DEPUTY COMMISSIONER OF INCOME TAX 1(1)(2), MUMBAI vs. HINDUSTAN UNILEVER LIMITED, MUMBAI

801B & 10B and are in no way dependent on\nthe said new industrial undertakings and therefore cannot be considered and\nallocated in arriving at the amount of profits derived from the said\nundertakings.\nExpenditure attributable to earning of tax-free income - Section 14A\ndisallowance\n4. erred in confirming disallowance under section 14A in respect of\nexpenditure in relation

HINDUSTAN UNILEVER LIMITED,MUMBAI vs. DY.CIT-1(1)(2), MUMBAI

801B & 10B and are in no way dependent on\nthe said new industrial undertakings and therefore cannot be considered and\nallocated in arriving at the amount of profits derived from the said\nundertakings.\nExpenditure attributable to earning of tax-free income - Section 14A\ndisallowance\n4. erred in confirming disallowance under section 14A in respect of\nexpenditure in relation

DCIT(CC)-2(4), MUMBAI., MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

transfer pricing adjustment made for specified domestic transactions (SDT) pursuant to clause(i) of section 92BA which was omitted by Finance Act, 2017 w.e.f. 01.04.2017 which the ld. CIT(A) held to be applicable retrospectively by placing reliance on the decision in case of PCIT vs. Texport Overseas Pvt. Ltd. by Hon'ble High Court of Karnataka [2020]114 taxman.com568

DCIT(CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

transfer pricing adjustment made for specified domestic transactions (SDT) pursuant to clause(i) of section 92BA which was omitted by Finance Act, 2017 w.e.f. 01.04.2017 which the ld. CIT(A) held to be applicable retrospectively by placing reliance on the decision in case of PCIT vs. Texport Overseas Pvt. Ltd. by Hon'ble High Court of Karnataka [2020]114 taxman.com568

DCIT(CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

transfer pricing adjustment made for specified domestic transactions (SDT) pursuant to clause(i) of section 92BA which was omitted by Finance Act, 2017 w.e.f. 01.04.2017 which the ld. CIT(A) held to be applicable retrospectively by placing reliance on the decision in case of PCIT vs. Texport Overseas Pvt. Ltd. by Hon'ble High Court of Karnataka [2020]114 taxman.com568

DEPUTY COMMISSIONER OF INCOME TAX, (CC)-2(4), MUMBAI, MUMBAI vs. MACLEODS PHARMACEUTICALS LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Pavan Kumar Gadale & Shri Girish Agrawal

transfer pricing adjustment made for specified domestic transactions (SDT) pursuant to clause(i) of section 92BA which was omitted by Finance Act, 2017 w.e.f. 01.04.2017 which the ld. CIT(A) held to be applicable retrospectively by placing reliance on the decision in case of PCIT vs. Texport Overseas Pvt. Ltd. by Hon'ble High Court of Karnataka [2020]114 taxman.com568

PROCTER & GAMBLE HYGINE & HEALTH CARE LTD,MUMBAI vs. ADDL CIT RG 7(1), MUMBAI

In the result, appeal of the assessee is allowed

801B(13) r.w.s 801A(9). GROUND IV: The CIT(A) erred in upholding the penalty levied by the AO under Section 271(1(c) of the adjustment made by the Transfer Pricing

ACIT, MUMBAI vs. RELIANCE INDUSTRIES LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed whereas the cross-objection of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2014-15 Acit, Reliance Industries Ltd., Room No. 559, 5Th Floor, 3Rd Floor Maker Chamber Iv, Aayakar Bhavan, New Marine Vs. Nariman Point, S.O. Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

transfer pricing officer ("TPO") in his order u/s. 92CA(3) 5. Assessment of lower book profit by Computation of Income 3.07 not reducing principal portion of lease rent Excess Deduction u/s 10AA in respect of Jamnagar Refinery 7.0 The first issue is regarding excess deduction allowed u/s 10AA of the Act by treating the year under consideration as 5th year

ADDL CIT RG 7(1), MUMBAI vs. PROCTOR & GAMBLE HYGIENE & HEALTHCARE LTD, MUMBAI

Appeals are partly allowed

801B under the Act be allowed.‖ 19.1. Ground No. II raised by the Assessee in appeal for the Assessment Year 2005-06 is identical to Ground No. III raised in appeal by the Assessee for the Assessment Year 2004-05. Accordingly, in view our ITA. No. 6591 & 6549/Mum/2010 (AY 2004-05) ITA. No. 2780 & 2849/Mum/2011 (AY 2005-06) finding/adjudication

PROCTER & GAMGLE HYGIENE& HEALTHCARE ,LTD,MUMBAI vs. ACIT CIR 7(1), MUMBAI

Appeals are partly allowed

801B under the Act be allowed.‖ 19.1. Ground No. II raised by the Assessee in appeal for the Assessment Year 2005-06 is identical to Ground No. III raised in appeal by the Assessee for the Assessment Year 2004-05. Accordingly, in view our ITA. No. 6591 & 6549/Mum/2010 (AY 2004-05) ITA. No. 2780 & 2849/Mum/2011 (AY 2005-06) finding/adjudication

THE DY CIT, CIRCLE-4(1)(2),, AHMEDABAD vs. VODAFONE WEST LIMITED,, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

transferring the prepaid coupons or starter kits\nto the distributors and thus section 194H is not applicable on trade discounts\ngiven to prepaid distributors. We find that similar findings have also been\nrendered recently by the Co-ordinate Bench of the Tribunal in Vodafone\nDigilink Ltd. (supra), vide order dated 14.10.2024. Therefore, respectfully\nfollowing the decisions cited supra, the disallowance

VODAFONE WEST LIMITED,(FORMERLY KNOWN AS VODAFONE ESSAR GUJARAT LIMITED),AHMEDABAD vs. THE DY.CIT, CIRCLE-4(1)(2),, AHMEDABAD

In the result, the appeal by the Revenue is partly allowed for statistical\npurposes

transferring the prepaid coupons or starter kits\nto the distributors and thus section 194H is not applicable on trade discounts\ngiven to prepaid distributors. We find that similar findings have also been\nrendered recently by the Co-ordinate Bench of the Tribunal in Vodafone\nDigilink Ltd. (supra), vide order dated 14.10.2024. Therefore, respectfully\nfollowing the decisions cited supra, the disallowance

ADDL CIT CEN RG IX, MUMBAI vs. UNIPHOS ENTERPRISES LTD ( FORMLERY KNOWN AS UNITED PHOSPHORUS LTD), MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

801B. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not correct in directing the AO not to consider the amount of excise duty and sales tax totaling to Rs.37,83,51,575/- as a part of total turnover for the purpose of deduction u/s. 80HHC. 6. On the facts

ASST CIT CC 38, MUMBAI vs. UNIPHOS ENTERPRISES LTD, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

801B. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not correct in directing the AO not to consider the amount of excise duty and sales tax totaling to Rs.37,83,51,575/- as a part of total turnover for the purpose of deduction u/s. 80HHC. 6. On the facts

UNIPHOS ENTERPRISES LTD ( FORMERLY KNOWN AS UNITED PHOSPHORUS LTD),MUMBAI vs. ADDL CIT CEN RG IX, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

801B. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not correct in directing the AO not to consider the amount of excise duty and sales tax totaling to Rs.37,83,51,575/- as a part of total turnover for the purpose of deduction u/s. 80HHC. 6. On the facts

THE ACIT CC-38, MUMBAI vs. M/S. UNITED PHOSPHOROUS LTD, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

801B. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not correct in directing the AO not to consider the amount of excise duty and sales tax totaling to Rs.37,83,51,575/- as a part of total turnover for the purpose of deduction u/s. 80HHC. 6. On the facts

M/S. UNITED PHOSPHORUS LTD(NOW KNOWN AS UNIPHOS ENTERPRISES LTD),MUMBAI vs. THE DCIT CEN CIR-38, MUMBAI

In the result, the appeal of assessee is allowed

Bench: SHRI PAWAN SINGH (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

801B. 5. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) was not correct in directing the AO not to consider the amount of excise duty and sales tax totaling to Rs.37,83,51,575/- as a part of total turnover for the purpose of deduction u/s. 80HHC. 6. On the facts

M/S. ZENSAR TECHNOLOGIES LTD,MUMBAI vs. THE ACIT -2(3), MUMBAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Zensor Technologies Ltd V. Acit-2(3) Magnet House, 2Nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 Pan: Aaacf0742K (Appellant) (Respondent) Acit- 2(3) V. M/S. Zensor Technologies Ltd Room No. 555, Aayakar Bhavan Magnet House, 2Nd Floor Mumbai Narottam Morarjee Marg Ballard Estate, Mumbai- 400038 Pan: Aaacf0742K (Appellant) (Respondent)

price of the option is recognized as Deferred Employee's compensation and is charged to Profit and Loss account on straight line basis over the vesting period of the options. He brought to our notice pages 33, 36 and 37 of the paper book filed on 17 August 2021). In support of the contention that ESOP expenses have