REHAU POLYMERS PVT. LTD.,,PUNE vs. ASISTANT COMMISSIONER OF INCOME-TAX,,

In the result, appeal of the assessee is allowed

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm आयकर अपील सं. / Ita No. 519/Pun/2014 "नधा"रण वष" / Assessment Year : 2009-10

section 143(3) r.w.s 144C(13) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the assessment year 2009-10. 2. The brief facts of the case as emanating from the record are: The assessee company is engaged in the business of manufacturing, distribution and marketing of polymer products and providing technical, sales and other services

DEPUTY COMMISSIONER OF INCOME-TAX vs. EATON FLUID POWER LTD.,, PUNE

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

sections 234B and 234C of the Act.” 10. The ld. AR submitted that the primary grounds raised by the assessee in appeal is against transfer pricing adjustment in respect of international transactions pertaining to payments made to Associated Enterprises (AEs) for Corporate Support Services. The authorities below have erred in coming to the conclusion that the assessee has not received

EATON FLUID POWER LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

sections 234B and 234C of the Act.” 10. The ld. AR submitted that the primary grounds raised by the assessee in appeal is against transfer pricing adjustment in respect of international transactions pertaining to payments made to Associated Enterprises (AEs) for Corporate Support Services. The authorities below have erred in coming to the conclusion that the assessee has not received

EATON FLUID POWER LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

sections 234B and 234C of the Act.” 10. The ld. AR submitted that the primary grounds raised by the assessee in appeal is against transfer pricing adjustment in respect of international transactions pertaining to payments made to Associated Enterprises (AEs) for Corporate Support Services. The authorities below have erred in coming to the conclusion that the assessee has not received

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. EATON FLUID POWER LTD.,, PUNE

In the result, the appeal of Revenue for assessment year 2011-12 is dismissed being devoid of any merit

Bench: Shri Anil Chaturvedi, Am & Shri Vikas Awasthy, Jm

sections 234B and 234C of the Act.” 10. The ld. AR submitted that the primary grounds raised by the assessee in appeal is against transfer pricing adjustment in respect of international transactions pertaining to payments made to Associated Enterprises (AEs) for Corporate Support Services. The authorities below have erred in coming to the conclusion that the assessee has not received

M/S PERSISTENT SYSTEMS LIMITED,PUNE vs. ASSESSMENT UNIT, INCOME-TAX DEPARTMENT, PUNE

In the result, appeal of the Assessee is Partly Allowed

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.692/Pun/2022 िनधा"रणवष" / Assessment Year : 2018-19 M/S.Persistent Systems Assessment Unit, Income Limited, V Tax Department. “Bhageerath” 402, Senapati S Bapat Road, Pune – 411016. Pan: Aabcp 1209 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Dhanesh Bafna& Shriaditya Vaidya– Ar’S Revenue By Shri Suhas Kulkarni - Irs Addl Commissioner Of Income Tax Date Of Hearing 26/09/2023 Date Of Pronouncement 02/11/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Assessment Order, Dated 20.07.2022 Under Section 143(3) R.W.S. 144C(13) Read With Section 144B Of The Income Tax Act, 1961 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “Ground 1: Order Is Invalid / Non Est  On The Facts & In The Circumstances Of The Case & In Law, The Assessment Unit (‘Au’) Has Erred In Passing The Draft Assessment M/S.Persistent Systems Limited [A]

section 92C prescribes 6 methods by which this exercise can be done by adopting most appropriate method having regard to the nature of transaction or class of transactions or functions performed by the parties. In the present case the revenue as well as appellant both has agreed that transactional net margin method is the most appropriate method for determination

EATON TECHNOLOGIES PVT. LTD.,,PUNE vs. ACIT, CIRCLE 1(2),, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1650/Pun/2013 यििाारण वषा / Assessment Year :2008-09 Eaton Technologies Pvt. Ltd., Cluster C, Wing 1, Eon Free Zone, Plot No.1, Survey No.77, Midc, Kharadi Knowledge Park, अऩीऱाथी/Appellant Kharadi, Pune – 411014 …. Pan: Aabce4323Q Vs. The Asst. Commissioner Of Income Tax, …. प्रत्यथी / Respondent Circle 1(2), Pune

section 154 of the Act. 9. The assessee is in appeal against the order of CIT(A). 10. The learned Authorized Representative for the assessee pointed out that ground of appeal No.1 raised by assessee was general in nature. With regard to issue in ground of appeal No.2, the learned Authorized Representative for the assessee pointed out that

CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED ( SUCCESSOR OF ARICENT TECHNOLOGIES HOLDINGS LIMITED),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX - CIRCLE 1(1), PUNE

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

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2804/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Capgemini Technology V The Assistant Services India Limited[As S Commissioner Of Income Successor In Interest Of Tax-1(1)(1), Pune. Erstwhile Aricent Technologies (Holdings) Limited-Since Amalgamated], Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase-Iii, Midc Sez, Village Man, Taluka Mulshi, District- Pune – 411057. Maharashtra. Pan: Aacck8280B Appellant/ Assessee Respondent / Revenue Assessee By Shri Nikhil Pathak – Ar Revenue By Shri Prakash L Pathade –Cit(Dr) Date Of Hearing 19/06/2025 Date Of Pronouncement /06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Assessment Order Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 Dated 29.10.2024 For The A.Y.2021-22, Emanating From The

Transfer Pricing Officer has passed the order u/s.92CA(3) of the Act, on 29.10.2013 in the name of Aricent Technologies (Holdings) Limited. Ld.AR submitted that Aricent Technologies (Holdings) Limited merged with Capgemini Technology Services India Limited with an appointed date of 1st ITA No.2804/PUN/2024 [A] October, 2021. Ld.AR submitted that this fact was brought to the notice

KIMBERLY CLARK LEVER PVT. LTD.,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeal of assessee is allowed for statistical purposes and the appeal of Revenue is dismissed in the above terms

158 Total 29,35,78,230 5. The appellant in its TP study report has adopted a transaction level approach and benchmarked the transaction by selecting AEs as tested parties. It was claimed that the transaction of import of raw materials from its third parties is at arm's length price by demonstrating that the rates charged by the appellant

DEPUTY COMMISSIONER OF INCOME-TAX,, PUNE vs. M/S. KIMBERLY CLARK LEVER PVT. LTD.,, PUNE

In the result, appeal of assessee is allowed for statistical purposes and the appeal of Revenue is dismissed in the above terms

158 Total 29,35,78,230 5. The appellant in its TP study report has adopted a transaction level approach and benchmarked the transaction by selecting AEs as tested parties. It was claimed that the transaction of import of raw materials from its third parties is at arm's length price by demonstrating that the rates charged by the appellant

REHAU POLYMERS PVT.LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 8,, PUNE

Bench: Shri R. K. Panda & Shri Vinay Bhamore

158,603/-. He noted that during the year under consideration the assessee has paid the cost sharing charges to its various AEs, the details of which are as under: Sl. No. Name of AE Amount in INR 1 Rehau Pte. Ltd., Singapore 2,06,26,689 2 Rehau Polymers (Suzhou) Co. Ltd. 76,01,305 3 Rehau

DEPUTY COMMISSIONER OF INCOME-TAX vs. AMBER POINT TECHNOLOGY INDIA P. LTD.,,

In the result, appeals of assessee for both the years are partly allowed and appeals of Revenue in assessment year 2008-09 is partly allowed and in assessment year 2009-10 is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.756 & 757/Pun/2014 नििाारण वषा / Assessment Years : 2008-09 & 2009-10

158/-. The Assessing Officer made reference under section 92CA(1) of the Act to the Transfer Pricing Officer (TPO) to benchmark

M/S. AMBERPOINT TECHNOLOGY INDIA PVT. LTD.,,GURGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals of assessee for both the years are partly allowed and appeals of Revenue in assessment year 2008-09 is partly allowed and in assessment year 2009-10 is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.756 & 757/Pun/2014 नििाारण वषा / Assessment Years : 2008-09 & 2009-10

158/-. The Assessing Officer made reference under section 92CA(1) of the Act to the Transfer Pricing Officer (TPO) to benchmark

M/S. AMBERPOINT TECHNOLOGY INDIA PVT. LTD.,,GURGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX,,

In the result, appeals of assessee for both the years are partly allowed and appeals of Revenue in assessment year 2008-09 is partly allowed and in assessment year 2009-10 is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.756 & 757/Pun/2014 नििाारण वषा / Assessment Years : 2008-09 & 2009-10

158/-. The Assessing Officer made reference under section 92CA(1) of the Act to the Transfer Pricing Officer (TPO) to benchmark

DEPUTY COMMISSIONER OF INCOME-TAX vs. AMBER POINT TECHNOLOGY INDIA P. LTD.,,

In the result, appeals of assessee for both the years are partly allowed and appeals of Revenue in assessment year 2008-09 is partly allowed and in assessment year 2009-10 is dismissed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.756 & 757/Pun/2014 नििाारण वषा / Assessment Years : 2008-09 & 2009-10

158/-. The Assessing Officer made reference under section 92CA(1) of the Act to the Transfer Pricing Officer (TPO) to benchmark

DATTATRAY HANMANTRAO DESAI,KARAD vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal filed by the assessee is dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2018-19

158 (Chennai – Trib.) (viii) PCIT vs. Dharmesh Padamshibhai Patel (2023) 156 taxmann.com 491 (Guj) 17. He accordingly submitted that the order passed by the Ld. PCIT be set aside. 18. The Ld. DR on the other hand heavily relied on the order of the Ld. PCIT invoking the jurisdiction u/s 263 of the Act. He submitted that the case

JAIN IRRIGATION SYSTEMS LTD,,JALGAON vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2,, JALGAON

Appeal is partly allowed in above terms

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.227/Pun/2018 िनधा"रणवष" / Assessment Year : 2013-14 Jain Irrigation Systems Ltd., The Deputy Commissioner Of Jain Plastic Park, N.H No.6, Vs Income Tax, Circle-2, Jalgaon – 425001. . Jalgaon. Pan: Aaacj 7163 Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Percy Pardiwala; Shri Prashant Maheshwari & Ms.Monicamulchandani – Ar’S Revenue By Shri B Koteswara Rao – Dr Date Of Hearing 23/09/2022 Date Of Pronouncement 22/12/2022 आदेश/ Order Per S.S.Godara, Jm: This Assessee’Sappeal For Assessment Year 2013-14Is Directed Against Thedeputy Commissioner Of Income Tax, Cricle-2, Jalgaon’S Assessment Order Dated 29.10.2017, Framed In Furtherance To The Dispute Resolution Panel-3, Mumbai (Drp)’S Direction Dated 25.09.2017 Passed In Objection No.78, In Proceedings U/S 143(3) R,.W.S 144C(5) Of The Income Tax Act, 1961 [In Short “The Act”].

transfer pricing issue of disallowance of interest of Rs.68,40,000/- calculated at the ad-hoc rate of 12% of the interest free security deposits given to related parties in relation to two plots at Walkeshwar, Mumbai and similar claim ofRs.1542361/- regarding various leased properties. The Revenue could hardly dispute that the learned lower authorities have adopted their respective findings

M/S. OCWEN FINANCIAL SOLUTIONS PRIVATE LIMITED,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, appeal of the assessee is partly allowed

Bench: Shri R.S.Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपीऱ सं. / Ita No. 2520/Pun/2017 नििाारण वषा / Assessment Year : 2013-14 M/S. Ocwen Financial Solutions Private Limited. Pritech Park, Block-12, Unit-2, 5B & 6A Floors, Bellandur Village, Sarjapur, Marathahalli Ring Road, Bangalore-560 103. Pan : Aaaco3764E .......अऩीऱाथी / Appellant बिाम / V/S. The Assistant Commissioner Of Income Tax, Circle-11, Pune. ……प्रत्यथी / Respondent

158 of the paper book, it is specified about this company i.e. Jindal Intellicom Private Limited that in accordance with Accounting Standard 17- Segment Reporting, the company has only one reportable business segment call center services. 8.1 That having all these submissions, the Ld. Counsel for the assessee vehemently submitted that this company should be included in the final list