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1,350 results for “transfer pricing”+ Section 83clear

Sorted by relevance

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Key Topics

Section 143(3)81Addition to Income65Section 115J59Section 14A58Disallowance45Section 80I30Section 26328Deduction28Transfer Pricing22

FIRMENICH AROMATICS (INDIA) P. LTD,MUMBAI vs. DCIT 9(3)(1), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 2590/MUM/2017[2012-13]Status: DisposedITAT Mumbai23 Jul 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri Dhanesh Bafnaa/wFor Respondent: Shri Jayant Kumar
Section 143(3)Section 144C(13)

section 37(1) of the Act. Further, he observed, considering that the assessee might be getting some technical inputs to run his manufacturing plant, the assessee would be required to pay 10% of the royalty which was paid during the year. Therefore, he determined the arm's length price of the royalty payment for availing technical knowhow

ACCENTURE SERVICES P.LTD,MUMBAI vs. ADDL CIT RG 3(1), MUMBAI

In the result, assessee’s appeal is partly allowed

Showing 1–20 of 1,350 · Page 1 of 68

...
Section 145A19
Section 25018
Section 143(2)16
ITA 7686/MUM/2012[2008-09]Status: DisposedITAT Mumbai20 Jul 2018AY 2008-09

Bench: Shri Saktijit Dey & Shri Rajesh Kumar

For Appellant: Shri P.J. Pardiwallaa/wFor Respondent: Shri Saurabh Deshpande
Section 10ASection 143(3)Section 154Section 92C

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

ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, appeal is partly allowed

ITA 1671/MUM/2014[2009-10]Status: DisposedITAT Mumbai28 Jun 2019AY 2009-10

Bench: Shri Saktijit Deyand Shri N.K. Pradhan

For Appellant: Shri P.J. Pardiwalaa/w Shri Hiten ChandeFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

83,831, was treated as upward adjustment to the arm's length price shown by the assessee. On the basis of transfer pricing adjustment suggested by the Transfer Pricing Officer, the Assessing Officer made the addition while framing the draft assessment order. The assessee raised objections against the draft assessment order before learned DRP. 6. After considering the submissions

DCIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2815/MUM/2015[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3267/MUM/2012[2007-08]Status: DisposedITAT Mumbai29 Aug 2022AY 2007-08

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3597/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

DCIT CENT. CIR. 5(2), MUMBAI vs. IPCA LABORATORIES LTD., MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 5227/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

ACIT CEN CIR 13, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 7511/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. ASST CIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 2493/MUM/2015[2008-09]Status: DisposedITAT Mumbai29 Aug 2022AY 2008-09

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8084/MUM/2010[2006-07]Status: DisposedITAT Mumbai29 Aug 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

ASST CIT (LTU) 1, MUMBAI vs. IPCA LABORATORIES LTD, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3691/MUM/2016[2009-10]Status: DisposedITAT Mumbai29 Aug 2022AY 2009-10

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. ACIT (LTU), MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 8120/MUM/2010[2005-06]Status: DisposedITAT Mumbai29 Aug 2022AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

IPCA LABORATORIES LTD,MUMBAI vs. DCIT LTU, MUMBAI

In the result, appeal filed by the learned assessing officer is dismissed

ITA 3811/MUM/2016[2010-11]Status: DisposedITAT Mumbai29 Aug 2022AY 2010-11

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri F.V. Irani, ARFor Respondent: Shri Sumit Kumar, DR
Section 801BSection 801CSection 80ISection 92C

83,300/-. During the course of assessment proceedings, it was found that assessee has entered into international transactions and therefore, such transactions were referred to the learned Transfer Pricing Officer for determining Arms Length Price. The learned Transfer Pricing Officer found that assessee has exported pharmaceutical products to National Drugs (Pty) Ltd. It considered the CUP as the most appropriate

J.P MORGAN ADVISORS INDIA P.LTD,MUMBAI vs. DCIT RG 3(2), MUMBAI

In the result, appeal is partly allowed

ITA 990/MUM/2014[2009-10]Status: DisposedITAT Mumbai19 Jun 2019AY 2009-10

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Madhur AgrawalFor Respondent: Shri Anand Mohan
Section 143(3)Section 144C(13)

83. The learned Departmental Representative relied upon the observations of the Transfer Pricing Officer and learned DRP. 84. We have considered rival submissions and perused the material on record. On a perusal of the annual report of the company, we find the aforesaid submissions of the learned Authorised Representative acceptable. While deciding the comparability of this company in case

JSW ENERGY LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (TRANSFER PRICING) 2(3)(1), MUMBAI

In the result, the appeal is allowed

ITA 1223/MUM/2019[2014-15]Status: DisposedITAT Mumbai12 Aug 2022AY 2014-15

Bench: Us Is A Public Company Engaged In The Business Of Generation Of Power & Operation & Maintenance Of The Power Plants, As Also Other Allied Activities. During The Course Of Its Assessment Proceedings, The Assessing Officer Made A Reference Under Section 92Ca(1), For Determination Of The Arm‟S Length Price Of The International Transactions & Specified Domestic Transaction Entered Into By The Assessee With Its Associated Enterprises (Aes), To The Deputy Commissioner Of Income Tax, Assessment Year 2014-15 Page 2 Of 17

Section 271GSection 92CSection 92D

Transfer Pricing Study Report/Documentation prescribed under Rule 10D(1) of Rule 10D(2A) in the case of an assessee having eligible specified domestic transaction referred to in Rule 10THB: and (iii) copies of all agreements entered into by your with your Associated Enterprises till date. Clearly, therefore, the notice, termed as notice under section 92D(3), requisitions information other than

VIACOM 18 MEDIA P.LTD,MUMBAI vs. ADDL CIT 11(1), MUMBAI

In the result, assessee‟s appeal for A

ITA 8754/MUM/2010[2006-07]Status: DisposedITAT Mumbai03 Sept 2021AY 2006-07

Bench: Shri C.N. Prasad & Shri S. Rifaur Rahman

transfer pricing adjustment relating to mark–up on reimbursement of expenses at ` 21,99,60,689. 36 Viacom 18 Media Pvt. Ltd. 80. Having heard both the parties and having perused the material on record, we find that related facts and circumstances of the issue raised by the Revenue is mutatis mutandis and materially identical to the issue decided

M/S. INDIA MEDTRONICS PVT.LTD.,,BARODA vs. THE DY.CIT.,CIRCLE-1(2),, BARODA

In the result, similarly the Assessee’s appeal is partly allowed

ITA 480/AHD/2011[2005-06]Status: DisposedITAT Mumbai30 Sept 2022AY 2005-06

Bench: Shri Amit Shukla & Shri Gagan Goyal

For Appellant: Sh. Rajan R. Vora with Sh. Nikhil TiwariFor Respondent: Dr. Yogesh Kamath/ Akhtar Hussain Ansari
Section 234BSection 271Section 274Section 92C

Transfer Pricing Officer to delete the addition on account of excessive purchase price as it is already benchmarked once under TNMM/RPM, as under 69. However, learned Commissioner (Appeals), inadvertently dismissed the ground, whereas it was to be allowed following DRP direction. Hence, the based on the above order, adjustment on account of excessive purchase price amounting

THE ACIT RG 10(1), MUMBAI vs. M/S. NETAFIM IRRIGATION INDIA P. LTD, MUMBAI

In the result, appeals are dismissed

ITA 3668/MUM/2008[2003-2004]Status: DisposedITAT Mumbai25 Apr 2019AY 2003-2004

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

For Appellant: Shri K.K. VedFor Respondent: Shri Manish Kumar Singh

sections 92(1) & 92C(1) of the Act as well as rule 10B(1) of the Rules and certain OECD guidelines, the learned Departmental Representative submitted, each international transaction should be benchmarked independently. Further, he submitted, for benchmarking the arm's length price RBI/SIA approval cannot be considered as a CUP as it is not provided under rule

NESS TECHNOLOGIES (INDIA) P. LTD,MUMBAI vs. DCIT CEN CIR 6(1), MUMBAI

In the result, whereas the appeal of the assessee is partly allowed, that of the Revenue is dismissed

ITA 696/MUM/2016[2011-12]Status: DisposedITAT Mumbai11 Nov 2016AY 2011-12

Bench: Shri G.S.Pannu & Shri Ravish Soodness Technologies (India) Private Ltd., Unit 501, Interface, New Link Road, Malad (West) Mumbai 400 064. Pan:Aaaca 9649L ...... Appellant Vs. The Dcit, Central Circle -6(1), Air India Building, 19Th Floor, Nariman Point, Mumbai 400 020 .... Respondent It(Tp)A No. 1006/Mum/2016 (Assessment Year 2011-12) The Dcit, Central Circle -6(1), Mumbai 400 020 ... Appellant Vs. Ness Technologies (India) Private Ltd., Mumbai. Assessee By : S/Shri M.P.Lohia /Nikhil Tiwari Revenue By : Shri Debashish Chand Date Of Hearing : 23/08 /2016 Date Of Pronouncement : 11/11/2016

For Appellant: S/Shri M.P.Lohia /Nikhil TiwariFor Respondent: Shri Debashish Chand
Section 143(3)Section 92C

83,706 instead of Rs 5,14,69,706; Interest under Section 234C of the Act of Rs 53,67,503 26. erred in levying interest under Section 234C of the Act on assessed income without appreciating that the interest under section 234C is applicable on returned income; Penalty Proceedings 27. erred in initiating penalty proceedings under Section

DCIT RG 8(2), MUMBAI vs. INDIA MEDTRONIC P. LTD, BARODA

In the result, assessee’s appeal is partly allowed

ITA 4074/MUM/2012[2007-08]Status: DisposedITAT Mumbai16 Oct 2019AY 2007-08

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwal

For Appellant: Shri Rajan R. Vora a/wFor Respondent: Shri Jayant Kumar

transfer pricing study report which ranges from 0.52% to 21.65% of sales. Further, it was submitted, determination of arm's length price of AMP expenditure by applying the bright line test (BLT) is without any basis. 13. After considering the submissions of the assessee, the learned Commissioner (Appeals) finally concluded that by incurring the AMP expenditure, the assessee had promoted