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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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

73,43,364/-. The learned Assessing Officer further examine the deduction under Section 80IB for Silvassa unit and found that assessee is claimed deduction on export incentive of DEPB of ₹7190,276/- by reducing it from the cost of material consumed. According to learned Assessing Officer, the above income is not derived from industrial under taking and therefore, to that

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 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

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

Transfer Pricing Officer in Page–37 of his order submitted, assessee also provides high end information technology enabled services, hence, assessee’s objections should not be accepted. 67. We have considered the submissions of the parties and perused the material available on record. We have noted that the Tribunal, Bangalore Bench, in Symphony Marketing Solutions India Pvt. Ltd. (supra), after

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

1 of the appeal is transfer pricing adjustment in relation to export of finished goods. The facts with regard to the impugned dispute are that the assessee has exported finished goods to its AE. The assessee has benchmarked its transactions with AE in respect of sale of finished goods by applying TNMM as most appropriate method. The AO has rejected

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

73. This company though was rejected by the assessee in its transfer pricing study report, however, the Transfer Pricing Officer accepted it as a comparable stating that it is functionally similar to the assessee. However, while considering assessee’s objection, learned DRP rejected the company as a comparable since it did not qualify IT service income filter of 75% applied

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 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 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

TATA AIG GENERAL INSURANCE COMAPANY LTD,MUMBAI vs. ASST CIT 2(3), MUMBAI

In the result, the appeal of the assessee is allowed

1,24,66,73,601/-. 9 A.Y. 2009-10 Tata AIG General Insurance 12. Here in this case, from a perusal of the chronology of events as incorporated above, it can be seen that the transfer pricing order u/s 92CA(3) as per the statute ought to have been passed on 29.01.2013, i.e., the period of 60 days prior

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

1) of the Act. As per Ld. Representative for the assessee, the aforesaid loss of Rs.26,73,93,000/- was not in the nature of ‘speculation’ as envisaged under section 43(5) of the Act. Accordingly to him, provisions of section 43(5) of the Act are attracted only to transactions which, inter-alia, involve a contract for purchase