandra (E), Princess Street, Mumbai-400051. Mumbai-400 002. Pan No. Aacfp 3044 K Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2012-13 Asst. Commissioner Of Income Tax- M/S Pankaj Enterprises, 25(3), Plot No. 1, Behind Ice Factory, Room No. 601, C-10, 6Th Floor, Vs. Saki Vihar Road, Chandivali, Pratyakshakar Bhavan, Bandra Mumbai-400072. Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfp 3044 K Appellant Respondent Co No. 313/Mum/2018 (Ita No. 4875/Mum/2017) Assessment Year: 2009-10 & Co No. 312/Mum/2018 (Ita No. 4876/Mum/2017) Assessment Year: 2012-13

2 and 3 of the appeal as well as raised of the appeal as well as raised by the assessee in ground No. see in ground No. 1 of its appeal. Pankaj Enterprises ITA NO. 3773, 4875 & 12. The assessee in its computation of long The assessee in its computation of long-term capital gain has term capital gain

PANKAJ ENTERPRISES,MUMBAI vs. JT CIT RG 25(3), MUMBAI

In the result, both the appeals of the Revenue for AY 2012

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 Pankaj Enterprises, Jt. Cit Range-25(3), C/O Shankarlal Jain & Assoicates Pritashkar Bhavan, Bkc, 12, Engineer Building, 265, Vs. Bandra (E), Princess Street, Mumbai-400051. Mumbai-400 002. Pan No. Aacfp 3044 K Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2012-13 Asst. Commissioner Of Income Tax- M/S Pankaj Enterprises, 25(3), Plot No. 1, Behind Ice Factory, Room No. 601, C-10, 6Th Floor, Vs. Saki Vihar Road, Chandivali, Pratyakshakar Bhavan, Bandra Mumbai-400072. Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfp 3044 K Appellant Respondent Co No. 313/Mum/2018 (Ita No. 4875/Mum/2017) Assessment Year: 2009-10 & Co No. 312/Mum/2018 (Ita No. 4876/Mum/2017) Assessment Year: 2012-13

2 and 3 of the appeal as well as raised of the appeal as well as raised by the assessee in ground No. see in ground No. 1 of its appeal. Pankaj Enterprises ITA NO. 3773, 4875 & 12. The assessee in its computation of long The assessee in its computation of long-term capital gain has term capital gain

ASSISTANT COMMISSIONER OF INCOME TAX 25(3), MUMBAI vs. PANKAJ ENTERPRISES, MUMBAI

In the result, both the appeals of the Revenue for AY 2012

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 Pankaj Enterprises, Jt. Cit Range-25(3), C/O Shankarlal Jain & Assoicates Pritashkar Bhavan, Bkc, 12, Engineer Building, 265, Vs. Bandra (E), Princess Street, Mumbai-400051. Mumbai-400 002. Pan No. Aacfp 3044 K Appellant Respondent Assessment Year: 2009-10 & Assessment Year: 2012-13 Asst. Commissioner Of Income Tax- M/S Pankaj Enterprises, 25(3), Plot No. 1, Behind Ice Factory, Room No. 601, C-10, 6Th Floor, Vs. Saki Vihar Road, Chandivali, Pratyakshakar Bhavan, Bandra Mumbai-400072. Kurla Complex, Bandra (East), Mumbai-400051. Pan No. Aacfp 3044 K Appellant Respondent Co No. 313/Mum/2018 (Ita No. 4875/Mum/2017) Assessment Year: 2009-10 & Co No. 312/Mum/2018 (Ita No. 4876/Mum/2017) Assessment Year: 2012-13

2 and 3 of the appeal as well as raised of the appeal as well as raised by the assessee in ground No. see in ground No. 1 of its appeal. Pankaj Enterprises ITA NO. 3773, 4875 & 12. The assessee in its computation of long The assessee in its computation of long-term capital gain has term capital gain

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

2 and 6, being general in nature, do not require adjudication. 55. In grounds no.13 to 19, the assessee has challenged selection / rejection of certain comparables under Information Technology (IT) Service and Information Technology Enabled Services (ITES) segments. At first, we will deal with the comparables disputed under Information Technology Service segment. 56. In its transfer pricing analysis, the assessee

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

2. Having held so, it is necessary to examine whether the benchmarking of the Transfer Pricing Officer insofar as it relates to interest payment to the 34 ITA 6081/Mum/2018 AE on ECB loan is correct. On perusal of the facts and material on record, we are of the view that determination of arm's length price of interest charged

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing

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

55,079/-. Accordingly, the order under Section 92CA(3) of the Act was passed on 29th October, 2010 proposing the total transfer pricing adjustment of ₹1,66,99,302/-. 072. Income of the assessee was assessed under Section 143(3) of the Act vide order dated 14th February, 2011, wherein over and above the transfer pricing adjustment the learned Assessing