M/S. LAXMI ORGANIC INDUSTRIES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(2)(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Section 80A(6), there is, in effect, no change in the\nlegal position so far as the transfer price of the electricity

DCIT-5(2)(1),MUMBAI, AAYAKAR BHAVAN vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, C.O. filed by assessee is\ndismissed as infructuous

80A(6)", "Section 92BA", "Section 92F", "Section 14A", "Section 115JB", "Section 41(1)" ], "issues": "The main issue revolves around the correct determination of the Arm's Length Price (ALP) for the inter-unit transfer

DY. COMMISSIONER OF INCOME TAX 5(2)(1), MUMBAI, MUMBAI vs. JSW STEEL COATED PRODUCTS LIMITED, MUMBAI

In the result, appeal of the

Bench: Shri Pawan Singh & Shri Girish Agrawal

6) of Section 80A, that the expression “market value” in relation to any goods or services sold, supplied or acquired means the “arm’s length price” as defined in clause (ii) of section 92F of such goods or services, if it is a specified domestic transactions referred to in section 92BA? 43. After examining various provisions under the Electricity

KBS CREATION LTD ,MUMBAI vs. DY COMM. OF INCOME TAX -CIRCLE 24(1), MUMBAI

In the result, the concise ground of appeal of the assessee is allowed

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

6 KBS Creations(AY: 2021-22) aforesaid submissions,the assessee submitted that profit of assessee is consistent with the period of tax holiday as well as non-tax holiday. The DRP after considering the submission of assessee held that TPO has dealt this issue and address that being controlled transaction; this cannot be taken as bench mark. Transfer pricing analysis

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

In the result, the appeal is partly allowed

Bench: Amit Shukla () & Ms. Padmavathy S. ()

80A clearly states that in computing the total income of an assessee, there shall be allowed from his “gross total income”, the deductions specified in sections 80C to 80U. We are, therefore, of the considered view that the ratio laid down by the Hon’ble Supreme Court in Reliance Energy (supra) is clearly applicable to Assessee’s case also

DCIT(CC)-8(3) , MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment\nyears under consideration stands partly allowed and cross\nappeals filed by the assessee stands dismissed

Price.\n6.3.7 With reference to above, judicial precedents rendered by various\nTribunals while examining 'market price' in the context of power supplied\nby power plants to manufacturing units has held that the rate at which\nthe State Electricity Board supplies power to its consumers is to be\nconsidered to be the market value:\n• M/s Hero Motocorp Limited

AAACORP EXIM INDIA PRIVATE LIMITED,MUMBAI vs. D.C.I.T.-CIRCLE-14(1)(1), MUMBAI

In the result the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri Gagan Goyal & Aaa Corp Exim India Pvt. Ltd. C-206, Ghatkopar Industrial Estate, Off Lbs Marg, Ghatkopar (W), Mumbai-400 086 Pan: Aacca8815C ...... Appellant Vs. Dcit-14(1)(1) Income Tax Offices, Aayakar Bhavan, M. K. Road, Mumbai-400 020 ..... Respondent

80A; (iii) any transfer of goods or services referred to in sub-section (8) of section 80-IA; (iv) any business transacted between the assessee and other person as referred to in sub- section (10) of section 80-IA; (v) any transaction, referred to in any other section under Chapter VI-A or section 10AA, to which provisions

DCIT(CC)-8(3), MUMBAI vs. JSW ENERGY LIMITED, MUMBAI

In the result the appeals filed by the revenue for assessment\nyears under consideration stands partly allowed and cross\nappeals filed by the assessee stands dismissed

price at which the consumers were\nable to procure the power. Had the assessee not been saddled with\nrestrictions of supplying surplus power to the State Electricity Board, it\nwould have supplied power to the ultimate consumers at rates similar to\nthose of the Board or such other competitive rates, meaning thereby that\nprice received by the assessee would

ACIT CC-6(1), MUMBAI, BKC, MUMBAI vs. PRISM JOHNSON LIMITED , MUMBAI

In the result, appeal of the revenue is dismissed

80A(6) of the Act is clear that open\nmarket has to be presumed in existence for the purpose of computing a\ndeduction u/s 80IA and market value has to be taken as if such open\nmarket exists. The ld. CIT(A) was also convinced with the savings\napproach drawing support from various judicial decisions, namely, CIT\n-vs.- Thiagarajar

ASST CIT (LTU) 1, MUMBAI vs. GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the International Transaction the assessee is having with its Associated Enterprises (AE). The TPO passed an under section 92CA of the Act dated 09.01.2015 computing a TP Adjustment towards performance guarantee at Rs. 5,26,17,801/-. The AO passed an assessment order under section 143(3) r.w.s

GRASIM INDUSTRIES LIMITED (AS A SUCCESSOR TO ADITYA BIRLA NUVO LTD),MUMBAI vs. ADDL CIT LTU, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy, Jm & Ms Padmavathy S, Am

Transfer Pricing Officer (TPO) to determine the Arms Length Price (ALP) of the International Transaction the assessee is having with its Associated Enterprises (AE). The TPO passed an under section 92CA of the Act dated 09.01.2015 computing a TP Adjustment towards performance guarantee at Rs. 5,26,17,801/-. The AO passed an assessment order under section 143(3) r.w.s

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring the appeal before the Ld. CIT(A) and accordingly, the final assessment order u/s 144(C)(13) was 4 I.T.A. No. 4935/Mum/2024 I.T.A. No. 4933/Mum/2024 I.T.A. No. 4931/Mum/2024 passed on 29/04/2021 by incorporating

ASSISSTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring the appeal before the Ld. CIT(A) and accordingly, the final assessment order u/s 144(C)(13) was 4 I.T.A. No. 4935/Mum/2024 I.T.A. No. 4933/Mum/2024 I.T.A. No. 4931/Mum/2024 passed on 29/04/2021 by incorporating

ASSISTANT COMMISSIONER OF INCOME TAX, MUMBAI vs. ASR MULTIMETALS PRIVATE LIMITED, MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

transfer pricing order was received by the AO and the draft assessment order was issued to the assessee. The assessee intimated the Ld. AO of preferring the appeal before the Ld. CIT(A) and accordingly, the final assessment order u/s 144(C)(13) was 4 I.T.A. No. 4935/Mum/2024 I.T.A. No. 4933/Mum/2024 I.T.A. No. 4931/Mum/2024 passed on 29/04/2021 by incorporating

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

ACC LTD.,MUMBAI vs. DCIT(LTU) - 1, MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

DCIT(LTU) - 1, MUMBAI vs. ACC LTD., MUMBAI

In the result, appeal filed by assessee is partly allowed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

price, made a reference to the DVO under Section 142A. The DVO estimated the market value of the property at an amount which was much higher than the amount shown in the document. The Assessing Officer added the difference between the two figures as undisclosed investment. It was in this background that this Court held that the report

ACIT, CIRCLE-6(1)(2), MUMBAI, MUMBAI vs. ASR MULTIMETALS PVT. LTD., MUMBAI

In the result, appeals for all the assessment years filed by the revenue stand dismissed

Bench: Shri Pawan Singh & Shri Girish Agrawal(Hybrid Hearing) Assistant Commissioner Of Asr Multimetals Pvt. Ltd. Income Tax 6(1)(2), Mumbai Vs 202, Steel Center, Iron Market, Room No. 506, 5Th Floor, Mumbai – 400009. Aayakar Bhavan, M. K. Road, Mumbai – 400020. [Pan No. Aaeca9439L] Appellant / Revenue Respondent / Assessee Assessee By Shri Sunil Talathi, Ca (Virtually Present) Revenue By Shri Bhagirath Ramawat (Sr. Dr) Date Of Hearing 11.03.2026 Date Of Pronouncement 11.03.2026

price. As against the same, the assessee does not perform any function relating to distribution, nor does it assume any risk connected with distribution. ASR Multimetals Pvt. Ltd. b) TPO called the information under Section 133(6) of the IT Act, 1961 and adopted external CUP by using the rates at which state power distribution companies had purchased power from