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

56. In its transfer pricing analysis, the assessee benchmarked the international transaction with the AE by applying TNMM as the most appropriate method. The assessee selected eleven comparables with arithmetic mean of 12.83% as against the margin shown by it at13.33%. The Transfer Pricing Officer rejected some of the comparables selected by the assessee and introduced some fresh comparables. Finally

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

Transfer Pricing (*TP') adjustment in relation to export of finished goods 1.1. On the facts and circumstances of the case, and in law, the Hon'ble DRP has erred in upholding the action of the Ld. AO/TPO in determining the Arms' Length Price ('ALP') of the international transaction of export of finished goods at Rs. 10,35,77,048 instead

UTILITY SUPPLY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(4) MUMBAI, MUMBAI

In the result, the appeal filed by the Assessee is allowed

section 56(2)(viia) of the Act was inserted by Finance Act,\n2010 to prevent the practice of transferring of unlisted shares at\na price

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

56,365/- was made under Section 40A(3)of the Act. Accordingly, the total income was computed at ₹64,78,14,863/- by order dated 14th February, 2011. 073. Assessee preferred the appeal before the learned CIT (A), who passed an order on 12th December, 2011. The learned CIT (A) considering the transfer pricing

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

section 144C(13) of the Income Tax Act, 1961 (for short "the Act") in pursuance to the directions of the Dispute Resolution Panel–III (DRP), Mumbai. 2. Since all these appeals pertain to the same assessee involving common issues arising out of identical set of facts and circumstances, therefore, as a matter of convenience, these appeals were heard together

M/S. MERCATOR LTD,MUMBAI vs. THE DY CIT 5(2), MUMBAI

In the result, the appeal filed by the revenue and CO by the asssessee are dismissed and the asseessee appeal is allowed for statistical purposes

Bench: Shri Baskaran Br & Shri Pavan Kumar Gadaleita No. 7278/Mum/2017 (A.Y: 2010-11) & Co No. 21/Mum/2019 (2010-11) (Arising Out Of Ita No. 29/Mum/2018) Mercator Ltd Vs. Dcit 3Rd Floor, Mittal Tower- Range 5(2) B Wing, Nariman Point Aayakar Bhavan, Mk Mumbai- 400021. Road, Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Dy. Cit Vs. Mercator Lines Ltd Range 5(2)(2), Rno.571 3Rd Floor, Mittal Tower- Aayakar Bhavan, Mk B Wing, Nariman Point Road, Mumbai – 400 021. Mumbai - 400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacm5007A Appellant .. Respondent Assessee By : Mr.Nikhil Tiwari.Ar Revenue By : Mr.Krishnakumarmishra.Dr Date Of Hearing 30.11.2022 Date Of Pronouncement 22.12.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: 29/Mum/2018 & Co No. 21/Mum/2019 M/S. Mercator Ltd, Mumbai. The Cross Appeal Is Filed By The Assessee & The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) (Cit(A))-57, Mumbai Passed U/S 250 Of The Act & The Assessee Has Filed The Cross Objection(Co) In The Revenue Appeal.

56,000 as against Rs 1,36,34,299 computed by the Appellant; Levy of Interest under section 234C of the Act 27. erred in upholding interest under section 234C of the Act; Levy of Interest under section 234D of the Act 28. erred in upholding interest under section 234D of the Act; Penalty proceedings 29. erred in initiating penalty

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

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

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer was also found that there is also an international transaction of reimbursement and recovery of expense amounting to ₹2,75,66,373/-. The Associated Enterprises incurred certain expenses on behalf of assessee related to the hotel, Visa and other cost. These were reimbursed by the assessee to the Associated Enterprises on cost to cost basis. similarly; there

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

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Transfer Pricing Officer was also found that there is also an international transaction of reimbursement and recovery of expense amounting to ₹2,75,66,373/-. The Associated Enterprises incurred certain expenses on behalf of assessee related to the hotel, Visa and other cost. These were reimbursed by the assessee to the Associated Enterprises on cost to cost basis. similarly; there