MOTT MACDONALD P.LTD,MUMBAI vs. DCIT CIR 2(2), MUMBAI

In the result, the appeal is allowed in the terms indicated above

House Dr R G Thandani Marg, Worli Mumbai 400 018 [AABCM0834G] Vs Deputy Commissioner of Income Tax Circle 2(2), Mumbai ….……......Respondent Appearances by Aarti Vissanji for the appellant Rignesh Das, Inder Solanki for the respondent Dates of hearing of the appeal : February 24th, 2020 May 27th, 2020 Date of pronouncing this order : O R D E R Per Pramod

DY.CIT 7(1) (1) , MUMBAI vs. M/S. MATTEL TOYS (INDIA) PVT. LTD, MUMBAI

In the result, the appeal of the Revenue is dismissed, whereas,

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2012-13 Dy. Cit, Circle-7(1)(1), M/S Mattel Toys (India) Pvt. Ltd., Room No. 126, 1St Floor, Phoenix House, B-Wing, 4Th Floor, Vs. Aayakar Bhavan, M.K. Road, 462, Senapati Bapat Marg, Lower Mumbai-400020. Parel, Mumbai-400013. Pan No. Aaccm 2563 P Appellant Respondent

House, B-Wing, 4th floor, Room No. 126, 1st floor, Vs. 462, Senapati Bapat Marg, Aayakar Bhavan, Lower Parel, M.K. Road, Mumbai-400013. Mumbai-400020. PAN No. AACCM 2563 P Appellant Respondent : Assessee by Mr. Ketan Ved, AR Revenue by : Mr. Jitendra Kumar, Sr. DR : Date of Hearing 07/11/2022 : Date of pronouncement 29/12/2022 M/s Mattel Toys (India

PROCTER & GAMBLE HOME PRODUCTS LTD,MUMBAI vs. ADDL CIT RG 8(2), MUMBAI

In the result, ground No. 3 of the

Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Procter & Gamble Home Products Ltd. Addl Cit Rg 8(2) P & G Plaza Cardinal Gracias Rd. Mumbai-400020. Chakala, Andheri (E)- 40009 Vs [Pan:Aaacp4072C] Appellant / Assessee Respondent / Revenue Procter & Gamble Home Products Addl Cit 8(2) Private Limited, Vs Mumbai-400020. P & G Plaza Cardinal Gracias Rd. Chakala, Andheri (E)- 40009 [Pan:Aaacp4072C] Appellant / Assessee Respondent / Revenue

House Property", in such case, only the expenditure related to building ought to be considered for disallowance and not the shared expenses which were not related to building at all. ii. The Appellant prays that for the purpose of disallowance; the AO be directed to consider only building related expenses. Ground VI: i. On the facts and circumstances

PROCTER & GAMBLE HOME PRODUCTS P.LTD,MUMBAI vs. ADDL CIT 8(2), MUMBAI

In the result, ground No. 3 of the

Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Procter & Gamble Home Products Ltd. Addl Cit Rg 8(2) P & G Plaza Cardinal Gracias Rd. Mumbai-400020. Chakala, Andheri (E)- 40009 Vs [Pan:Aaacp4072C] Appellant / Assessee Respondent / Revenue Procter & Gamble Home Products Addl Cit 8(2) Private Limited, Vs Mumbai-400020. P & G Plaza Cardinal Gracias Rd. Chakala, Andheri (E)- 40009 [Pan:Aaacp4072C] Appellant / Assessee Respondent / Revenue

House Property", in such case, only the expenditure related to building ought to be considered for disallowance and not the shared expenses which were not related to building at all. ii. The Appellant prays that for the purpose of disallowance; the AO be directed to consider only building related expenses. Ground VI: i. On the facts and circumstances

JT. CIT (OSD) - 2 (3)(1), MUMBAI vs. TATA SONS PRIVATE LTD., MUMBAI

house property income, the Tribunal restored the issue to the Assessing Officer, following precedents in the assessee's own cases for earlier assessment years. Regarding disallowance under Section 14A, the Tribunal directed that net interest expenses should be considered and addressed the issue of double disallowance, allowing the appeal for statistical purposes.", "result": "Partly Allowed", "sections": ["Section 92C

MONDELEZ INDIA FOODS P. LTD,MUMBAI vs. DCIT RG 5(1)(2), MUMBAI

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Housing Co. Ltd NC-Significant RPT 6 Crystal Hues Ltd 11.27% 7 Quadrant Communication Ltd 15.84% 8 Indus Technical and Financial Consultants Ltd 12.05% Average 11.35% 7. Accordingly, the TPO arrived at the TP adjustment as per below working:- Particulars Amount Expenditure incurred for developing the intangibles Rs.1,61,01,97,731 Mark-up on Expenditure incurred for developing

MONDELEZ INDIA FOODS P.LTD,MUMBAI vs. ASST CIT RG 5(1)(2), MUMBAI

Bench: Vikas Awasthy () & Ms. Padmavathy S. ()

Housing Co. Ltd NC-Significant RPT 6 Crystal Hues Ltd 11.27% 7 Quadrant Communication Ltd 15.84% 8 Indus Technical and Financial Consultants Ltd 12.05% Average 11.35% 7. Accordingly, the TPO arrived at the TP adjustment as per below working:- Particulars Amount Expenditure incurred for developing the intangibles Rs.1,61,01,97,731 Mark-up on Expenditure incurred for developing

MONDELEZ INDIA FOODS P.LTD (FORMERLY KNOWN AS CADBURY INDIA LIMITED),MUMBAI vs. ASST CIT RG 5(1)(2), MUMBAI

In the result, appeal filed by the assessee for AY 2013-14 is allowed for statistical purpose

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

House, Unit No.2001, 20th Floor Mumbai-400 020 Tower-3 (Wing C) India Bulls finance Centre), Parel, Mumbai0400 013 PAN : AAAC0460H APPELLANT RESPONDENT Present for the Assessee Shri J.D. Mistri, Shri Hiten Chande Present for the Department Shri Manoj Kumar – CIT DR Date of hearing 07/09/2023 Date of pronouncement 20/09/2023 O R D E R Per Padmavathy S (AM): These

TATA SONS LTD.,MUMBAI vs. ACIT,CIR 2(3)(1), MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

92C(3) are not satisfied before the passing of the final Assessment Order. (viii) On the facts and in the circumstances of the case, Transfer Pricing adjustments cannot be made without arriving at the finding that the intention of the assessee was to evade tax or manipulate prices or shift profits outside of India. Further, such finding of tax evasion

ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(3)(1), MUMBAI vs. TATA SONS LIMITED, MUMBAI

In the result, appeal by the Revenue is dismissed

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

92C(3) are not satisfied before the passing of the final Assessment Order. (viii) On the facts and in the circumstances of the case, Transfer Pricing adjustments cannot be made without arriving at the finding that the intention of the assessee was to evade tax or manipulate prices or shift profits outside of India. Further, such finding of tax evasion

TATA SONS PVT. LTD,MUMBAI vs. CIT (A)-58, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.1093/मुं/2019(िन.व. 2012-13) Tata Sons Private Limited, Bombay House, 24, Homi Mody Street, Fort, Mumbai 400 001. ...... अपीलाथ"/Appellant Pan: Aaact-4060-A बनाम Vs. The Commissioner Of Income Tax (Appeals)-58, Jcit, Room No.552, Aaykar Bhavan, M.K.Road, ....."ितवादी/Respondent Mumbai – 400 020 आअसं.1349/मुं/2019 (िन.व. 2012-13) Jt.Cit (Osd)-2(3)(1), Mumbai Room No.552, 5Th Floor, Aaykar Bhavan, M.K.Road, ...... अपीलाथ"/Appellant Mumbai – 400 020 बनाम Vs. Tata Sons Private Limited, Bombay House, 24, Homi Mody Stree, Fort, Mumbai 400 001. ....."ितवादी/Respondent Pan: Aaact-4060-A अपीलाथ""ारा/Appellant By : Ms. Arati Vissanji & Ms. Aastha Shah, Advocates. "ितवादी "ारा/Respondent By : S/Shri Manoj Kumar, Cit-Dr & Ujjwal Kumar Chavhan, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 22/12/2023 घोषणा की ितिथ/ Date Of Pronouncement : 15/03/2024

92C of the Act. As per RBI Circular (supra), where shares of an unlisted company are disinvested in a private arrangement, the share price should not be less than the value certified by a Chartered Accountant/Certified Public Accountant based on the latest Audited Financial Statement of the wholly owned subsidiary (WOS). It is an undisputed fact that TGBGL