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1,778 results for “transfer pricing”+ Section 92(3)clear

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Key Topics

Section 143(3)81Addition to Income57Disallowance37Section 14A32Transfer Pricing28Section 153C16Deduction16Double Taxation/DTAA15Section 92C

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

3) of section 92D, the Assessing Officer or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two percent of the value of the international transaction or specified domestic transaction for each such failure. Assessment year 2014-15 Page 10 of 17 Information and documents to be kept and maintained under

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

Showing 1–20 of 1,778 · Page 1 of 89

...
14
Section 40A(2)14
Section 115J13
Section 69C11

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

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

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3) read with section 144C of the Act on 2nd February 2012. The learned Assessing Officer further made following addition; i. Assessee is claiming deduction in respect of expenditure on scientific and research on account of capital expenditure and Revenue expenditure. It claimed deduction under Section 35(2AB) of the Act at the rate of 150% on capital expenditure

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

3 of 29 8. The learned AO/TPO/DRP erred in holding that even if the Appellant's case is covered under the TTS, transfer pricing provisions under section 92

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

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)

3. 82. Objecting to the selection of this company, the learned Authorised Representative submitted, the company has re–aligned its investment advisory business with Everstone Investment Advisors Pvt. Ltd. w.e.f. 1st January 2010. He submitted, the company has operated only for nine months during the financial year 2009–10 which is evident from sharp drop in operational expenditure as well

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)

3) of the Act dated 31/10/2011 computing the arm's length price of the international transaction, which was in variance with the stated value of such transactions. Before the Transfer Pricing Officer, assessee pointed out that it was purchasing as well as producing in- house general entertainment programmes, current affairs and films for telecasting on its channels in India. After

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 adjustment of AMP expenses. According to the Assessing Officer/Transfer Pricing expenses. According to the Assessing Officer/Transfer Pricing expenses. According to the Assessing Officer/Transfer Pricing Officer, the AMP expenses incurred by the assessee for its own the AMP expenses incurred by the assessee for its own the AMP expenses incurred by the assessee for its own business made

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