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1,843 results for “transfer pricing”+ Section 92clear

Sorted by relevance

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Key Topics

Section 143(3)76Addition to Income52Disallowance35Section 14A34Transfer Pricing29Deduction20Double Taxation/DTAA17Section 4016Section 92C

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)

92 of the Act provides for computation of income arising from international transaction at arm's length price. Section 92C of the Act provides for determination of arm's length price of an international transaction by applying the most appropriate method having regard to the nature of transaction for class of transaction or functions performed, etc. The most appropriate method

GOLDMAN SACHS (INDIA) SECURITIES PVT LTD,MUMBAI vs. ADDL.C.I.T. RG.3(1), MUMBAI

In the result, appeal stands partly allowed

Showing 1–20 of 1,843 · Page 1 of 93

...
16
Section 25015
Section 40A(2)14
Section 19512
ITA 6912/MUM/2012[2008-09]Status: DisposedITAT Mumbai22 Jul 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ashwani Taneja

For Appellant: Shri P.J. Pardiwala, Sr. CounselFor Respondent: Shri N.K. Chand
Section 143(3)Section 144C(13)Section 92C(2)

92,530. In the course of assessment proceedings, the Assessing Officer noticing that assessee has entered into international transactions with its A.E. made a reference to the Transfer Pricing Officer (Transfer Pricing Officer) for determining the arm's length price (arm's length price). In the course of proceedings before him, the Transfer Pricing Officer after verifying the records noticed

VAN OORD INDIA P.LTD,MUMBAI vs. DCIT RG 5(3), MUMBAI

In the result, the appeal of the assessee is treated as partly allowed for statistical purposes

ITA 720/MUM/2015[2010-11]Status: DisposedITAT Mumbai11 Nov 2019AY 2010-11

Bench: Shri. A. D. Jain & Shri Rajesh Kumar

For Appellant: S/Shri Nishant Thakkar, RishiFor Respondent: Shri Rajeev Harit, D.R
Section 115VSection 143(3)Section 144C(13)Section 28Section 43CSection 92Section 92(1)Section 92CSection 92C(4)Section 92E

pricing provisions begin from section 92 and end with 92F. They are contained in chapter X in the special provisions relating to avoidance of tax. As such, it is not correct to interpret that the scheme of Tonnage Tax will override the provisions of section 92 to 90 2F The fact that they are special provisions (Transfer

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)

Transfer Pricing Officer, we do not intend to deal with the acceptability or otherwise of the rest of the comparables disputed before us under ITES segment and leave the issue relating to comparability of these comparables open for adjudication if they arise in any other assessment year in future. 84. Ground no.7, of this appeal is identical to ground no.6

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

In the result, the appeal filed by the assessee is partly allowed

ITA 6081/MUM/2018[2014-15]Status: DisposedITAT Mumbai07 Jun 2019AY 2014-15

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

Section 143(3)Section 144C(5)

92 of the Act provides for computation of income arising from international transaction at arm's length price. Section 92C of the Act provides for determination of arm's length price of an international transaction by applying the most appropriate method having regard to the nature of transaction for class of transaction or functions performed, etc. The most appropriate method

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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

Transfer Pricing Officer rejected the contention of the assessee and computed the interest on the advance given to subsidiaries in Mauritius, USA and Brazil. He adopted that this Associated Enterprises’ will be categorized in the BB category for which rate of interest is 14.39% and accordingly, adjustment on account of non-charging of interest on advances to Associated Enterprises

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)

Pricing Study. As per the Revenue, since the said concern has been adopted by the assessee as a comparable, it is impermissible for the assessee to raise a plea asking for its exclusion in the process of determination of average margins under the TNM method. In our considered opinion, the proposition being canvassed by the Revenue is not absolute

DY.CIT 7(1) (1) , MUMBAI vs. M/S. MATTEL TOYS (INDIA) PVT. LTD, MUMBAI

In the result, the appeal of the Revenue is dismissed, whereas,

ITA 2304/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 Dec 2022AY 2012-13

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2012-13 Dy. Cit, Circle-7(1)(1), M/S Mattel Toys (India) Pvt. Ltd., Room No. 126, 1St Floor, Phoenix House, B-Wing, 4Th Floor, Vs. Aayakar Bhavan, M.K. Road, 462, Senapati Bapat Marg, Lower Mumbai-400020. Parel, Mumbai-400013. Pan No. Aaccm 2563 P Appellant Respondent

For Respondent: Assessee by Mr. Ketan Ved, AR

transfer pricing pricing pricing adjustment adjustment adjustment envisages the substitution of the price of such envisages the substitution of the price of such envisages the substitution of the price of such international transaction with the ALP. international transaction with the ALP. M/s Mattel Toys (India) Pvt. Ltd. M/s Mattel Toys (India) Pvt. Ltd. 12 ITA No. 2304/M/2021 & CO No. 124/M/2022

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

ITA 3406/MUM/2014[2008-09]Status: DisposedITAT Mumbai05 May 2017AY 2008-09

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

For Appellant: Shri Vijay MehtaFor Respondent: S/Shri N.K.Chand &
Section 143(3)

Transfer Pricing Officer was justified in selecting the RPM as most appropriate method. Section 92(1) of the Act provides

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

92 provides that any income arising from an international transaction shall be computed having regard to the arm's length price, sub-section (3) provides that : 'The provisions of this section shall not apply in a case where the computation of income under sub-section (1) or the determination of the allowance for any expense or interest under that

SOLAR TURBINES INDIA P.LTD,MUMBAI vs. DCIT 15(3)(2), MUMBAI

In the result, assessee’s appeal is partly allowed

ITA 1075/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2017AY 2011-12

Bench: Shri Rajendra & Shri Saktijit Deyआयकर अपीऱ सं. / Ita No. 1075/Mum./2016 (निर्धारण वषा / Assessment Year : 2011–12) Solar Turbines India Pvt. Ltd. (Formerly Known As Turbomach India P. Ltd.), 401, 402, 403, 4Th Floor ……………. Appellant Powai Plaza, Hiranandani Business Park Powai, Mumbai 400 076 Pan – Aabct7422R V/S Dy. Commissioner Of Income Tax Circle–15(3)(2), Aayakar Bhawan ……………. Respondent 101, M.K. Road, Mumbai 400 020 निर्धाररती की ओर से / Assessee By : Shri Arvind Sonde A/W Shri Ketan Ved रधजस्व की ओर से / Revenue By : Shri N.K. Chand सुिवधई की तधरीख / आदेश घोषणध की तधरीख / Date Of Hearing – 05.10.2016 Date Of Order – 02.01.2017 आदेश / Order शक्तिजीि दे, न्याययक सदस्य के द्वारा / Per Saktijit Dey, J.M.

For Appellant: Shri Arvind Sonde a/wFor Respondent: Shri N.K. Chand
Section 133(6)Section 143(3)Section 234ASection 271(1)(c)

transfer pricing provisions. He submitted, for applying Chapter–10 arising of income is sin qua non. He submitted, section 92