COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

92 CA (3) as "any time before 60 days prior to the date on which the period of limitation referred to in section 153, expires." According to the provisions of section 153 (1) read with section 153 (4), the time limit for passing of the order under section 153 is available up to 31/3/2015. Thus the time limit for passing

COLGATE PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

92 CA (3) as "any time before 60 days prior to the date on which the period of limitation referred to in section 153, expires." According to the provisions of section 153 (1) read with section 153 (4), the time limit for passing of the order under section 153 is available up to 31/3/2015. Thus the time limit for passing

COLGATE -PALMOLIVE (INDIA) LTD,MUMBAI vs. ASST CIT CIR 15(1)(2), MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

92 CA (3) as "any time before 60 days prior to the date on which the period of limitation referred to in section 153, expires." According to the provisions of section 153 (1) read with section 153 (4), the time limit for passing of the order under section 153 is available up to 31/3/2015. Thus the time limit for passing

DCIT 15(1)(2), MUMBAI vs. COLGATE PALMOLIVE (INDIA) LTD., MUMBAI

Accordingly, number 75/M/2018 filed by the assessee for assessment year 2013 – 14 is allowed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

92 CA (3) as "any time before 60 days prior to the date on which the period of limitation referred to in section 153, expires." According to the provisions of section 153 (1) read with section 153 (4), the time limit for passing of the order under section 153 is available up to 31/3/2015. Thus the time limit for passing

SHAPOORJI PALLONJI AND COMPANY PVT LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE 8(3), MUMBAI

Appeals are partly allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

3) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’]. 2.1. The Assessee has raised following grounds of appeal in ITA No.1149/Mum/2025 [Assessment Year 2013-2014] : "Ground 1: Erroneous transfer pricing adjustment sustained by the Commissioner of Income-tax [Appeals] 1.1 The learned Commissioner of Income-tax (Appeals)-58 erred, both in law and on the facts

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

3) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’]. 2.1. The Assessee has raised following grounds of appeal in ITA No.1149/Mum/2025 [Assessment Year 2013-2014] : "Ground 1: Erroneous transfer pricing adjustment sustained by the Commissioner of Income-tax [Appeals] 1.1 The learned Commissioner of Income-tax (Appeals)-58 erred, both in law and on the facts

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONI AND COMPANY PRIVATE LIMITED, MUMBAI

3) of the Income Tax Act,\n1961 [hereinafter referred to as `the Act'].\n2.1.\nThe Assessee has raised following grounds of appeal in ITA\nNo.1149/Mum/2025 [Assessment Year 2013-2014]:\n\"Ground 1: Erroneous transfer pricing adjustment sustained by the\nCommissioner of Income-tax [Appeals]\n1.1 The learned Commissioner of Income-tax (Appeals)-58 erred,\nboth

DCIT(CC)-8(3), MUMBAI vs. SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED, MUMBAI

3) of the Income Tax Act,\n1961 [hereinafter referred to as `the Act'].\n2.1.\nThe Assessee has raised following grounds of appeal in ITA\nNo.1149/Mum/2025 [Assessment Year 2013-2014]:\n\"Ground 1: Erroneous transfer pricing adjustment sustained by the\nCommissioner of Income-tax [Appeals]\n1.1 The learned Commissioner of Income-tax (Appeals)-58 erred,\nboth

INDIA MEDTRONIC P LTD,MUMBAI vs. ADDL/JT/DY/ASSTT/CIT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, appeal of the assessee is allowed on legal ground

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRASHANT MAHARISHI (Accountant Member)

transfer pricing adjustment / additions/disallowances. The ld. DRP has disposed off the objections, vide directions dated 23 March 2021 wherein certain relief was granted/ enhancement were made and certain adjustments were confirmed by the ld. DRP. 7. Based on the directions of the ld. DRP, the ld. AO issued the final assessment order dated 25 May 2021 under section 143(3

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

3) of section 92C and send a copy of his order to the Assessing Officer and to the assessee.  Section 92CA(4) of the Act states that on the receipt of the order, the AO shall proceed to compute the total income of the assessee according to section 92C(4) of the Act. On the perusal of the section

DCIT 1(1), MUMBAI vs. HSBC ASSET MANAGEMENT (I) P. LTD, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

transfer pricing adjustment of Rs. 1,21,92,637. In conformity, the AO passed the assessment order under section 143 r/w section 144C(3

HSBC ASSET MANAGEMENT (INDIA) P.LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

transfer pricing adjustment of Rs. 1,21,92,637. In conformity, the AO passed the assessment order under section 143 r/w section 144C(3

DCIT CIR 1, THANE vs. LAXCESS INDIA P.LTD, THANE

In the result, the appeal of the assessee

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

section 92CA(3) of the Act transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. TPO computed adjustment for Nagada plant at Rs.2

LANXESS INDIA P.LTD,THANE vs. DCIT CIR 1, THANE

In the result, the appeal of the assessee

Bench: Shri Om Prakash Kant () & Shri Kavitha Rajagopal () Assessment Year: 2011-12 Lanxess India Pvt. Ltd., Dy. Cit, Circle-1, Lanxess House, Plot No. Room No. 22, 6Th Floor, B A/162-164, Road No. 27, Vs. Wing Asher It Park, Road, Wagle Estate, Opp. Iti College, 16-Z, Wagle Industrial Midc, Thane (West)-400 604. Estate, Thane (West)-400604. Pan No. Aaccb 3880 A Appellant Respondent Assessment Year: 2011-12 Dy. Cit, Circle-1, Lanxess India Pvt. Ltd., Room No. 22, 6Th Floor, B Wing Lanxess House, Plot No. Asher It Park, Road, 16-Z, Vs. A/162-164, Road No. 27, Wagle Industrial Estate, Thane Wagle Estate, Opp. Iti (West)-400604. College, Midc, Thane (West)- 400 604. Pan No. Aaccb 3880 A Appellant Respondent

section 92CA(3) of the Act transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and transfer pricing adjustment to manufacturing segment and technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. technical support service. Under manufacturing segment, the Ld. TPO computed adjustment for Nagada plant at Rs.2

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

92,92C and section 92D of the I.T. Act and Rule 10C, Rule 10B(1), Rule 10B(2) and (3) and Rule 10D(g), and Rule 10C, Rule 10B(1), Rule 10B(2) and (3) and Rule 10D(g), and Rule 10C, Rule 10B(1), Rule 10B(2) and (3) and Rule

M/S. NATUREX INDIA PVT. LTD,MUMBAI vs. NFAC, DELHI DCIT-CIR 2(3) (1), MUMBAI

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

Bench: Shri Vikas Awasthy & Shri Gagan Goyalm/S. Naturex India Pvt. Ltd. 502, 5Th Floor, Akruti Centre Point, Midc Central Road, Andheri (East), Chakala Midc S.O. Mumbai-400093 Pan: Aabcv0883A ..... Appellant Vs. Nfac, Delhi/Dcit Cir. 2(3) (1) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

transfer price of the Appellant in respect of the payment of management service fee of INR 3, 01, 42,197/- to Associated Enterprises ('AEs'), holding that this international transaction does not satisfy the arm's length principle envisaged under the Act and in specific in doing so grossly erred in: 2.1 Disregarding the evidence placed on record by labelling them

ACIT CIRCLE 5(1)(1), MUMBAI vs. M/S ESSAR SHIPPING LIMITED, MUMBAI

In the result, appeal filed by the learned AO is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm M/S Essar Shipping Limited Acit, Circle 5(1)(1) Essar House, 11, R.No.568, Aaykar Bhavan, Vs. Kk Marg, Mahalaxmi, M.K. Road, Mumbai-400 020 Mumbai-400 034 (Appellant) (Respondent) Pan No. Aacce3707D

Transfer pricing adjustment to the International transaction of Rs 1,92,97,355/– was made by passing an order under section 92CA (3

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

transferred company, i.e., Tata Sons Ltd. He also pointed out to the difference in logo and trade mark as noted by ld. TPO in his order. It was thus, contended that brand of “Tata Consultancy Services” is owned by the assessee and not by Tata Sons Ltd. Thus, assessee has got its own brand value and has incorporated its valuation

MACROTECH DEVELOPERS LTD.(SUCCESSOR TO BELLISSIMO CROWN BUILDMART PVT LTD.,,MUMBAI vs. DCIT CENTRAL CIRCLE 7(3), MUMBAI

The appeal is allowed

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

Transfer Pricing- 3(2)(1), Mumbai, the Hon'ble Dispute Resolution Panel ('DRP') erred in: 1.1. not appreciating that explanation to section 92B of the Act as amended by Finance Act, 2012 does not alter the basic character of the definition of 'international transaction' u/s 928 and therefore, since provision of guarantee (by the assessee