MS IMSOFER MANUFACTURING INDIA PRIVATE LIMITED (NOW KNOWN AS FERRERO INDIA PRIVATE LIMITED),PUNE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1(1)– PUNE AND NATIONAL FACELESS ASSESSMENT CENTRE, DELHI, PUNE AND NFAC (DELHI)
In the result, the appeal filed by the assessee is partly allowed for statistical purposes
ITA 1316/PUN/2024[2012-13]Status: DisposedITAT Pune11 Mar 2025AY 2012-13
Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1316/Pun/2024 िनधा"रण वष" / Assessment Year : 2012-13 M/S. Imsofer Manufacturing Vs. Dcit, Circle-1(1), Pune. India Private Limited (Now Known As Ferrero India Private Limited), World Trade Center, 8Th Floor, Tower-3, Kharadi- 411014. Pan : Aabci6450N Appellant Respondent Assessee By : Shri Siddhesh Chaugule & Nagma Gupta Revenue By Shri Amol Khairnar : Date Of Hearing : 18.12.2024 Date Of Pronouncement : 11.03.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.04.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2012-13. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “General Grounds: 1. On The Facts & Circumstances Of The Case & In Law, The Hon. Cit(A) Has Erred In Passing Order Under Section 250 Of The Act I.E. Levying Penalty Of Inr 3,55,82,949/-. Legal Grounds:
For Appellant: Shri Siddhesh Chaugule &
Section 154Section 250Section 251Section 271(1)(c)Section 275(1)(A)
154 of the Act for reducing the TP adjustment on account of Manufacturing Segment
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to Rs.16,90,85,442/-. Accordingly, rectification order was passed on 1st Feb 2017 with reduced TP adjustment of Rs.18,94,51,272/-.
The Appellant filed an appeal to the CIT(A) against the order of TOP. After careful consideration, the Ld CIT(A) passed
