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

1,56,365/- 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

1,56,365/- 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

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

1,56,365/- 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

1,56,365/- 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

1,56,365/- 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

1,56,365/- 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

1,56,365/- 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

1,56,365/- 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

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

56,74,029. 6. The Transfer Pricing Officer after analysing the activity of the assessee and the nature of business in the aforesaid three categories was of the view that the functions are basically in the nature of merchant banking service for the Associate Enterprise (A.E). Though, the assessee tried to impress upon the Transfer Pricing Officer that the aforesaid

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

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

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

56,40,90,000/- and re-compute deduction under Section 80IA of the Act after including Other Income. Accordingly, Ground No. 6 raised by the Assessee is allowed. Ground No. 7 10. Ground No. 7 raised by the Assessee pertains to transfer pricing adjustment. Ground No. 7.1 and 7.2 11. Ground No. 7.1 and 7.2 raised by the Assessee

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

NERKA CHEMICALS P. LTD,GUJRAT vs. ASST CIT CEN CIR 38, MUMBAI

In the result this ground of appeal is allowed for statistical purpose

Bench: Shri R.C. Sharma, Accountant Mamber & Shri Pawan Singh

prices much below their fair market value or without any consideration. It is pertinent to mention that after amendment to section 56(2)(viia), only the inadequate consideration is deemed to be income chargeable to tax. It is not in dispute that the assessee has received gift of shares of UPL and UEL being listed company, which cannot be treated

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI vs. CIT (TRANSFER PRICING)-4, MUMBAI

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section

ZENZI PHARMACEUTICAL INDUSTIES PVT LTD.,MUMBAI CITY vs. CIT (TRANSFER PRICING)-4, MUMBAI CITY

In the result all the four appeals filed by the assessee are dismissed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

transfer-pricing officer to compute the arm‟s- length price of the international transaction on 30/12/2019. The learned TPO passed an order under section 92CA (3) of the Act dated 27/1/2021 stating that the value of the international transaction with its associated enterprises are not being disturbed, since assessee has not filed 3CEB report. Penalty proceedings were initiated under section