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3,045 results for “transfer pricing”+ Set Off of Lossesclear

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Key Topics

Section 143(3)56Addition to Income53Disallowance51Section 14A40Section 115J34Transfer Pricing31Deduction28Section 25016Section 6813

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

In the result, assessee’s appeal is partly allowed

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

set of comparables selected by the Transfer Pricing Officer consisted of 18 companies having average arithmetic mean of 31.36% as against assessee’s margin of 15.26%, which resulted in an upward adjustment of the arm's length price amounting to `178,10,59,529. On the basis of the adjustment made by the Transfer Pricing Officer the Assessing Officer framed

Showing 1–20 of 3,045 · Page 1 of 153

...
Section 92C13
Section 4013
Depreciation13

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)

loss of ` 6,12,59,849. During the assessment proceedings, the Assessing Officer noticing that the assessee has entered into international transaction with its A.E. made a reference to the Transfer Pricing Officer to determine the arm's length price of the international transactions. During the proceedings before him, the Transfer Pricing Officer found that in the transfer pricing study

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)

transfer pricing adjustment to the extent of Rs. 42,181,115 for the international transaction pertaining to provision of Information Technology enabled services to its AE and in re-computing the arm's length price under the Transactional Net Margin Method, inter alia, on following grounds: i. Rejecting the functional analysis, search process adopted and documentation maintained by the Appellant

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)

set–up and management, consulting service, architecture, configuration and installation, etc. Many of such services are in the nature of KPO services. Further, though, the company has earned revenue from various services provided by it, however, the segmental details are not available. In fact, the Transfer Pricing Officer himself has admitted that the Profit & Loss

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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

set of products traded as a whole or have their commercial application connected to each other or commercial proximity of the products in old in the basket such as prices or market is shown or in case the same are traded together. 024. However, it is important that basket of product must have greater rational to show that

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)

set of facts and circumstances, therefore, as a matter of convenience, these appeals were heard together and are being disposed of by way of this consolidated order. ITA no.990/Mum./2014 Assessee’s Appeal – A.Y. 2009–10 3. In ground no.1, the assessee has challenged the addition of ` 42,14,72,098, on account of transfer pricing adjustment relating

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 is based on the fees charged by the banks. Quite clearly, the aforesaid approach of the income-tax authorities is inconsistent with the judgment of the Hon'ble Bombay High Court in the case of Everest Kanto Cylinders Ltd.(supra). As per Hon'ble Bombay High Court, the instance of a commercial bank issuing bank guarantee

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 Officer while conducting its bench marking analysis, had excluded certain comparable (sr no 18 to 25) on account of they being loss making companies. In this regard, he submitted that only consistent loss-making companies should be excluded from benchmarking set

PUBLICS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 6(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 7523/MUM/2016[2010-11]Status: DisposedITAT Mumbai27 Apr 2023AY 2010-11

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

sets need to match the ever changing demand for professionals. Failure to do so would result in a loss of revenue and clients. 4.3.5 Cost Overrun Risk Some of the services contracts are on fixed-price basis. Any cost failure to estimate accurately the resources and time required for a project, future rates of wage inflation and currency exchange rates

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 1994/MUM/2014[2009-10]Status: DisposedITAT Mumbai27 Apr 2023AY 2009-10

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

sets need to match the ever changing demand for professionals. Failure to do so would result in a loss of revenue and clients. 4.3.5 Cost Overrun Risk Some of the services contracts are on fixed-price basis. Any cost failure to estimate accurately the resources and time required for a project, future rates of wage inflation and currency exchange rates

PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

ITA 462/MUM/2016[2011-12]Status: DisposedITAT Mumbai27 Apr 2023AY 2011-12

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

For Appellant: Shri Ketan VedFor Respondent: Shri Asif Karmali
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)(ii)Section 92C

sets need to match the ever changing demand for professionals. Failure to do so would result in a loss of revenue and clients. 4.3.5 Cost Overrun Risk Some of the services contracts are on fixed-price basis. Any cost failure to estimate accurately the resources and time required for a project, future rates of wage inflation and currency exchange rates