GROWMORE RESEARCH AND ASSETS MANAGEMENT ,MUMBAI vs. DCIT, CC-4(1) (ERSTWHILE DCIT-31, MUMBAI

In the result, both the appeals are treated as partly allowed

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

price as on 31-03-1992. Hence, we are of the view that there may be error in mentioning the name of the company. Since no detail was produced by the revenue also, we deem it proper to restore this addition to the file of the AO with the direction to furnish the material relating to the addition

LANXES INDIA P.LTD,THANE vs. ASST CIT CIR 1, THANE

In the result, both the appeals are treated as partly allowed

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjee

price as on 31-03-1992. Hence, we are of the view that there may be error in mentioning the name of the company. Since no detail was produced by the revenue also, we deem it proper to restore this addition to the file of the AO with the direction to furnish the material relating to the addition

DY. COMMISSIONER OF INCOME TAX, CC-4(3) CENTRAL RANGE-4 , MUMBAI vs. M/S GROWMORE RESEARCH AND ASSETS MANAGEMENT LIMITED, MUMBAI

In the result, both the appeals are treated as partly allowed

unexplained investment u/s.69 of the Act.\n\n19. 2. Before the Ld.CIT(A), the assessee contended thatthe AO has not given details of shares, viz., the name of the holders, the place wherefrom they were seized etc. It also submitted that the AO did not allow inspection of the shares seized by the department. It submitted that the registered shares

KANTAR ANALYTICS INDIA PRIVATE LIMITED (FORMERLY KNOWN AS FIREFLY MARKET RESERCH INDIA PRIVATE LIMITED (SUCCESSOR OF ANALYTICS QUOTIENT SERVICE INDIA PRIVATE LIMITED),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1(3)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

investment or to facilitate compliance with\nreporting, legal, or regulatory requirements of the ultimate parent or;\nb) May be duplicative in nature or otherwise do not constitute a benefit\n7.4\nAllocation methodology\nThe service fee is arrived at based on AQ India's share of total net sales achieved relative to\nworldwide net sales in that calendar year.\nMark

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

DCIT CC 3(4) CEN RG 3, MUMBAI vs. PATEL ENGINEERING LTD, MUMBAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon’Ble

price and the book value of share, this ground is similar to Ground No. 4 of grounds of appeal raised by the revenue for the A.Y. 2006-07 and the decision taken therein shall apply mutatis-mutandis to the appeal for the A.Y. 2007-08. We order accordingly. 42. With regard to Ground No. 8 which is in respect

INCOME TAX OFFICER 11(2)(1), MUMBAI vs. SATGURU CORPORATE SERVICES PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

unexplained investment amounting to Rs.50,00,45,000/-. The . The material facts qua the issue in dispute are facts qua the issue in dispute are that the assessee company purchased 20,000 equity share, which that the assessee company purchased 20,000 equity share that the assessee company purchased 20,000 equity share is 100% shareholding of M/s Somani

SATGURU CORPORATE SERVICES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER 11(1)(3), MUMBAI

In the result, the appeal of the Revenue

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale () Assessment Year: 2012-13 M/S Satguru Corporate Services Ito, 11(1)(3), Pvt. Ltd., Aayakar Bhavan, 4Th Vs. 5Th Floor, Sunteck Centre, 37-40 Floor, Mumbai. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent Assessment Year: 2012-13 Ito, 11(1)(3), M/S Satguru Corporate Services Pvt. Room No. 201, Aayakar Ltd., Vs. Bhavan, M.K. Marg, 5Th Floor, Sunteck Centre, 37-40 Mumbai-400020. Subhash Road, Vile Parle (East), Mumbai-400057. Pan No. Aapcs 2160 R Appellant Respondent

unexplained investment amounting to Rs.50,00,45,000/-. The . The material facts qua the issue in dispute are facts qua the issue in dispute are that the assessee company purchased 20,000 equity share, which that the assessee company purchased 20,000 equity share that the assessee company purchased 20,000 equity share is 100% shareholding of M/s Somani

L & T TECHNOLOGY SERVICES LIMITED,MUMBAI vs. ACIT CIRCLE 2(2)(1), MUMBAI

In the result, appeal filed by the assessee is allowed for statistical purpose

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blel & T Technology Services Limited V. Acit – Circle – 2(2)(1) L & T House, N.M. Marg Room No. 545, 5Th Floor Mumbai - 400001 Aaykar Bhavan, M.K. Road Mumbai - 400020 Pan: Aaccl4310P (Appellant) (Respondent) Assessee Represented By : Shri Nitesh Joshi Department Represented By : Shri Manoj Kumar

TRANSFER PRICING ISSUES 2. The Assessing Officer erred in adding the premia income on forward contracts to the total income of the Appellant without appreciating the fact that the premia income had already been offered to tax in the earlier years. 3. Without prejudice to Ground No.2, the Assessing Officer erred in adding an amount of Rs.49

ELVIS ZEPHERIN CRASTO ,MUMBAI vs. INCOME TAX OFFICER, INT TAX WARD 2(1), MUMBAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bleelvis Zepherin Crasto V. Income Tax Officer Gorai Village, Jui Pada International Taxation Gorai Essel World Road Ward – 2(1)(1) Borivali (W), Mumbai - 400091 Room No. 1724, 17Th Floor Air India Building Nariman Point, Mumbai – 400 021 Pan: Asgpc6280N (Appellant) (Respondent)

unexplained investment u/s 69 without any cogent evidence. 8. After considering the above submissions of the assessee, Ld. DRP briefly narrated the various arguments raised by the assessee vide letter dated 27.02.2021, for the sake of clarity it is reproduced below: - “The Assessee had submitted following arguments vide his letter dated 27.02.2021. the same are narrated below: 1. The said

PFS SHIPPING (I) LIMITED,MUMBAI vs. DCIT CC 1(2), MUMBAI

In the result, the appeal preferred by the Assessee [ITA No

unexplained cash credit on assumptions and surmises, without appreciating that- i) Out of the loan amount of Rs.53,19,90,430/-, Rs. 20.40 Crs. was directly received form OOSPL, Rs. 19.19 Crs. and Rs. 13.58 Crs. was received respectively from PRP International, and Nissim Traders Pvt. Ltd., on behalf of OOSPL. ii) OOSPL is assessed to income tax with

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(4), MUMBAI vs. SHRI NARENDRA GEHLAUT, MUMBAI

In the result, the appeal filed by the Revenue is partly allowed e appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2017-18 The Dy. Cit, Central Circle-6(4), Shri Narendra Gehlaut, Room No. 1925, 19Th Floor, Air 875, Sector – 17B, Gurgaon, India Building, Nariman Point, Vs. Haryana, 122 001. Mumbai-400021. Pan No. Aazpg 9630 K Appellant Respondent

price paid by the Government, the cost of the asset will be the price paid by the Government, the cost of the asset will be the price paid by the assessee for acquiring the asset. assessee for acquiring the asset. In the instant case, the allegation is In the instant case, the allegation is that at the time of Commissioner

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate

DCIT CC 8(3), MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate

DCIT CC 8(3)(ERSTWHILE DCIT,CC-46, MUMBAI vs. JSW STEELS LTD, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate

JSW STEEL LIMITED,MUMBAI vs. ACIT,CC-46, MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate

JSW STEELS LTD,MUMBAI vs. DCIT CC 8(3), MUMBAI

Appeal of the revenue is partly allowed and appeal of the assessee is dismissed

unexplained expenditure.” 7. “On the facts and the circumstances of the case and in law, the Hon'ble CIT(A) erred in not sharing with Appellant the copies of relevant correspondences and documents and not allowing the Appellant to cross- examine the persons whose views were relied upon by Hon'ble Assessing Officer in the impugned assessment order to substantiate