PUBLICIS COMMUNICATIONS P. LTD,MUMBAI vs. DCIT CIR 7(3)(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Pricing Officer. 022. Ground no.3 and ground no.4 are with respect to depreciation on goodwill. The learned Assessing Officer disallowed the deprecation on goodwill amounting to ₹11,73,198/-. The learned Assessing Officer made the above disallowances on protective assessment manner. The assessee company entered into business transfer

PUBLICIS COMMUNICATIONS P.LTD,MUMBAI vs. DCIT CIR 7(1), MUMBAI

In the result, for assessment year 2012 – 13, appeal of the assessee is allowed for statistical purposes whereas the cross objection of the assessing officer is dismissed

Bench: Shri Prashant Maharishi, Am & Shri Kuldip Singh, Jm

Pricing Officer. 022. Ground no.3 and ground no.4 are with respect to depreciation on goodwill. The learned Assessing Officer disallowed the deprecation on goodwill amounting to ₹11,73,198/-. The learned Assessing Officer made the above disallowances on protective assessment manner. The assessee company entered into business transfer

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

disallowance made u/s\n14A.\n Assessment Year 2010-11\n6. From the Transfer Pricing study report the Ld. TPO noted

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

disallowing\nthe Appellant's claim for tax credit of Rs 9,96,61,577 being the 'Singapore tax\npaid as defined under Article 25 (3) of the of the Double Tax Avoidance Agreement\nbetween India and Singapore.\nGrounds related to Transfer Pricing

VODAFONE INDIA LTD,MUMBAI vs. ASST CIT 8(3)(2), MUMBAI

Transfer Pricing Officer has exceeded his jurisdiction by disallowing certain expenditure, is against the facts. The Transfer Pricing Officer has not disallowed

3I INFOTECH LIMITED,MUMBAI vs. PR. CIT- 15, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm 3I Infotech Limited Pcit-15 Tower No.5, 5Th Floor, Aaykar Bhavan, 3Rd To 6Th Floors, Vs. International Infotech Park, Mumbai-400 020 Vashi, Navi Mumbai-400 703 (Appellant) (Respondent) Pan No. Aaaci5205Q Assessee By : Shri Bhupendra Karkhanis, Shri Jay Dharod, Ars Revenue By : Ms. Samruddhi Hande, Dr Date Of Hearing: 17.02.203 Date Of Pronouncement : 10.05.2023

pricing order the matters for which adjustments/ disallowances are made and that the transactions whose ALP is accepted or expenses for which no disallowances are to be made, do not find any place in either assessment order or in Transfer

TATA CONSULTANCY SERVICES LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOMETAX 3(4), MUMBAI

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

disallowing the Appellant's claim for tax credit of Rs 9,96,61,577 being the 'Singapore tax paid as defined under Article 25 (3) of the of the Double Tax Avoidance Agreement between India and Singapore. Grounds related to Transfer Pricing

THOMAS COOK (INDIA) LTD.,MUMBAI vs. ADDL/ JT/ DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT CENTRE, DELHI

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

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Ble

transfer pricing provisions since they are merely 'machinery provisions and not charging provisions 2. Disallowance of principal lease payment of finance

ACIT-23(1), MUMBAI, PIRAMAL CHAMBER, MUMBAI vs. PARISHI DIAMONDS, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2012-13 Acit-23(1), Parishi Diamonds, 511, 5Th Floor, Piramal Chamber, Cc2091 To Cc 2093 Tower Central Vs. Lalbaug, Parel, Wings Bharat Diamond Bourse Bandra Mumbai-400012. Kurla Complex, Bandra East, Mumbai-400051. Pan No. Aajfp 2118 B Appellant Respondent

price. The requirement to maintain having regard to arm's length price. The requirement to maintain having regard to arm's length price. The requirement to maintain documentation is mandatory as pr documentation is mandatory as provided in sec.92D) r.w. Rule 10D. ovided in sec.92D) r.w. Rule 10D. The significance of maintenance of documentation has The significance of maintenance

DCIT 1(1), MUMBAI vs. HSBC ASSET MANAGEMENT (I) P. LTD, MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

Transfer Pricing additions made by the AO/TPO to the extent of Rs. 3,08.96,398 (Rs.1,13,82,173+ Rs.1,21,92,637+ Rs.28,31,154 + Rs.44,90,434) to the total income of the appellant by erroneously disallowing

HSBC ASSET MANAGEMENT (INDIA) P.LTD,MUMBAI vs. ASST CIT 1(1), MUMBAI

In the result, the appeal by the assessee is allowed

Bench: Shri M. Balaganesh & Shri Sandeep Singh Karhail

Transfer Pricing additions made by the AO/TPO to the extent of Rs. 3,08.96,398 (Rs.1,13,82,173+ Rs.1,21,92,637+ Rs.28,31,154 + Rs.44,90,434) to the total income of the appellant by erroneously disallowing

SHAPOORJI PALLONJI AND COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -3(3)(1), MUMBAI

Appeals are partly allowed

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI JAGADISH (Accountant Member)

Transfer Pricing Addition of INR. INR.5,67,32,905/-. The Assessing Officer also disallowed deduction of INR.12,95,04,995/- claimed