ASSISTANT COMMISSIONER OF INCOME TAX, KOLHAPUR vs. UNDERCARRIAGE AND TRACTOR PARTS PRIVATE LIMITED, KOLHAPUR

In the result, the appeal of the Revenue is dismissed

Bench: Shri R.K. Panda & Ms. Astha Chandra

Transfer pricing documentation as per rule 10D r.w.s. section 92D. Perusal of Transfer pricing study report shows that the appellant

INCOME TAX OFFICER , JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED , JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

Transfer Pricing Officer TPO under Section 92CA could be invalid and bad in law.” 10. We have further considered the following various judgments passed by the Hon’ble Benches as relied upon by the Ld. AR: (i) ITAT Cuttack Bench in the matter of M/s. SKM- UMSL JV vs. ITO in ITA No. 229/CTK/2019 for A.Y. 2014-15 observed

INCOME TAX OFFICER WARD 1 JALNA, JALNA vs. VIKRAM TEA PROCESSOR PRIVATE LIMITED, JALNA

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2013-14

Transfer Pricing Officer TPO under Section 92CA could be invalid and bad in law.” 10. We have further considered the following various judgments passed by the Hon’ble Benches as relied upon by the Ld. AR: (i) ITAT Cuttack Bench in the matter of M/s. SKM- UMSL JV vs. ITO in ITA No. 229/CTK/2019 for A.Y. 2014-15 observed

DCIT, SWARGATE PUNE vs. ELICA PB WHIRLPOOL KITCHEN APPLIANCES PRIVATE LIMITED, PUNE

In the result, appeal of the Revenue in ITA No

Bench: the Hon'ble Tribunal which may please be granted.” Submission of ld.AR : 2. Ld.AR for the assessee submitted that Quantum Addition has been deleted by ITAT for A.Y.2014-15 in Assessee's own case in

Section 92D of the Act. However, ld.AR for the Assessee has submitted a list of documents which were filed before the Transfer Pricing

DCIT, SWARGATE vs. ELICA PB WHIRLPOOL KITCHEN APPLIANCES PRIVATE LIMITED, PUNE

In the result, appeal of the Revenue in ITA No

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 92D of the Act. However, ld.AR for the Assessee has submitted a list of documents which were filed before the Transfer Pricing

RENISHAW METROLOGY SYSTEMS LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 5,, PUNE

In the result, appeal of the assessee is dismissed

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपीलसं. / Ita No.619/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Renishaw Metrology Systems The Dy.Commissioner Limited, V Of Income Tax, Circle- S.No.283, Hissa No.2, S.No.284, S 5, Pune. Hissa No.2 & 3A, Raisoni Estate, Taluk – Mulshi, Dist-Pune. Pan: Aabcr6361F Appellant/ Assessee Respondent /Revenue Assessee By Shri Ajit Jain & Shri Siddesh Chaugule – Ar’S Revenue By Shri Suhas Kulkarni – Addl. Cit(Dr) Date Of Hearing 04/01/2024 Date Of Pronouncement 24/01/2024

transfer pricing study report maintained as per Section 92D of the Act read with Rule 10D of the Income-tax Rules

M/S VODAFONE GLOBAL SERVICES P LTD,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE 1(1),, PUNE

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.660/Pun/2022 Assessment Year : 2018-19

transfer pricing study report maintained as per section 92D of the Act. 3. Rejecting comparable companies functionally comparable to the Appellant

SEQUENCE DESIGN (INDIA) PRIVATE LIMITED,PUNE MAHARASHTRA vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE 1(1) PUNE, PUNE

In the result, appeal of the assessee is allowed

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2106/Pun/2024 Assessment Year : 2015-16

transfer pricing adjustment of Rs 4,07,42,345/- in respect of earlier years The Appellant prays leave to add, alter, vary, omit, amend, substitute, or delete grounds of appeal at any time before or at the time of appeal, so as to enable the Hon'ble Income Tax Appellate Tribunal to decide this appeal in accordance with

SEMPERTRANS INDIA PRIVATE LIMITED,ROHA vs. INCOME-TAX OFFICER, PANVEL

In the result, appeal filed by the assessee is partly\nallowed for statistical purposes

Price ('ALP') of the payment for services as 'NIL' by\ndisregarding the detailed benchmarking approach and the\nmethodology adopted by the Appellant in its TP documentation\nmaintained under section 92D of the Act read with Rule 10D of the\nIncome Tax Rules, 1962 ('Rules').\n8. Upholding/confirming the action of Ld. TPO, in going beyond\nthe scope under section 92CA

M/S. JYOTI PAPER UDYOG LTD,NASHIK vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NASHIK

In the result, appeal of the assessee is allowed

Bench: Shri R.S. Syal, Hon. Vice- & Shri Partha Sarathi Chaudhury, Hon.M/S. Jyoti Paper Udyog Ltd., Vs Acit, Circle-1, Plot No.B67, Nice, Midc Nashik. Satpur, Nashik – 422 007 Pan: Aaacj 7288 E Appellant Respondent Assessee By : Shri Sanket M. Joshi, Ca Revenue By : Shri Ramnath P Murkunde, Dr Date Of Hearing : 06/09/2023 Date Of Pronouncement : 20/09/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Order Of National Faceless Appeal Centre [Nfac], Delhi, Dated 28.04.2023 For A.Y.2013-14 As Per The Grounds Of Appeal On Record.

Transfer Pricing Regulations, in my opinion, the provisions of section 92C, 92D and 92E would not have application in the case

BAJAJ HOUSING FINANCE LIMITED,PUNE vs. ITO, WARD-8(1), PUNE, PUNE

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

Bench: Dr.Manish Borad

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction

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

In the result, the appeal of the assessee is allowed

Bench: Shri R.K. Panda & Ms. Astha Chandra

Transfer Pricing Officer, where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRAHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D

DEPUTY COMMISSIONER OF INCOME TAX, NASHIK vs. CHAKRADHAR CONTRACTORS AND ENGINEERS PRIVATE LIMITED, JALGAON

In the result, both the appeals of the Revenue are

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamore

Transfer Pricing Officer, where the assessee had maintained 13 ITA.Nos.1939 & 1940/PUN./2024 information and documents as prescribed under section 92D